Optimizing Telehealth Billing: Current Telehealth CPT Codes & Telehealth Reimbursement Strategies

Growing Your Telehealth Services? Consider Telehealth Medicare Reimbursement


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Of all the payors consistently funded to expand telehealth in the immediate future, Medicare stands head and shoulders above many others. On October 8, the Center for Medicare and Medicaid Services (CMS) released the final CY 2023 Medicare Physician Fee Schedule (PFS) rule. CMS finalized many of its telehealth services proposals and immediate steps following the end of the public health emergency (PHE). Set to end in January 2023., the current extension of the PHE was signed by  HHS Secretary Xavier Becerra through a renewal determination dated October 13, 2022. One of the more significant contributors to the easing of tensions around the consequences of ending the PHE for millions of Americans who no longer have the same access to care, the 2022 Budget Act allows for an automatic extension of telehealth rules for another 151-day grace period after the end of the PHE.

2023 Medicare Physician Fee Schedule Final Rule: Details of Telehealth Medicare

There has been extensive consumer, organizational and legislative support for telehealth, creating pressures on Washington for permanent reimbursement avenues to be solidified. Those pressures particularly concern behavioral health, which includes mental health and addiction treatment. In its November summary announcement of the final CY 2023 Medicare Physician Fee Schedule (PFS) rule, CMS stated the following:

  • CMS clarified that the list of services temporarily allowed for telehealth delivery will continue to be reimbursed by Medicare during the 151-day grace period. 
  • CMS confirmed its intention to implement the telehealth provisions to ensure a smooth transition after the end of the PHE. These policies, such as allowing telehealth services to be furnished in any geographic area and any originating site setting (including the beneficiary’s home); allowing certain services to be furnished via audio-only telecommunications systems, will remain in place during the PHE for 151 days after the PHE ends.
  • A disappointment to many who had hoped the in-person visit requirements for telemental health services would be eliminated has not yet been realized. Rather, CMS has now announced that the in-person requirement need not be furnished until 152 days after the end of the PHE. The final rule states that an in-person visit will be required within the first six months of an initial telehealth mental health and every 12 months afterward (with exceptions). Again, this rule won’t be implemented until 152 days after the end of the PHE.
  • It also finalized the proposal to allow practitioners to bill with the place of service (POS) indicator that would have been reported had the service been furnished in person. These claims will require the modifier “95” to identify them as services furnished as telehealth services. Claims can continue to be billed with the place of service code that would be used if the telehealth service had been furnished in-person through the later of the end of CY 2023 or the end of the year in which the PHE ends.
  • The Telehealth Originating Site Facility Fee has been updated for CY 2023.
  • A current list of telehealth billing codes is also now available.

Telehealth Medicare & Other Reimbursement for Counselors, MFTs, Psychologists & Social Workers

In the FPS final rule, CMS announced that it has considered regulatory revisions that may help to reduce existing barriers and make greater use of the services of behavioral health professionals, such as licensed professional counselors (LPCs) and Licensed Marriage and Family Therapists (LMFTs). 

  • CMS is currently finalizing the proposal to add an exception to the direct supervision requirements to allow behavioral health services to be provided under the general supervision of a physician or non-physician practitioner (NPP) rather than under direct supervision when these services or supplies are furnished byLPCs and LMFTs, incident to the services of a physician (or NPP).
  • Diagnosis and treatment of a mental health or substance use disorder will also be reimbursed when furnished by auxiliary personnel under the general supervision of a physician or NPP authorized to furnish and bill for services provided incident to their own professional services. 
  • CMS is also finalizing a proposal to create a new General BHI code describing a service personally performed by clinical psychologists (CPs) or clinical social workers (CSWs) to account for monthly care integration where the mental health services furnished by a CP or CSW are serving as the focal point of care integration. CMS is also finalizing the proposal to allow a psychiatric diagnostic evaluation to be the initial visit for the new general BHI service.

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