In this blog, we cover updates on audio-only telephone services, a summary of the Federal Communications Commission (FCC) COVID-19 Telehealth Program and emids insights on telehealth program planning for the long-term.

You are not alone if you are looking for clarity in reimbursement coverage for providing care through Telehealth, specifically for virtual visits. From the Centers for Medicare and Medicaid Services (CMS) to private payers, there are evolving changes, complex reimbursement policies and a lot of questions.

One question we have been asked by our healthcare clients is whether Medicare reimburses patient visits via audio-only telephone calls as a telehealth service.

A month ago, it was clear that telehealth visits required both audio and video capabilities. In response to the COVID-19 Public Health Emergency (PHE), CMS’ Interim Final Rule with Comment Period (IFC), filed on March 31, 2020, revised its definition of interactive telecommunications systems required for telehealth stating that: “interactive telecommunications system” means multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner.” The same rule also stated that telephones, facsimile machines and electronic mail systems did not meet the definition of an interactive telecommunications system for purposes of Medicare telehealth services.

Coinciding with the IFC, CMS’ announcement of March 30, 2020, stated that: “CMS will now pay for more than 80 additional services when furnished via telehealth… and providers also can evaluate beneficiaries who have audio phones only.” This statement was a little misleading, as evaluate beneficiaries was in reference to evaluation and management (E&M) services, which is not the same as telehealth.

Constituents in the healthcare industry asked for additional telehealth coverage and more clarity on the policies. For example, on April 25, 2020 a letter from AMGA (formerly American Medical Group Association) sent on behalf of 101 medical groups and independent practice associations, expressed to the Department of Health & Human  Services (HHS) and CMS that audio-only encounters are a vital source of health care services during COVID-19.

Did CMS and HHS listen? Yes, they did. On May 1, 2020, CMS issued additional regulatory waivers that deliver expanded care under telehealth services for Medicare during the PHE. CMS is waiving the video requirement for certain telephone evaluation and management services and adding them to the list of Medicare telehealth services. As a result, Medicare beneficiaries with audio-only telephone capabilities will be able to receive these services.

Audio-Only Telephone Evaluation and Management Services

For the duration of the COVID-19 public health emergency, CMS is waiving limitations on Medicare telehealth services. The IFC states: “we are now recognizing that the intensity of furnishing an audio-only visit to a beneficiary during the unique circumstances of the COVID-19 pandemic is not accurately captured by the valuation of these services we established in the March 31st COVID-19 IFC.”

Waivers for Audio-Only Telephone Evaluation and Management (E&M) Services:

  • In addition to allowing doctors, nurse practitioners, physician assistants and certain others to deliver telehealth services, CMS has approved physical therapists, occupational therapists and speech language pathologists to provide telehealth services.
  • CMS is establishing new relative value units (RVUs) for the telephone E&M services based on crosswalks to the most analogous office/outpatient E&M codes, based on the time requirements for the telephone codes and the times assumed for valuation for purposes of the office/outpatient E&M codes.
  • CMS is cross-walking CPT codes 99212, 99213 and 99214 to 99441, 99442 and 99443 respectively.
  • CMS recognizes that these codes should be considered as telehealth services, and they are adding them to the list of Medicare telehealth services for the duration of the PHE.

Crosswalk of Telephone E&M Services Temporarily Covered for Telehealth Services


Cross-walked to CPT Codes

Interim Work RVUs for COVID-19 PHE

Short Descriptor

Audio-only Interaction Status

99441 99212 0.48; an increase from 0.25 Phone E/M Phys/QHP 5-10 min Covered temporarily
99442 99213 0.97; an increase from 0.50 Phone E/M Phys/QHP 11-20 min Covered temporarily
99443 99214 1.5; an increase from 0.75 Phone E/M Phys/QHP 21-30 min Covered temporarily

CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services from a range of about $14-$41 to about $46-$110. The payments are retroactive to March 1, 2020.

Bottom line, during this public health emergency, CMS is waiving the video requirement for certain telephone E&M and Medicare telehealth services.

