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Answering the Frequently Asked Questions Your Employees Ask About Telehealth

Shelly Denham, senior vice president of compliance, risk & audit services at UofL Health in Louisville, Kentucky, and the compliance team there developed these answers to frequently asked questions based on CMS guidance and questions employees asked.[1] Contact Denham at

Q1. Can new patients be seen under telehealth?

A. Under the current public health emergency (PHE), yes. The federal government posted a waiver that under the COVID-19 PHE, new patients are allowed to be treated via telemedicine. After the PHE, currently scheduled to end 6/30/2020 (may change), a decision has not been made by Medicare and/or private payers about the decision to keep new patients as eligible for telehealth services. We will update as we receive information.

Q2. I have a patient that is on vacation in another state and cannot leave due to the travel emergency ban. I am currently not licensed in that state. Can I still perform telehealth services for this established patient?

A. Yes, the federal government has issued waivers that allow for providers to perform telehealth visits across state lines.

Q3. Can telephone calls be billed?

A. Under the current PHE, yes. If the intent of the visit is for a telephone call only, then codes G2012 or 99441-99443 can be billed if time is documented. If no time of the call is documented, then code G2012 only can be billed, as it is a brief check-in only.

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