Billing and Reimbursement

The relationship between telemedicine reimbursement and access to care has evolved significantly over the past few years, largely spurred by necessity during the COVID-19 pandemic.

Telemedicine has the potential to improve access to care and reduce healthcare expenditures. 
Examples:
• In the emergency setting where specialists may not be on site, virtual consultations can limit the need for transportation of patients to other facilities for care. Estimates predict that teleconsults can obviate the need for up to 850,000 transfers and save $537 million per year.
• Specific to allergy, a pilot study of 50 patients utilizing telemedicine to evaluate patients for penicillin allergy demonstrated high patient satisfaction and potential savings of over $30,000 due to increased access to specialty allergy care and improved antibiotic stewardship.

There are ongoing efforts from multiple patient and physician advocacy groups for permanent laws providing parity of coverage and reimbursement for telemedicine services.

•    Coverage parity = both in-person and telemedicine services are covered for the same indication.
Forty-one states plus the District of Columbia have an explicit requirement for coverage parity.
•    Payment parity = reimbursement for telemedicine services approximates that of the equivalent in-person E/M service.
As of the Fall of 2025, twenty-four states have an explicit requirement for payment parity.

Parity increases adoption of telemedicine.  
•    Almost 90% of both users and non-users (of telemedicine) said they would use telehealth if they were to be reimbursed.  
•    A 77.5% increase in telehealth adoption was noted after implementation of parity in Michigan.

References:
http://www.amdtelemedicine.com/telemedicine-resources/documents/ATATelemedicineResearchPaper_impact-on-healthcare-cost-and-quality_April2013.pdf
 
Mary L. Staicu, Anne Marie Holly, Kelly M. Conn, Allison Ramsey. The Use of Telemedicine for Penicillin Allergy Skin Testing. The Journal of Allergy and Clinical Immunology: In Practice, Volume 6, Issue 6, 2018, Pages 2033-2040

https://www.cchpca.org/topic/parity/

https://www.ajmc.com/newsroom/lack-of-reimbursement-barrier-to-telehealth-adoption

Variability in Reimbursement Rules Among States Contributes to Confusion
No two insurers or states are alike in how they define or cover telehealth services.

•    Currently, 44 states, Washington, DC, Puerto Rico and the U.S. Virgin Islands have laws that govern private payer telehealth reimbursement policies.

•    All 50 states and Washington, DC, provide reimbursement for some form of live video in Medicaid fee-for service, with fewer states covering store-and-forward or remote physiologic monitoring.

Know if your site qualifies for billing an originating site fee, facility fee, or transmission fee. Currently, 18 states and DC have a specific list of sites that can serve as the originating site for a telehealth encounter.  Thirty-five states will reimburse either a transmission, facility fee, or both. Be familiar with the rules if the referring physician and the consulting physician are at the telemedicine visit at the same time. For example, the consulting physician would bill for the visit and the referring physician would bill an originating site or facility/transmission fee if the visit was conducted while the patient was located at the referring physician’s office. 

Special note regarding transmission fees: Code T1014 has largely been phased out or remains state-/payer-specific and is not broadly reimbursed under Medicare for telehealth transmission fees.

Interactive 50 state map of telemedicine reimbursement policies.

CMS Has Made Sweeping Changes in Telemedicine Reimbursement, Designed to Improve Access to Care
CMS has historically placed strict limits on criteria for telemedicine reimbursement:
•    Rural location of patient
•    Originating site must be a health center
•    Service must be synchronous live video

Medicare Telehealth Payment Eligibility Analyzer (Check if an address is eligible for Medicare telehealth originating site payment.)

Unfortunately, these strict limits on telehealth services may have contributed to thwarting innovation and increased adoption of new technologies, thereby limiting access to care. Therefore, CMS has pivoted to enhanced coverage of telemedicine over the last few years.    
   
Changes in 2019:
•    Brief communication technology-based service (e.g., virtual check-in, HCPCS code G2012)
•    Remote evaluation of pre-recorded patient information (HCPCS code G2010)
•    Interprofessional internet consultation (CPT codes 99452, 99451, 99446, 99447, 99448 and 99449)

Changes in 2020:
•    Expanded access for Medicare Advantage enrollees
•    Part of government funded “basic benefits” instead of supplemental services
•    Available to enrollees in both urban and rural areas
•    Removed requirement to go to a health care facility as the originating site of service, instead, patient can receive telemedicine services from home

