Get to Know About Telehealth Reimbursement Playbook

Telehealth Reimbursement Playbook: Navigating Audio-Only & Device-Based Care

Telehealth has evolved from a niche service to a mainstream healthcare delivery model. Fueled by the COVID-19 pandemic, patients and providers have embraced remote care as a safe, convenient, and effective alternative to in-person visits. However, the reimbursement landscape is far from straightforward. One of the biggest challenges lies in understanding how audio-only visits and device-based remote monitoring services are covered, billed, and reimbursed.

This blog provides a comprehensive reimbursement playbook for providers navigating telehealth—covering regulations, billing codes, payer differences, and workflow strategies to maximize revenue without compromising compliance.

The Evolution of Telehealth Reimbursement

Historically, Medicare and many private payers restricted telehealth reimbursement to limited geographic areas and specific originating sites. The pandemic changed everything. Emergency waivers expanded coverage for:
– Telehealth delivered to patients at home.
– Audio-only visits when video wasn’t feasible.
– Remote patient monitoring (RPM) using devices like blood pressure cuffs or glucose monitors.

While some flexibilities were temporary, others have become permanent, making telehealth a core part of modern healthcare delivery.

The Two Pillars: Audio-Only vs. Device-Based Care

Audio-Only Telehealth
Not all patients have access to broadband internet, smartphones, or video-capable devices. For them, audio-only visits (telephone consultations) are essential. These encounters may include:

Behavioral health counseling.
Primary care check-ins.
Follow-up visits for chronic conditions.

Reimbursement dynamics:

Medicare: Currently reimburses audio-only E/M codes (99441–99443) at parity with in-person visits in certain contexts, particularly for behavioral health.
Commercial payers: Coverage varies—some reimburse at parity, others pay less than video visits.
Medicaid: Rules differ by state, but many continue to support audio-only reimbursement due to access concerns.

Device-Based Care (Remote Patient Monitoring)

Device-based telehealth involves collecting patient data through connected medical devices and transmitting it for provider review. Examples include:

Daily blood pressure monitoring.
Glucose tracking for diabetic patients.
Pulse oximetry for chronic respiratory disease.

Reimbursement dynamics:

CPT codes 99453–99458 cover RPM setup, device supply, and data monitoring.
Medicare: Pays monthly for RPM services, provided data is collected on at least 16 days in a 30-day period.
Commercial payers: Increasingly adopting RPM coverage, though requirements vary.
Medicaid: Expanding but inconsistent—some states cover RPM for chronic conditions, others limit coverage.

Ethical and Compliance Considerations

When billing for telehealth, practices must balance revenue optimization with ethical responsibilities.

Audio-only visits: Ensure documentation supports medical necessity, not just a check-in.
RPM services: Providers must meet CMS requirements for patient consent, data thresholds, and device qualification.
No double billing: Providers cannot bill for both a full telehealth E/M visit and RPM monitoring of the same data set without clear clinical justification.

Failure to follow rules can lead to denials, audits, and recoupments.

Key Telehealth Billing Codes

Audio-Only E/M (Medicare and some payers)

99441: 5–10 minutes of medical discussion.
99442: 11–20 minutes.
99443: 21–30 minutes.

Behavioral Health Audio-Only

98966–98968 (non-physician telephone visits).
Coverage is strong, especially for mental health services.

Remote Patient Monitoring (Device-Based)

99453: Initial setup & patient education.
99454: Device supply & data transmission.
99457: First 20 minutes of provider management per month.
99458: Each additional 20 minutes.

Payer-Specific Considerations

Medicare

Covers audio-only for behavioral health permanently.
RPM reimbursed if 16 days of readings are submitted monthly.
Strict rules around provider type, consent, and device qualification.

Medicaid

Varies by state—some pay for audio-only primary care, others restrict to behavioral health.
RPM is growing but not yet universal.

Commercial Payers

Many adopted telehealth parity laws during COVID-19, but reimbursement can differ post-pandemic.
Contract negotiations are key to securing parity for audio-only visits.

Common Pitfalls in Telehealth Billing

1. Inadequate Documentation

Simply stating “telehealth visit completed” is insufficient. Providers must document time, modality (audio vs. video), and medical necessity.

2. Wrong Modifiers

– Modifier 95: For synchronous telemedicine via video.
– Modifier FQ: Audio-only telehealth.
– Modifier FR: Two-way audio-video telehealth.

3. Misuse of Place of Service (POS) Codes

– POS 02: Telehealth provided other than patient’s home.
– POS 10: Telehealth provided in patient’s home.

4. Not Verifying Payer Policies

– Payers differ dramatically in audio-only reimbursement. Practices must verify coverage before services.

Optimizing Workflows for Telehealth Reimbursement

Step 1: Eligibility Verification
– Confirm if telehealth, audio-only, or RPM is covered under the patient’s plan.
– Check payer-specific modifiers and POS code requirements.

Step 2: Document Thoroughly
– Capture time spent, modality, patient consent, and medical necessity.
– For RPM, ensure patient data meets the 16-day threshold.

Step 3: Automate Where Possible
– Use EHR templates for telehealth documentation.
– Automate claim submission with correct modifiers.
– Flag patients eligible for RPM services.

Step 4: Train Frontline Staff
– Educate schedulers and billing staff on differences between audio-only and video visits.
– Create quick-reference guides for CPT codes and payer rules.

Step 5: Monitor Denials
– Track denials by payer and service type.
– Adjust workflows to minimize repeat errors.

The Financial Impact of Telehealth Done Right
When billed correctly, telehealth can become a significant revenue stream:

Audio-only visits allow providers to reach underserved populations who lack video access.
Device-based RPM provides ongoing monthly reimbursement and improves chronic care outcomes.
Reduced no-show rates increase efficiency and provider productivity.

At the same time, correct billing protects against audits, ensures compliance, and strengthens patient trust.

Best Practices for Success

Use technology to your advantage: Implement telehealth platforms that integrate billing workflows.
Stay updated: Regulations and payer policies change frequently—assign a compliance lead to track updates.
Educate patients: Let patients know telehealth is covered and clarify if visits are audio-only or device-based.
Negotiate contracts: Push commercial payers for parity in reimbursement across telehealth modalities

Final takeaway

The future of healthcare is hybrid—where in-person, video, audio-only, and device-based care complement one another. Providers who understand the reimbursement nuances of telehealth will be better positioned to maximize revenue while expanding access to care.

The playbook is clear:

Bill audio-only visits ethically, using correct codes and modifiers.
Leverage device-based monitoring for chronic care reimbursement.
Train staff and monitor workflows for compliance.
By mastering the dynamics of audio-only and device-based care, providers can transform telehealth from a regulatory headache into a sustainable, patient-centered revenue strategy.