The Medicare and Medicaid programs take different approaches to reimbursing telehealth services. This article provides an overview of current reimbursement policies and links to resources for navigating the complexities of Medicare and Medicaid telehealth coverage.
Medicare Telehealth Coverage
To expand access to healthcare, the Centers for Medicare & Medicaid Services (CMS) continue to cover a wide range of telehealth services. While some flexibilities introduced during the COVID-19 public health emergency (PHE) have been extended, others have expired. Below is an updated overview of Medicare’s telehealth policies.
Medicare Telehealth Services
Medicare reimburses for synchronous (real-time) telehealth consultations across a variety of medical settings. Key updates include:
- Permanent Expansion: Patients can now receive telehealth services from home for many medical conditions without requiring an in-person visit first.
- Expanded Provider Types: Federally qualified health centers (FQHCs) and rural health clinics (RHCs) remain eligible telehealth providers.
- Audio-Only Services: Coverage for audio-only visits has been extended for specific services, particularly for behavioral health.
Virtual Check-Ins
Virtual check-ins allow brief, patient-initiated communications with physicians to assess whether an in-person visit is needed. These are billed using:
- HCPCS code G2012 – Synchronous (real-time) communication.
- HCPCS code G2010 – Asynchronous (store-and-forward) communication.
Recent Changes: Some telehealth flexibilities related to virtual check-ins have expired, so providers should verify coverage based on current CMS guidelines.
E-Visits
E-visits involve patient-initiated, non-face-to-face interactions through a patient portal. Common billing codes include:
- CPT codes 99421-99423 – Time-based e-visits for established patients.
- HCPCS codes G2250 and G2251 – Asynchronous e-visits for specific provider types.
- New Considerations: CMS continues to refine its e-visit policies, and reimbursement depends on service type and provider eligibility.
Medicaid & Telehealth
Medicaid’s telehealth coverage varies significantly by state. All 50 states and Washington, D.C., offer reimbursement for live video services under Medicaid fee-for-service, but requirements differ.
Key policy trends include:
- State-Specific Rules: Medicaid programs define their own reimbursement policies, including eligible services and provider types.
- Originating Site Flexibility: Many states now allow home-based telehealth, but some still restrict services to specific locations.
- Parity Laws: Some states require Medicaid to reimburse telehealth services at the same rate as in-person visits, while others do not.
Providers should refer to state Medicaid agencies or the Center for Connected Health Policy (CCHP) for the latest regulations.
Medicaid offers reimbursement fordelivered via telehealth. This service is available in all fifty states and Washington DC under Medicaid fee-for-service. However, it’s important to note that to qualify for reimbursement, the services must meet federal requirements. The specifics of what and how they are reimbursed can vary significantly. Common restrictions include limitations on specialty types, service codes, and provider types, as well as requirements for patient location at specific originating sites.
Medicaid & Remote Patient Monitoring (RPM)
As of 2024, 43 state Medicaid programs reimburse for remote patient monitoring (RPM), an increase from previous years. However, reimbursement policies differ widely:
- Eligible Conditions: Some states restrict RPM reimbursement to chronic conditions like diabetes and hypertension.
- Provider Limitations: Certain states only allow home health agencies or physicians to bill for RPM services.
- Technology Requirements: States may specify which devices qualify for reimbursement.
Providers should check state-specific guidelines for coverage details.
Medicaid & Remote Therapeutic Monitoring (RTM)
Medicaid coverage for remote therapeutic monitoring remains limited, but some states are exploring reimbursement. Medicare, on the other hand, fully reimburses RTM services, covering:
- Device supply and setup
- Data collection for at least 16 out of 30 days
- Time spent analyzing patient data and modifying treatment
Providers should monitor updates from CMS and state Medicaid programs regarding RTM expansion.
Medicaid & Telehealth Resources
For up-to-date Medicaid telehealth reimbursement policies, the Center for Connected Health Policy (CCHP) remains the leading resource.
- Policy Finder Tool: Tracks Medicaid telehealth policies across all 50 states, Washington, D.C., Puerto Rico, and the Virgin Islands.
- Updated Reports: CCHP regularly compiles the latest state and federal telehealth policies.
Access the Center for Connected Health Policy to stay current on reimbursement regulations. The free Policy Finder tool offers a database to search each state’s regulations and policies surrounding telehealth and remote patient monitoring.
Understanding Medicare and Medicaid Telehealth
Understanding Medicare and Medicaid telehealth coverage is essential for optimizing healthcare delivery. By leveraging available resources and staying informed about policy changes, healthcare providers and organizations can enhance patient access to vital services.