For 2021, CMS finalized the addition of the following services to the Medicare telehealth list, which remained covered after the end of the PHE on May 11, 2023:
•    Group psychotherapy
•    Psychological and neuropsychological testing
•    Lower-level domiciliary, rest home, or custodial care services, established patients
•    Lower-level home visits, established patients
•    Cognitive assessment and care planning services
•    Visit complexity inherent to certain office/outpatient evaluation and management (E/M) Prolonged services

Updates for 2024–2025:
•    Effective January 1, 2024, CMS finalized that claims for telehealth services provided to patients in their homes are to be paid at the non-facility payment rate when billed under Medicare. 
•    Audio-only telehealth: Under the CY 2025 Physician Fee Schedule, CMS permanently changed the regulatory definition of “interactive telecommunications system” to include audio-only for telehealth services, but only when the patient is at home, the distant-site provider is technically capable of video, and the patient cannot or does not consent to using video. 
•    Many of the “pandemic-era” waivers for Medicare telehealth (e.g., home as originating site, geographic restrictions, some distant-site provider types) expired during the government shutdown from October 1, 2025 through November 12, 2025, but were temporarily extended through January 2026 as part of the continuing resolution re-opening the federal government. This resolution allows retroactive payment for telehealth services provided on or after Oct. 1, 2025.
•    For behavioral/mental-health telehealth services under Medicare: There are no geographic or originating-site restrictions permanently for home-based telehealth; two-way audio-only is permitted permanently.

Medicaid Has Generally Had Broader Coverage for Telemedicine Services Than Medicare, But It Varies From State to State
The current state of Medicaid reimbursement:
•    Fifty states and Washington, DC, provide reimbursement for some form of live video in Medicaid fee-for-service
•    Forty-six jurisdictions reimburse for store and forward delivered services.
•    Forty-one jurisdictions reimburse for remote patient monitoring (RPM).
•    Forty jurisdictions reimburse for audio-only telephone visits in some capacity.
•    Forty-eight states plus DC recognize the patient’s home as an eligible originating site.

https://www.cchpca.org/policy-trends/

Commercial Insurers Are Focused on Cost-Savings and Operational Efficiency
Forty-four states, Washington, DC, Puerto Rico, and Virgin Islands have laws that govern private payer reimbursement of telehealth. Most jurisdictions only require parity in covered services, not reimbursement amount, and depending on how the law is written, may provide payers with the ability to limit the amount of that coverage. 24 states have laws mandating payment parity for at least one specialty. Not all laws mandate reimbursement. 

Some private insurance carriers restrict how telehealth services may be delivered by requiring patients to use the insurer’s contracted telehealth vendor, such as a national telemedicine platform, instead of receiving virtual care from their own physician. These policies are often framed as cost-containment or network-management strategies, but they can create significant barriers to continuity of care. When patients are forced to see an unfamiliar clinician who lacks access to their full medical history, it can lead to fragmented care, delays in diagnosis and reduced patient satisfaction. For practices, these arrangements may also limit reimbursement opportunities, even when the patient–physician relationship is well established and the practice is fully capable of providing compliant telehealth services.

https://www.cchpca.org/policy-trends/

Self-Payment Remains An Option For Those Patients Without Insurance Coverage For Telemedicine Services
Although not ideal, many patients would prefer to pay a convenience fee to access non-covered telemedicine services. Costs vary significantly but tend to be lower than the charges for an in-person evaluation.

In 2020, COVID-19 Ushered in A Dramatic Expansion of Telemedicine
In 2020, governments and payers rapidly expanded telemedicine coverage and payment in an effort to ensure public access to healthcare in the midst of an infectious pandemic. As part of the expansion of telehealth services during the COVID-19 public health emergency (PHE), a number of remote services which were previously non-covered by payers gained temporary coverage. In addition, reimbursing for telemedicine visits at the same rate as in-person visits was instrumental in encouraging increased telemedicine adoption among providers during the PHE.

For the most part, states continue to keep their temporary telehealth COVID-19 emergency policies siloed from their permanent telehealth policies. This gives jurisdictions flexibility to revert to their permanent policies once the extension of PHE-associated flexibilities comes to an end. However, extensive lobbying is occurring to make at least some of the COVID-19-associated telehealth reimbursement expansion permanent.

As of 2025, several Medicare telehealth expansions for behavioral/mental health have been made permanent but generally do not affect most allergy/immunology practices. Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) may permanently serve as distant-site providers for behavioral/mental telehealth services; Medicare patients can receive these services in their homes with no geographic restrictions on the originating site; and behavioral/mental telehealth may be delivered via audio-only platforms when certain conditions are met. Rural Emergency Hospitals (REHs) are also permanently recognized as eligible originating sites for telehealth. 

