Telephone vs Telemedicine: Code and Bill Correctly During COVID-19

Betsy Nicoletti, MS


May 18, 2020

The Coding Expert Answers Your Questions

Betsy Nicoletti, MS, a nationally recognized coding expert, will take your coding questions via email and provide guidance on how to code properly to maximize reimbursement. Have a question about coding? Send it here.

In this column, Nicoletti discuses a recent decision by the government to align rates for telephone-based visits with those for face-to-face office visits.

Editor's note: A previous version of this article incorrectly stated that phone calls did not need to be patient initiated. CPT says "These codes are used to report episodes of care initiated by an established patient...." CMS is allowing them to be used for new or established patients, but did not comment on patient-initiation.

Getting Paid for Patient Visits Over the Phone

Q: The Centers for Medicare & Medicaid Services (CMS) says it will now pay for telephone visits during the public health emergency at the same rate as for in-office visits. How does my internal medicine practice code for these visits correctly? How do these codes differ from telemedicine codes?

A: With all of the changes that CMS has implemented since the beginning of the COVID-19 crisis, this one has generated a great deal of questions; several physicians have asked about this.

In March, CMS announced that it would pay for telephone call codes, using codes that were previously noncovered, for services provided with audio only. The change in policy was part of a wide package announced by the Trump Administration amid the COVID-19 pandemic and came on the heels of earlier announcements broadening the use of telemedicine.

Many medical practices were disappointed in telehealth rates and told Medicare that not all of their patients have the equipment needed for evaluation and management (E/M) services via telemedicine, which requires audio and visual real-time interactive technology.

On April 30, CMS announced that it would increase the payment for audio-only phone calls and made the increased payment retroactive to March 1, 2020.

It added the codes 99441-99443 to the Medicare telehealth list, for practitioners who have E/M in their scope of practice. This includes physicians, nurse practitioners, clinical nurse specialists, certified nurse midwives, and physician assistants.

Here are details on the codes:

99441: Telephone E/M service by a physician or other qualified healthcare professional who may report E/M services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

99442: 11-20 minutes of medical discussion

99443: 21-30 minutes of medical discussion

Although Current Procedural Terminology (CPT) describes these as services to established patients, CMS is waiving that requirement and allowing these codes to be used for both new and established patients.

CMS did not waive the other code descriptors, that the call cannot be a result of an E/M service in the past 7 days or result in an E/M service in the next 24 hours or soonest available appointment.

Reimbursement for Phone Calls

CMS has increased the payment for telephone calls retroactive to March 1 and is paying at the rate of codes 99212-99214:



National nonfacility payment

National facility payment














The times are similar as well. Practices can select the telephone code based on the total time spent on the phone by the practitioner with the patient.

99441: 5-10 minutes       99212: 10 minutes
99442: 11-20 minutes       99213: 15 minutes
99443: 21-30 minutes       99214: 25 minutes

Besides adding these codes to the telehealth list released at the end of April, CMS added a column to the list that showed what services can be provided with audio equipment only.

For Medicare, do not use place of service 02 (telehealth) for codes on the telehealth list. Use the place of service where the service would have been furnished if done face-to-face. For phone calls, this is most likely to be office or outpatient department. Do add modifier -95 to the codes for Medicare services, however.

I've also received questions via email on the following aspects of telehealth and COVID-19, so here are some answers to help those of you who've asked.

Office Visits via Telemedicine

When billing for office visit codes 99201-99215 done via telemedicine, real-time, interactive audio and visual equipment is still required. During the time of the public health emergency, CMS is allowing practitioners to select the level of service for these office visits based on total time or medical decision-making.

CMS clarified in its April rule that practitioners should use CPT times. Counseling does not need to dominate the visit in order to use time.

Other Communications-Based Technology Services

Online digital E/M services 99421-99423 and virtual communication codes G2010 and G2012 are not considered telehealth services. These codes were developed for use by physicians, physician assistants, and advanced nurse practitioners performing brief, online E/M services via a secure platform.

CMS defines them as communications-based technology services. Because they are not on the telehealth list released by Medicare at the end of April, don't use POS 02 or modifier 95 on these codes, as they aren't telehealth codes.

Cost Sharing and Modifier CS

It is a federal law that health insurers cover testing for COVID-19 and the visit at which the testing is ordered without assessing a patient due amount.

Append modifier CS to the test and to the visit in order to get paid. This can apply to services retroactive to March 18. There are limited circumstances in which there is no cost sharing and there will be patient due amounts for treatment for COVID-19.

All of these changes are in effect during the time of the public health emergency.

Have a coding question? Send it in and it may be answered in a future column. (Please be sure to note your specialty in the text of the question.)

Betsy Nicoletti, MS, is a consultant, author, and speaker as well as the founder of, a library of medical practice coding resources.

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