Billing Telehealth: Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020


Congress passed the Coronavirus Preparedness and Response Supplemental Appropriations Act last week. The legislation allows healthcare providers to bill Medicare for services provided via telehealth during the current coronavirus public health emergency. The legislation removed certain billing requirements for telehealth services when the President declares a National Emergency, or the HHS Secretary declares a Public Health Emergency. Secretary Alex Azar did just that in January.


The first requirement that is no longer needed is the Originating Site Requirement.


Secondly, the legislation also allows for telehealth services to be provided by phone, as long as the phone allows for audio-video between provider and patient.


Additional requirements are as follows:


  1. Patient is existing, has been treated by the provider within the last three years

  2. Patient initiates the service

  3. Patient gives consent to be treated virtually. This consent must be documented in the medical record before the service is provided


To bill these services, providers would bill their usual codes, along with the Place of Service code 02.


While it is not clear how private payers will handle billing for telehealth services during this time, CMS provided a fact-sheet regarding information about individual and small group coverage.


Please reach out to us with any questions!

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