An overview of the Centers for Medicare and Medicaid Services changes effective through December 2024

Technology continues to reshape our culture. From how we socialize to how we shop for goods and services, no aspect of our lives remains untouched by digital tools, automation, and, most recently, AI.  

Some businesses spawned from technology and disrupted their industries, like Airbnb and Uber, while others struggled to keep pace with new technologies, like healthcare providers and practitioners. 

This is especially the case with telehealth adoption.  

Before the COVID-19 pandemic, telehealth services were sparsely offered and rarely sought out by most healthcare providers and patients due to tight regulations, reimbursement disparities, and competing IT priorities. The pandemic caused a shift in healthcare priorities, with governments lifting restrictions and virtual healthcare supported by remote workforces becoming the top focus. 

Telehealth is Here to Stay 

Before COVID-19, telehealth services were not a significant consideration for most providers, especially within the revenue cycle. In January 2020, the volume of telehealth claims billed to private insurers was 0.24%. But, a year later and nine months into the pandemic, the telehealth claim volume jumped to 7%.  

Although telehealth usage has leveled off since the COVID-19 pandemic, this is likely a temporary plateau, and use will continue to grow steadily, surpassing pre-pandemic levels. In January 2023, telehealth claims billed to private insurers were 5.9% of the total volume of claims.  

The American Medical Association (AMA) asserts that telehealth will play a significant role in the future of patient care. As patients and providers become more familiar and comfortable with non face-to-face interactions, the demand for digital tools will increase. Consequently, this increased demand will lead to more investment to introduce new technology to resource-strapped physician practices, such as senior living clinical assistant robots or satellite-supported, remote emergency medical care.  

Experts predict telehealth will continue to expand its reach and capabilities, with an estimated telehealth market valued at USD 41.7 billion in 2022.  

Contributing factors to continued telehealth growth include: 

  • Increased demand for mental health & chronic care services 
  • Decreased supply of physicians, especially in rural areas 
  • Improved technology 
  • Increased cost of healthcare 

Some outpatient healthcare services, such as psychiatry and psychotherapy, are well-suited for telehealth. Other clinical areas that are suitable for telehealth include chronic illness management of diseases such as diabetes, substance use disorder, and chronic obstructive pulmonary disease (COPD).  

As at-home diagnostic testing and remote patient monitoring technologies improve, physicians and patients can conduct office visits virtually instead of face-to-face when necessary. 

The federal government also recognizes the importance of telehealth. During the COVID-19 public health emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) used emergency waivers and other regulatory authorities to allow providers to use telehealth. 

The Consolidated Appropriations Act of 2023 extended many of the PHE flexibilities through December 31, 2024, and made some of them permanent. The following information summarizes the recently published Medicare Learning Network (MLN) Fact Sheet


Telehealth Medicare Policies–Effective Through 2024 

1.There are no geographic restrictions for patients or providers  

Before the pandemic’s PHE, telehealth services needed to occur in specific geographic locations depending on the location of the practitioner providing the service and the location of the patient receiving the service. 

Through December 31, 2024, all patients can access telehealth regardless of location. 

2.  Allows some non-behavioral telehealth to use audio-only technology. 

Medicare will temporarily waive some non-behavioral or mental health telehealth services from needing to use 2-way, interactive, audio-visual technology. These include services such as speech therapy, nutritional counseling, and medication management.   

Also, the Consolidated Appropriations Act of 2023 permanently extended the use of audio-only technology for all behavioral or mental telehealth and some non-behavioral or mental telehealth. 

3. Hospice clinicians can use telehealth to conduct recertifications. 

Hospice physicians and nurse practitioners can use two-way audio-video telecommunications technology as “face-to-face” interactions with patients to recertify patients for Medicare hospice benefits. 

4. Behavioral and mental telehealth patients do not require a 6-month in-person follow-up.  

For behavioral or mental telehealth, patients don’t need to conduct an in-person visit within six months of the initial telehealth visit. In addition, patients do not need to complete annual in-person visits. 

Billing Physician Telehealth Services 

As with all Medicare billing, providers should use the appropriate CPT or HCPCS codes on their claims and send them to their Medicare Administrative Contractor (MAC), ensuring to add the telehealth GQ modifier for asynchronous telehealth services.  

Getting Consent 

Medicare requires patient consent for all services, including virtual communication services. Providers may get patient consent at the same time services are initially provided.  

As with face-to-face services, non-clinical personnel under the general supervision of the billing practitioner can get patient consent for these services.  

Place of Service Codes (POS) 

For telehealth claims submitted in 2023, providers should continue to use the POS indicator that would be used for an in-person visit and add modifier 95 to identify the claim as telehealth.  

After December 31, 2023, providers should use ‘POS 02-Telehealth’ to indicate that the service was provided as a professional telehealth service when the originating site is other than the patient’s home and ‘POS 10-Telehealth’ for services when the patient is home. 

Originating Sites 

Providers should bill their MACs for the separately billable Part B telehealth originating site facility fee, as described by HCPCS Code Q301. 

The payment amount for HCPCS code Q3014 is 80% of the lesser of the actual charge. Medicare bases this payment rate on the Medicare Economic Index (MEI) percentage increase. The patient is responsible for any unmet deductible amount and coinsurance.  

Home Health  

Starting January 1, 2023, providers could voluntarily report the use of telehealth technology in providing home health (HH) services on HH payment claims. 

New G codes 

As of July 1, 2023, the following information must be included in HH claims:

  • G0320: Home health services that use synchronous telehealth via real-time audio-video telehealth. 
  • G0321: Home health services are provided that use synchronous telehealth via telephone or another real-time, interactive, audio-only telehealth. 
  • G0322: The collection of physiologic data that the patient digitally stores or transmits to the HH agency. 

This information is required to ensure that HH agencies provide quality patient care and billing for services accurately. 

When using the three codes above, follow these instructions: 

  • Report remote patient monitoring that spans more than one day as a single line item, showing the start date of monitoring and the number of days of monitoring in the Units field. 
  • Submit services provided via telehealth in line-item detail. 
  • Report each service as a separate dated line under the appropriate revenue code for each discipline providing the service. 
  • Document in the medical record how telehealth helps the patient achieve the goals outlined in their care plan. 
  • Only report these codes on Type of Bill 032x. 
  • Only report these codes with revenue codes 042x, 043x, 044x, 055x, 056x, and 057x. 

This information focuses on non-institutional provider care. Refer to the MLN fact sheet for more information about Critical Access Hospital providers. 


As telehealth expands its clinical reach, providers will need to be able to bill for services promptly and efficiently.  

Over time, telehealth claims will make up a larger and larger portion of the total number of claims that hospitals process. 

Advantum Health is committed to staying up to date on the latest telehealth policies and regulations so that we can provide our clients with the best possible revenue cycle management services.  

To learn more, please visit our website.