Federal Communications Commission (FCC) COVID-19 Telehealth Program

On April 9, 2020, the FCC issued a final order establishing the COVID-19 Telehealth Program, which is funded from Congress under the Coronavirus Aid, Relief and Economic Security (CARES) Act.  The program is for eligible not for profit health care providers to purchase telecommunications, information services and connected devices.

There is $200 million in funding allocated for this program distributed through an application process and funding amount determinations are limited to $1 million for any single applicant. The program was effective on April 9, 2020 and as of May 6, 2020, the COVID-19 Telehealth Program has funded 56 health care providers in 23 states for a total of $24.9 million of the $200M in funding provided for the program.

The goal of this program is to provide connected care services in response to the coronavirus pandemic. Funds will be available until they are expended or until the current pandemic has ended.

Within six months after the conclusion of the COVID-19 Telehealth Program, participants will need to provide a report to the FCC on the effectiveness of the COVID-19 Telehealth Program funding on health outcomes, patient treatment, health care facility administration and other relevant aspects of the pandemic. FCC will be looking for feedback in the report on how the funding was helpful in providing or expending telehealth services.

Telehealth Program Planning for the Long-Term

For many provider organizations, this pandemic has ignited the demand for more direct-to-consumer modalities, with the availability of telehealth virtual visits at the top of the list. Fortunately, the news around the continued use of virtual visits post-pandemic is sounding more and more positive. The public health emergency has forced a virtual visit “national demonstration” (Advisory Board webinar, March 26, 2020), exposing providers and patients to the convenience and benefits of this visit alternative. As we read above, there is also positive change in how CMS and commercial insurers are reimbursing for these visits, a huge step in providing assurance to care providers that telehealth is a viable and sustainable visit option. The use of virtual visits is also gaining prominence as standard practice in reducing provider waiting room crowding and to potentially eliminate the waiting room altogether. Let’s not forget that now the consumer/patient has also had the experience of virtual visits and will want to continue utilizing this kind of platform as an ease of mind, efficiency and improved interaction with their healthcare provider.

As a necessary response to the public health emergency, many organizations struggled to quickly add virtual visits to their care delivery platform. For many organizations, this meant having to develop and deploy short-term telehealth strategies within a matter of days while organizations with existing strategies found their carefully planned telehealth programs being put to the test. Prepared or not, there is no doubt that telehealth, particularly virtual visits, will now have a permanent spot on every organization’s strategic planning board given that long-term telehealth strategic planning is now inevitable.


  1. CMS and HHS Interim Final Rule, March 31, 2020.  Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
  2. CMS Press Release, March 30, 2020.  Additional Background: Sweeping Regulatory Changes to Help U.S. Healthcare System Address COVID-19 Patient Surge
  3. AMGA Letter, April 25, 2020.  Audio-only encounters as a vital source of health care services during COVID-19
  4. CMS and HHS Interim Final Rule, May 1, 2020.  Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program
  5. CMS Press Release, April 30, 2020.  Trump Administration Issues Second Round of Sweeping Changes to Support U.S. Healthcare System During COVID-19 Pandemic
  6. CMS List of services payable under the Medicare Physician Fee Schedule when furnished via telehealth.  List of Telehealth Services.  Zip file:  Covered Telehealth Services for PHE for the COVID-19 pandemic, effective March 1, 2020 – Updated 04/30/2020  (ZIP) modified on 4/30/2020.
  7. CMS FAQs, updated on 5/1/2020.  COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing
  8. Final Order rule by the Federal Communications Commission (FCC) on 04/09/2020Promoting Telehealth for Low-Income Consumers; COVID-19 Telehealth Program
  9. The CARES Act.  Coronavirus Aid, Relief, and Economic Security (CARES) Act.
  10. FCC Announcements on approved COVID-19 Telehealth Program Applications:  April 16, 2020; April 21, 2020; April 23, 2020; April 29, 2020; May 6, 2020.

Collaboration of content for this blog was provided by emids subject matter experts in the Provider Business Unit, covering important telehealth topics for our customers and partners. Points of view and interpretation were relevant at time of authorship; however, they are subject to change over time.