Telemedicine Reimbursement Through Medicare and Medicaid

Trying to understand Medicare and Medicaid's nuanced telemedicine reimbursement policy can often be confusing. Here is a detailed overview of the requirements for Medicare and Medicaid’s reimbursement policy:

Traditional Medicare (Part-B) and Medicare Advantage Plans (Part-C)

1

Are Medicare Part-B patients eligible for telemedicine?

Patients located at approved originating sites are eligible for telemedicine. Medicare defines an originating site as, “the location of an eligible Medicare beneficiary at the time the service furnished via a telecommunications system occurs.”  Medicare currently does not consider the patient's home for the majority of services as approved originating sites, therefore causing the rules engine to determine Medicare Part-B patients ineligible.  However, Medicare does not place originating site restrictions for the following when the patient is located in their home:

  • Treatment of a substance use disorder or a co-occurring mental health disorder
  • Monthly home dialysis ESRD-related medical evaluations
  • Diagnosing, evaluating or treating symptoms of an acute stroke

Also, although the following codes are not mentioned in the Medicare Telehealth Services MLN Booklet, they are "furnished via telecommunications technology" and CMS does not consider them to be a "telehealth" service; therefore there are no geographical or originating site restrictions:

  • 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.
  • G2012 - Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management (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

Click this link for more detailed information and for a list of approved Medicare originating sites: Medicare Telehealth Services MLN Booklet

2

Will Medicare Supplement plans cover telemedicine?

Providers must file all claims with the patient’s primary insurance prior to submitting the claim to the secondary insurance.

3

Do Medicare Advantage Plans (Medicare Part-C) cover telemedicine?

Yes, Medicare Advantage Plans are able to offer more telemedicine benefits than Orignal Medicare. They are not required to unless there is a state mandate.  Telemedicine state mandates, also known as a telemedicine parity law, require private payers to provide coverage for telemedicine/telehealth services. Federal legislation does not currently exist, leaving it to the states to regulate.

It's always a best practice to verify the patient's individual policy by contacting the payer directly.

Medicare Chronic Care Management (CCM) with Telemedicine

1

Which patients are eligible?

All Medicare patients with two or more chronic conditions, and who are registered with the Medicare CCM Program are eligible.

2

What services qualify as Telemedicine CCM?

Your practice must first be registered with the Medicare CCM program in order to file these telemedicine claims through Medicare.

A clinical staff member must engage with the patient for 20 minutes or more in a calendar month. 30-day total time period between submitting claims for the same patient is required.

Medicaid

1

Are Medicaid patients eligible for telemedicine?

Medicaid programs in a number of states still follow the originating site rule. However, all states offer some sort of telemedicine coverage. The Rules Engine determines which Medicaid patients are eligible or ineligible for video visits based on whether or not the patient's home is allowed. 

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