For non-behavioral telehealth services, including those more relevant to allergy / immunology, many of the COVID-era flexibilities (patient home as an originating site, removal of geographic restrictions, use of audio-only for some services, expanded distant-site provider types and FQHC/RHC distant-site billing) remain temporary. They were initially extended through December 31, 2024, then through September 30, 2025, and, after a brief lapse, have now been reinstated and extended only through January 30, 2026 under recent federal funding legislation. Unless Congress acts again, these non-behavioral telehealth flexibilities will revert to more restrictive, pre-pandemic rules after that date

https://telehealth.hhs.gov/providers/telehealth-policy/policy-changes-after-the-covid-19-public-health-emergency

Coding
CMS
For CMS, coding for telemedicine services is done using the corresponding codes for an in-person E/M visit, but with specific modifier(s) and place of service designation to clearly identify the service as telehealth.

Telemedicine coding can be based on either time or medical decision-making. Time-based coding includes the total time spent on the encounter on the day of service, rather than only face-to-face time.

Modifier: For CMS, the -95 modifier (synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) should be appended to E/M codes 99202-99215.

Place of Service: For CMS, the guidance is for place of service “02” to be used if the location of the patient at the time of the visit is outside of their home, and for place of service “10” to be used if the patient is at home during the visit. While a number of private payors have adopted similar guidance, they are not required to do so and may have their own guidance regarding how to list place of service for telemedicine. Due to this variability, it is best to check with each individual payor to determine how best to code telehealth visits, and to understand when COVID-19 specific billing and coding guidelines will expire.

Private Payors
Beginning in 2025, the AMA introduced a set of dedicated telehealth CPT codes designed to distinguish virtual encounters from traditional in-person E/M visits and to improve accuracy in reporting telehealth services. These new codes, grouped under the “Telemedicine Services” section, align closely with the structure of existing E/M codes but are specifically designated for synchronous audio-video encounters. They retain the familiar level-of-service framework (based on medical decision-making or total time), while allowing practices to clearly identify telehealth-delivered care for both Medicare and commercial payers. Although many payers, including CMS, still accept standard office/outpatient E/M codes for telehealth, the new AMA telehealth codes help streamline coding, support future reimbursement differentiation and provide a standardized mechanism for documenting the mode of care delivery. Practices should review payer-specific guidance, as adoption of these codes may vary during the transition period.

Bajowala SS, Milosch J, Bansal C. Telemedicine Pays: Billing and Coding Update. Curr Allergy Asthma Rep. 2020;20(10):60. Published 2020 Jul 27. doi:10.1007/s11882-020-00956-y

https://www.cms.gov/medicare/coding-billing/place-of-service-codes/code-sets

https://www.cms.gov/files/document/mln901705-telehealth-services.pdf

CMS has provided the following pamphlet to provide coding guidance for telehealth providers.

American Medical Association policy, coding and payment update.

Examples of Telemedicine Coding
Online synchronous video visit with an established patient (who is at home) to evaluate a new onset pruritic rash. Diagnosed as atopic dermatitis and prescribed emollients and triamcinolone 0.1% ointment. 20 minute visit.
 
Option 1 (Private Insurance):
CPT code: 98005
Modifier: 95 (may be optional)
Place of service: 10 (required)

Option 2 (Medicare):
CPT: 99213
Modifier: 95
Place of service: 10

If this patient was not at home, but rather at the primary care physician’s office for a facilitated telehealth visit, place of service would be changed to 11 for the originating site and 02 for the distant site and the following codes might also be billed:
Originating site (physical location of patient) also bills facility fee: CPT Q3014 (optional)
 
Online synchronous video visit with a new patient (who is at home) with multiple food allergies who wishes to obtain a second opinion about dietary management and review emergency action plan. 35 minute visit.
 
Option 1 (Private Insurance):
CPT: 98001
Modifier: 95 (may be optional)
Place of service: 10
 
Option 2 (Medicare):
CPT: 99203
Modifier: 95
Place of service: 10

If this patient was not at home, but rather at the primary care physician’s office for a facilitated telehealth visit, place of service would be changed to 11 for the originating site and 02 for the distant site, and the following codes might also be billed:
Originating site (physical location of patient) also bills facility fee: CPT Q3014 (optional)


These links are for research only. They are not endorsed by the American Academy of Allergy, Asthma & Immunology (AAAAI).

11/18/2025