CMS Approves ATA’s Proposals to Expand Telehealth Coverage


In the proposed Medicare rulemaking for 2015, the Centers for Medicare and Medicaid Services (CMS) approved requests by the American Telemedicine Association to expand healthcare services that are eligible for reimbursement.  These include telehealth services, remote testing and, for the first time, non-face-to-face chronic care services.  They are proposed to go into effect January 1, 2015.

The 609-page notice of proposed rulemaking is available at  Pages 139-150 are for telehealth services and 170-185 for chronic care management.  This notice will be published in the Federal Register of July 11 and open for comment on or before September 2.

Services to be covered when provided by telehealth

Specifically, CMS agreed to add the following services that can be furnished to Medicare beneficiaries under the telehealth benefit:

  • Psychotherapy services: CPT codes 90845 (Psychoanalysis); 90846 (family psychotherapy (without the patient present); and 90847 (family psychotherapy (conjoint psychotherapy) (with patient present)
  • Prolonged services in the office: CPT codes 99354 (prolonged service in the office or other outpatient setting requiring direct patient contact beyond the usual service; first hour (list separately in addition to code for office or other outpatient evaluation and management service); and, 99355 (prolonged service in the office or other outpatient setting requiring direct patient contact beyond the usual service; each additional 30 minutes (list separately in addition to code for prolonged service)
  • Annual wellness visit: HCPCS codes G0438 (annual wellness visit; includes a personalized prevention plan of service, initial visit; and, G0439 (annual wellness visit, includes a personalized prevention plan of service, subsequent visit)


In addition, CMS made explicit that Medicare’s telehealth restrictions do not apply to CPT codes 96103 (psychological testing) and 96120 (neuropsychological testing). Therefore, these computerized testing services can be furnished remotely without the physician being present and are billable using the same process as other physicians’ services.

Chronic Care Management

For the first time, CMS is proposing reimbursement criteria for non-face-to-face chronic care management (CCM) services, defined as a unique, covered service designed to pay separately for non-face-to-face care coordination services furnished to Medicare beneficiaries with two or more chronic conditions.  CMS discussed this new policy in 2013 but did not include a specific reimbursement proposal.

The specific code for this service (tentatively called GXXXI) is defined as “chronic care management services furnished to patients with multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient, that place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline; 20 minutes or more; per 30 days”

A payment rate of $41.92 could be billed no more frequently than once per month per qualified patient.