Telehealth is no longer a futuristic idea—it is a vital and permanent part of healthcare delivery. What began as an emergency solution during the COVID-19 pandemic has now grown into a mainstream care model. Virtual visits, remote monitoring, digital consultations, and hybrid care systems are now redefining how patients interact with providers.
But while the clinical benefits of telehealth are widely celebrated—greater access, convenience, continuity of care—the financial side tells a more complex story. Billing and reimbursement for telehealth remain a maze of regulations, codes, payer-specific rules, and shifting federal and state policies. For providers, understanding this landscape is not just an administrative task; it’s essential for ensuring financial sustainability and compliance.
THE EVOLUTION OF TELEHEALTH BILLING
Telehealth as a concept has been around for decades, but it was the COVID-19 pandemic that pushed it into the spotlight. In March 2020, CMS (Centers for Medicare & Medicaid Services) expanded telehealth coverage dramatically, waiving restrictions and allowing providers to bill for virtual visits much like in-person encounters. Commercial insurers followed suit, creating temporary parity in reimbursement rates.
This sudden expansion was groundbreaking:
- Patients in rural and urban areas alike could access care without travel.
- Providers were able to maintain continuity of care while minimizing exposure risk.
- Health systems saw reduced appointment no-shows, especially for behavioral health.
But as emergency waivers expired and payers began to revisit their policies, the question became: How do we establish a long-term, sustainable telehealth billing model?
CURRENT REIMBURSEMENT FRAMEWORK
Medicare
Medicare has been the most influential driver of telehealth policy. Before the pandemic, Medicare coverage was highly restrictive, with limitations based on geographic location, type of originating site, and eligible services.
Today, thanks to temporary extensions and ongoing policy discussions:
- Telehealth parity: Many telehealth services are reimbursed at the same rate as in-person visits.
- Audio-only coverage: Medicare now reimburses certain audio-only visits, a significant win for patients without video capabilities.
- Expanded provider types: Physical therapists, occupational therapists, and speech-language pathologists are now eligible telehealth providers.
Still, questions remain about long-term parity and whether Congress will make these policies permanent beyond the current extension dates.
Medicaid
Medicaid policies are set at the state level, leading to a patchwork of rules. Some states have comprehensive telehealth reimbursement policies, covering behavioral health, chronic disease management, and remote monitoring. Others remain more restrictive. For providers operating across multiple states, this variation adds complexity to billing operations.
Commercial Payers
Private insurers generally follow Medicare’s lead but often add their own requirements. Some states have enacted parity laws requiring commercial insurers to reimburse telehealth at the same rate as in-person services. Others allow payers to set their own rates. Providers must carefully track payer-specific guidelines, as billing codes and documentation requirements often differ.
KEY BILLING CODES FOR TELEHEALTH
Some of the most widely used telehealth billing codes include:
- CPT 99201–99215: Office/outpatient visits via telehealth
- HCPCS G2025: General telehealth visits (RHCs/FQHCs)
- CPT 99421–99423: Online digital evaluation and management services (e-visits)
- CPT 99441–99443: Audio-only services (telephone visits)
- CPT 99453, 99454, 99457, 99458: Remote patient monitoring services
Correct billing requires not just using the right code but also pairing it with appropriate modifiers (like 95 or GT) and place of service (POS) codes to indicate telehealth.