Telehealth Billing 2.0: Codes, Modifiers & Compliance Post‑Pandemic

The COVID-19 pandemic accelerated the adoption of telehealth like never before. What was once a convenience quickly became a necessity—reshaping the way providers deliver care and bill for services. As we transition into a post-pandemic era, the regulatory environment surrounding telehealth billing is evolving. What was temporarily permitted under emergency waivers is now being reassessed and codified under new federal and state policies.

Welcome to Telehealth Billing 2.0—where staying compliant, up to date on CPT/HCPCS codes, and using correct modifiers is crucial for accurate reimbursement and reduced denials. In this blog, we’ll break down the essential components of modern telehealth billing, including current codes, modifier usage, documentation standards, and compliance best practices.

The Post-Pandemic Telehealth Landscape

During the Public Health Emergency (PHE), CMS and private payers relaxed restrictions on telehealth billing, allowing:

• Use of smartphones and audio-only devices
• Expansion of eligible providers
• Elimination of rural location requirements
• Parity reimbursement for virtual and in-person visits

With the PHE ending, several of these flexibilities are being rolled back or restructured. Providers must now adapt billing practices to comply with the revised regulations and payer-specific guidelines.

Current CPT and HCPCS Codes for Telehealth

To ensure accurate telehealth billing, providers must use the most current set of CPT and HCPCS codes. Below is an updated list of common services reimbursed via telehealth:

✅ Evaluation & Management (E/M) Services (Office Visits)

• 99202–99215
  These codes are billable when visits are conducted via audio-video platforms. As of 2024, time or medical decision-making (MDM) can still be used for E/M code selection during telehealth.

Note: For established patients, 99212–99215 remain commonly used.

✅ Virtual Check-Ins

• G2012: Brief communication via telephone (5–10 minutes)
• G2251: Brief communication via audio-only
• G2252: Extended virtual check-in (11–20 minutes)

Used when a patient reaches out for minor concerns that do not result in an in-person visit.

✅ Remote Patient Monitoring (RPM)

• 99453: Device setup and patient education
• 99454: Device supply with daily recordings
• 99457: 20 minutes of remote monitoring management
• 99458: Additional 20 minutes

RPM services are considered telehealth-related but require real-time data transmission and documentation of patient interaction.

✅ Audio-Only Telehealth Codes

• 99441–99443: Telephone E/M services (5–30 minutes)
  These were temporarily reimbursed under the PHE and continue to be accepted by many payers through 2025, especially for behavioral health and rural settings.

Understanding Telehealth Modifiers

Using the correct modifiers is essential to indicate that a service was delivered virtually and to avoid claim denials. Here’s what you should be applying:

🔹 Modifier 95

• Used for synchronous telemedicine services rendered via real-time interactive audio and video.
• Commonly paired with office E/M codes (99202–99215).

🔹 Modifier GT (less common)

• Previously used for interactive audio-video telecommunications.
• Still accepted by some Medicaid programs and commercial payers.

🔹 Modifier GQ

• Indicates asynchronous telemedicine (e.g., store-and-forward technology).
• More relevant to specialties like dermatology or radiology.

🔹 Modifier 93

• Introduced recently to designate audio-only telehealth services.
• Used when billing 99441–99443 or similar codes.

Always check payer policies—some commercial insurers still require POS 02 (Telehealth) and POS 10 (Telehealth – Home) combinations in addition to modifiers.

Place of Service (POS) Codes for Telehealth

➤ POS 02 – Telehealth Provided Other than in Patient’s Home

Used when the patient receives telehealth services from a location other than their home (e.g., clinic, nursing home).

➤ POS 10 – Telehealth Provided in Patient’s Home

Introduced to better track home-based services. Providers must accurately distinguish between POS 02 and POS 10 based on where the patient is located during the encounter.

Documentation Requirements for Telehealth

To remain compliant and audit-ready, providers must document:

• Mode of delivery: audio-video or audio-only
• Location of patient and provider at the time of service
• Patient consent to receive services virtually
• Clinical content that supports CPT code selection (history, exam, decision-making)
• Time spent when billing time-based codes

Documentation must meet the same standard as in-person services, especially for E/M levels and time-tracked services.

Compliance and Risk Management

In the post-pandemic world, CMS and private payers are auditing telehealth claims more aggressively. Common pitfalls that lead to denials or clawbacks include:

• Inaccurate use of modifiers (e.g., missing Modifier 95 for a video visit)
• Billing for ineligible providers or services
• Documentation not supporting billed code
• Misuse of audio-only codes for video visits
• Failing to obtain/verbalize patient consent

✅ Tips for Staying Compliant:

• Use coding cheat sheets specific to your specialties
• Audit telehealth claims quarterly
• Train staff on updated billing rules and modifiers
• Confirm payer-specific policies before submission
• Use billing software that auto-suggests modifiers based on visit type

Specialty-Specific Considerations

🩺 Behavioral Health

Behavioral health services continue to enjoy more relaxed audio-only policies, with many insurers reimbursing parity rates for psychotherapy sessions.

🩺 Primary Care & Internal Medicine

Many primary care providers are using G2012 and G2252 for brief follow-ups and medication management—keeping patients engaged without unnecessary visits.

🩺 Chronic Care Management

Chronic care and remote monitoring services (99457, 99458) are reimbursable as long as clinical staff document patient interaction and clinical decision-making.

Telehealth Billing Challenges and Solutions

The Future of Telehealth Billing

As more services become digitized, we can expect:

• More granular CPT codes specific to virtual care
• Wider adoption of AI in documentation and coding
• Increased scrutiny from payers to avoid overutilization
• Growing demand for patient-friendly billing practices

Providers who invest now in accurate, compliant telehealth billing processes will be well-positioned to thrive in the hybrid care era.

Final Thoughts

Telehealth is here to stay, but billing for it has moved beyond emergency flexibility into a compliance-first environment. Mastering Telehealth Billing 2.0 means staying current with CPT and HCPCS codes, applying the right modifiers, documenting thoroughly, and customizing your billing strategy by specialty and payer.

At Right Medical Billing, we help practices navigate this transition with up-to-date billing services, audit support, and telehealth reimbursement strategies that maximize revenue and reduce denials.