Telehealth Billing

# Understanding Telehealth Billing: What’s New in 2025

- January 13, 2025
- Posted by Kristen Edwards

27 May

During the Covid pandemic, telehealth emerged as a new discipline in the healthcare sector, with new endeavors and protocols. Billing for telemedicine remains a great obstacle for healthcare providers, and a revolution has been made with time in the billing process. New rules and regulations continuously improve the telehealth billing process, but some intricate patterns are still present, which are newly addressed and resolved in the 2024 updates. The Centre of Medicare and Medicaid (CMS) is updating telemedicine billing by introducing new and more accurate codes and reimbursement policies.

We will learn the basic concept of how telehealth billing works; we know CMS telehealth billing guidelines 2023, but the new CMS telehealth billing guidelines 2024, telehealth reimbursement policies, regulatory changes, and best practices to ensure accuracy and efficiency.

## Understanding Telehealth Billing

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Telehealth is the provision of opportunity to distant or remote areas people to the healthcare practitioners. This system was introduced during the pandemic time when patients were restricted or afraid to visit the doctors, and healthcare was provided to them through video calls and live calls using innovative technologies. But now the question comes to how they are billed for the services provided. Three models handle the billing process.

### 1. Subscription-based model

There are many subscription plans available in which specific medical services are given to the patient. Patients can choose their subscription plan according to their needs and enjoy telehealth services when needed.

### 2. Medicare and Medicaid

Medicare and Medicaid are government programs, and people who are part of these models can get medical services from the doctors registered with this model. Healthcare practitioners can get reimbursement for the services given by the government health department.

### 3. Fee for service

In this model, there are no subscription criteria, and the patients must pay each time for the services they get. This model can be expensive, and patients may receive unexpected bills. It is recommended for that doctors to provide every bit of detail to the patient before providing any medical service to make the whole process transparent.

## Telehealth Billing Updates

CMS has decided to extend telehealth coverage in the US, and they have also introduced new updates regarding billing protocols. They have changed the scenario of sending bills for the reimbursement rate. Following are some CMS telehealth billing guidelines:

- According to the current line of updates, hospitals will now include the modifier “95” along with the hospital place of service code to bill for telehealth medical services.
- Audiologists are restricted from using the modifier “95” from now on, and they can use POS “02” for services rendered at satellite offices and POS “10” for services conducted at patients’ homes.
- Therapists, including the SLPs, can use the modifier “95,” and they are not supposed to use the POS code. They can mention POS if they want to indicate the area of service provision.
- Telehealth service provided at a patient’s home billed with POS “10” will be imbursed at a higher rate by the CMS. The CMS will reimburse Telehealth service billed with POS “02” at a lower rate.

## Telehealth Reimbursement Updates 2024

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CMS telehealth billing guidelines 2024 are concerned with the new reimbursement policies under the Physician Fee Schedule (PFS) for Medicare payments. These updates bring changes regarding the telehealth and remote patient monitoring:

### 1. Established patient requirement

This rule concerns new patients seeking RPM services. As opposed to established or previous patients, new patients have to undergo evaluation and management (E/M). There are a few exceptions to this rule, including patients who received services during a public health emergency (PHE). This update also does not apply to remote therapeutic monitoring (RTM) reimbursement.

### 2. 16-Day Data Collection for Remote Monitoring

- Healthcare practitioners are now supposed to collect data for CPT codes 99453 and 99454 for 16 days within 30 days of care. This indicates continuous monitoring all the time.
- This 16-day data collection rule is not applicable for time spent codes 99457 or 99458. This denotes the difference in billing protocols for different telehealth services.
- The two-day rule during the public health emergency has also come to an end.

### 3. RPM/RTM “Time Spent” clarification

- Billing guidelines for the 30-day calendar month will be followed for time spent codes 99457, 99458, 98980, and 98981.
- 16-day data collection is not applicable for time spent codes.

### 4. Concurrent billing rule

RTM and RPM cannot be billed for similar services together in the same month. These can be billed together for specific services, which include Chronic Care Management (CCM) and Behavioral Health Integration (BHI), Transition Care Management (TCM), and Chronic Pain Management (CPM).

### 5. RPM billing and Global surgery period

It is a rule that a physician during the global surgery period cannot bill for office visits. But the question arises: what is the global surgery period? If the patient has gone through some surgery and is billed for that treatment, then we will not pay for visits he will make during that period. This time duration is called the global surgery period.

However, there is a condition that if a patient is receiving RPM service prior to surgery procedure or from a physician different from the physician receiving global surgery payment, then CMS will pay for RPM services.

### 6. Single provider billing restriction

There is a change in CMS telehealth billing guideline 2024, which states that multiple providers are not eligible for the claim for RMP/RTM services, contrary to previous rules. Now, only one provider will get the reimbursement for RPM codes, including 99453 and 99454, or RTM codes 98976, 98977, 98980, and 98981. The practitioner who will submit the claim first will be imbursed only.

### 7. Updated cost structure

To make the telehealth service easily accessible and practical to the people, CMS has updated the cost fee structure for the services. There is a decrease in overall reimbursement rates for many codes for the services, including Chronic Care Management (CCM), RPM, and RTM. Providing complete details is separate from the subject of this article, but the previous and new costs for RPM are given below for quick assessment.

Remote Patient Monitoring (RPM) Reimbursement Rates:

CPT Code | 2023 Price | 2024 Price
99453 | $ 19.32 | $ 19.65
99454 | $ 50.15 | $ 46.83
99457 | $ 48.80 | $ 48.14
99458 | $ 39.65 | $ 38.64
99091 | $ 54.22 | $ 52.71

## Conclusion

Telehealth medical billing is complex, and policies are being updated to make the process effective and valuable for patients. Three models, including fee for service, subscription model, and Medicare and Medicaid model, are present to cover telehealth billing. The new regulatory policies should be adopted to optimize the process for enhancing patient experience, generating more revenue, and minimizing telehealth billing complexities.

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