Telehealth and Medicare During COVID-19

Telehealth Visits

Telehealth visits can be provided during the public health emergency using video conferencing technology (which was permissible pre-COVID) as well as smartphones with a video chat app such as Apple Facetime or Skype, as well as audio-only devices (e.g. landlines). 

LCSWs should bill Medicare for these psychotherapy services the same way they bill for an office visit by using the appropriate CPT® code for the service provided. The codes are as follows:

Effective March 31, 2020, providers furnishing services through telehealth should use the place of service (POS) that would have been reported if the service had been furnished in-person. CMS is making this change to identify when it is appropriate to pay a non-facility fee, rather than a facility fee which would have automatically been included under POS 02.

For example, a CSW who would have seen patients in a private office should use POS 11. Those who would have treated the patient in a clinic should use the corresponding POS.

All claims for telehealth services should now include modifier 95.

Telephone Evaluation and Management Services

New Service Category, Audio-Only May Be Used

CSWs can now bill for Evaluation and Management Services. For the telephone E/M codes noted below, the communication devices used by the CSW and/or their client can be audio-only (e.g. landline) in addition to video conferencing or a smartphone with a video chat app. These can be provided to new or established clients.

Service description: “Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment.”

• 98966 - 5-10 minutes of medical discussion 
• 98967 - 11-20 minutes of medical discussion 
• 98968 - 21-30 minutes of medical discussion

E-Visits

E-Visits are non-face-to-face, patient-initiated communications using online patient portals. An online patient portal is a secure online website that gives patients 24-hour access to personal health information from anywhere with an Internet connection by using a secure username and password. These digital assessment services are for established patients who require a clinical decision that otherwise typically would have been provided in the office. Medicare co-insurance and deductible amounts cannot be waived for E-Visits. During the public health emergency, CMS is not enforcing the requirement limiting E-Visits to established patients only. 
Service description: “Qualified nonphysician healthcare professional online assessment and management, for an established patient, for up to seven days.”

• G2061: cumulative time of 5-10 minutes during the seven days 
• G2062: cumulative time of 11-20 minutes during the seven days 
• G2063: cumulative time of 21 or more minutes during the seven days

Opioid Treatment: Use of Audio-Only Devices 


Under regulations finalized in 2019, CMS allowed the use of interactive two-way audio/video communication technology to furnish the counseling and therapy portions of the weekly bundle of services furnished by opioid treatment providers. During the public health emergency, CMS is allowing the use of audio-only devices for the therapy and counseling portions of the weekly bundles, as well as the add-on code for additional counseling or therapy, rather than via two- way interactive audio-video communication technology, if beneficiaries do not have access to two-way audio/video communications technology, provided all other applicable requirements are met.

Virtual Check-Ins

NASW is currently clarifying whether CSWs can bill for these services and will provide an update as soon as that information is available.

The above information does not constitute and should not be relied upon as legal advice and should not be used as a substitute for obtaining personal legal advice and consultation prior to making decisions.