Expansion of Telehealth with 1135 Wavier

CMS has temporarily expanded Telehealth to waive the originating sites and locations.  To qualify for a waiver the provider must have treated the patient within the previous three years or be in the same practice (i.e., as determined by tax identification number) of a practitioner who has treated the patient in the past three years.   

The bill also lessens the telecommunications requirements by allowing Medicare beneficiaries to receive telehealth services via their smartphones (i.e., telephones that allow for real-time, audio-video interaction between the provider and the beneficiary). Because the federal government has declared a nationwide public health emergency as a result of the coronavirus, the waiver will apply across the country until there is no longer a nationwide public health emergency.

Any Medicare patient, regardless of where they are located, can now receive telehealth services.  They can also be seen in a variety of locations including nursing homes, hospital OP departments, and other areas.  This expansion started on March 6, 2020 and is set for the duration of the COVID-19 Public Health Emergency.

IMPORTANT NOTE: Telehealth is NOT being restricted to COVID-19 diagnosis or treatment.  However, per CDC recommendations, is being encouraged to prevent the higher risk population from leaving their homes for care.


A summary of Medicare Telemedicine Services was provided with this waiver and is represented in the table below. The RevCycle+ Education Team has filled in some details around each of the HCPCS/CPT codes in the table as well.







A visit with a provider that uses telecommunication systems between a provider and a patient. 

Common telehealth services include: 


99201-99215 (Office or other outpatient visits)


G0425-G0427 (Telehealth consultations, emergency department or initial inpatient)


G0406-G0408 (Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs).


For a complete list: https://www.cms.gov/Medicare/Medicare-generalinformation/telehealth/telehealth-codes

For new* or established patients.   *To the extent the 1135 waiver requires an established relationship, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency.


A brief (5-10 minutes) check in with your practitioner via telephone or other telecommunication device to decide whether an office visit or other service is needed. A remote evaluation of recorded video and/or images submitted by an established patient

HCPCS code G2012 Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report E/M services, provided to an established patient, 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.


HCPCS code G2010 Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, 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.

For established patients


A communication between a patient and their provider through an online patient portal

99421 Practitioners who may independently bill Medicare for E/M visits (for instance, physicians and nurse practitioners) can bill the following codes: Online digital E/M service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes


99422 11– 20 minutes


99423 21 or more minutes


G2061 Qualified non-physician healthcare professional online assessment and management, for an established (establish requirement waived) patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes


G2062 11– 20 minutes


G2063 21 or more minutes

For established patients


Currently not included in the 1135 waiver are the following HCPCS/CPT codes:

  • 99441-99443 Telephone evaluation and management service …
  • 98966-98968 Telephone assessment and management service …



Document the visit as you normally would if you saw the patient in person.

  • Document the services were agreed to by the patient
  • Document medical necessity of visit
  • Document it was a Telehealth visit and the means by which it was conducted.
    • Document location of the Patient
    • Document location of the Provider
  • Document all persons participating and their role in the encounter
  • Document your time


Allowable Modifiers
  • Modifier GQ – Federal telemedicine demonstration programs in Alaska/Hawaii “via an asynchronous telecommunications service”
  • Modifier GT – Only Distant site Practitioners billing under the CAH method II or Modifier 95, depending on payor
  • Modifier GO – when telehealth service is furnished for purposes of diagnosis and treatment of an acute stroke



CMS maintains a list of services that are normally furnished in-person that may be furnished via Medicare telehealth. This list is available here: https://www.cms.gov/Medicare/Medicare-GeneralInformation/Telehealth/Telehealth-Codes .  These services are described by HCPCS codes and paid under the Physician Fee Schedule.  Under the emergency declaration and waivers, these services may be provided to patients by professionals regardless of patient location.


Additional Claim Guidance
  • POS 02: Telehealth
  • The “DR” (disaster related) condition code for institutional billing (CMS-1450)
  • The “CR” (catastrophe/disaster related) modifier for Part B billing, both institutional and non-institutional, professional claim (CMS-1500)