The Centers for Medicare and Medicaid Services (CMS) released emergency declaration waivers and clarifications related to telehealth and remote patient monitoring in response to the COVID-19 pandemic. 

These changes are intended to help the healthcare sites and operations affected most during the COVID-19 pandemic, including critical access hospitals, federally qualified health centers, rural health clinics, skilled nursing facilities, home health agencies, and hospice sites. 

Many of the responses from CMS are aimed at enabling quick deployment of virtual care strategies and solutions – to help reduce the number of people in the health system setting, and therefore reduce the exposure and spread of COVID-19. 

COVID-19 introduced a new world for healthcare organizations. Today, non-emergency health care services are supported largely by virtual care offerings leveraging remote monitoring and telehealth technology. These solutions are working together to manage patient populations – everyone from those exposed to COVID-19, to those recovering from the virus at home, to the chronically or acutely ill individuals who traditionally would have sought in-person or ongoing care from a provider. 

To help bolster these programs quickly, CMS has issued a series of waivers and clarifications to support providers as they tackle the operational, clinical, and financial challenges introduced or exacerbated by COVID-19.

Waivers Related to Telehealth

  • Providers can bill for telehealth visits at the same rate as in-person visits.
  • Providers can hold “virtual check-ins” (e.g. telephonic) with new, as well as established patients (e.g. via code G2012)
  • CMS has clarified that telehealth services are permitted with both new and established patients, as well. 
  • CMS will pay for an additional 85 services when furnished via telehealth, including ER visits, nursing facility visits, etc.
  • Clinicians can provide remote patient monitoring services for acute conditions, whether for COVID-19 or for another condition.
  • Telehealth can fulfill many face-to-face visit requirements for patients in home health, inpatient rehabilitation facilities, hospice, etc..
  • CMS expanded the list of Qualified Medical Professionals eligible for telehealth – adding additional codes for these services. 
  • Physicians can determine if a Medicare beneficiary should not leave home because of a medical reason or COVID-19 to satisfy the home health “homebound” requirement.

Clarifications on Remote Patient Monitoring

  • CMS clarified that remote patient monitoring (RPM) codes can now be used for physiologic monitoring of patients with acute and/or chronic conditions. 
  • RPM can be temporarily furnished to new patients, as well as established patients.
  • Consent for RPM services can be temporarily obtained at the same time the service is furnished. Consent can also be obtained by auxiliary staff under general supervision, as well as the billing practitioner.
  • OIG will temporarily not subject physicians/practitioners to administrative sanctions for reducing or waiving any cost-sharing obligations (i.e., co-pays) due to beneficiaries under federal healthcare program requirements.
  • 99457 and G2012 can be used and billed together for programs utilizing remote patient monitoring services and virtual check-ins. 
    • Virtual Check-ins: Telephone evaluations or assessments are now available for payment for physicians and Qualified Medical Professionals. 
    • Under Section 3703 in the CARES Act, telehealth restrictions like modality restrictions were removed. However, audio-only telephone calls are not billable via telehealth codes, these are billable via virtual check-in code G2012.
      • A virtual check-in allows for 5-10 minutes of medical discussion.

The American Medical Association created a special coding guide to help support virtual care (telehealth, remote patient monitoring, virtual check-ins, etc.) in response to COVID-19:

For more information on the CMS waivers, visit:

For more information on Validic’s COVID-19 Home Monitoring Solution, please visit:

The information provided in this blog does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available on this site are for general informational purposes only. These are Validic’s interpretations of the CMS codes and guidance from CMS. 

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