Editor’s note: The information contained in this article is current as of May 2021 and is based on CMS regulations. Please note that these regulations change often, and while we will do our best to stay current, we advise you to also reference the CMS’s Telehealth Services page for the most accurate information. Additionally, many commercial payers have different requirements.

For physical therapists, occupational therapists, and speech-language pathologists, telehealth and other virtual services can be an excellent adjunct to your practice. But knowing what remote services are covered by Medicare is critical to building a successful program. So, we’ve compiled this handy Medicare cheat sheet for outpatient rehab therapists, breaking down telehealth and communication technology-based service (CTBS) procedure codes.

Curious to learn more about Medicare Telehealth compliance? Check out this webinar with compliance expert Nancy Beckley.

Medicare Telehealth Terminology and Billing Guidelines

First, let’s define the three types of virtual services Medicare covers. “Virtual services” is the umbrella term CMS uses for remote visits. You may also hear the term “communication technology-based services” or CTBS, which constitutes brief services conducted over different types of technology.

Each type of service will have different billing requirements that must be met to be covered by Medicare. We recommend reviewing the full Medicare Telemedicine fact sheet prior to submitting claims.

  • E-Visits: When a provider communicates and conducts synchronous or asynchronous assessments on a patient, typically through an online portal.
    • When billing: These services require an established relationship between provider and patient.
  • Medicare Telehealth Visits: When the therapist offers a virtual service where the provider cares for a patient over a live, synchronous video stream.
    • When billing: These services are covered for the duration of the COVID-19 public health emergency (PHE) if the provider already has an established relationship with the patient. These visits are billed using standard CPT codes that are accepted by Medicare for telehealth services.
  • Virtual Check-ins: A virtual service where the provider conducts synchronous or asynchronous assessments or communicates with the patient via “a broader range of communication methods.” Telephone and short telehealth check-ins with patients fall under this category.
    • When billing: These services require an established relationship between provider and patient. Some codes require a timeframe of contact between the patient and qualified healthcare professional not originating from a related assessment or service provided in the previous 7 days, within the next 24 hrs., or the soonest available appointment (marked with * in our charts).

Telehealth Procedure Codes for Physical Therapists

To access a printable billing code cheat sheet for PT’s click here

Code Short DescriptorStatus During PHEAudio Only Allowed?
97110Therapeutic exercisesAvailable up through year in which PHE ends
97112 Neuromuscular reeducationTemporary addition for PHE
97116Gait training therapyTemporary addition for PHE
97150 Group therapeutic proceduresTemporary addition for PHE, added 4/30/2020
97161PT eval, low complex, 20 minsAvailable up through year in which PHE ends
97162PT eval, moderate complex, 30 minsAvailable up through year in which PHE ends
97163PT eval, high complex, 45 minsAvailable up through year in which PHE ends
97164PT re-eval, established plan of careAvailable up through year in which PHE ends
97530Therapeutic activitiesTemporary addition for PHE, added 4/30/2020
97535Self-care management trainingAvailable up through year in which PHE endsYes
97542Wheelchair management trainingTemporary addition for PHE, added 4/30/2020
97750 Physical performance testAvailable up through year in which PHE ends
97755Assistive technology assessmentAvailable up through year in which PHE ends
97760Orthotic management and training, 1st encounterAvailable up through year in which PHE ends
97761Prosthetic training, 1st encounterAvailable up through year in which PHE ends

Telehealth Procedure Codes for Occupational Therapists

To access a printable billing code cheat sheet for OT’s click here

CodeShort DescriptorStatus During PHEAudio-Only Allowed?
97110Therapeutic exercisesAvailable up through year in which PHE ends
97112Neuromuscular reeducationTemporary addition for PHE
97116Gait training therapyTemporary addition for PHE
97150Group therapeutic proceduresTemporary addition for PHE, added 4/30/2020
97165OT eval, low complex, 30 minsAvailable up through year in which PHE ends
97166OT eval, moderate complex, 45 minsAvailable up through year in which PHE ends
97167OT eval, high complex, 60 minsAvailable up through year in which PHE ends
97168OT re-eval, established plan of careAvailable up through year in which PHE ends
97530Therapeutic activitiesTemporary addition for PHE, added 4/30/2020
97535Self-care management trainingAvailable up through year in which PHE endsYes
97542Wheelchair management trainingTemporary addition for PHE, added 4/30/2020
97750Physical performance testAvailable up through year in which PHE ends
97755Assistive technology assessmentAvailable up through year in which PHE ends
97760Orthotic management and training, 1st encounterAvailable up through year in which PHE ends
97761Prosthetic training, 1st encounterAvailable up through year in which PHE ends

Telehealth Procedure Codes for Speech-Language Pathologists

To access a printable billing code cheat sheet for SLP’s click here

CodeShort DescriptorStatus During PHEAudio-Only Allowed?
92507Treatment of speech, language, voice, communication, and/or auditory processing disorder; individualAdded 3/30/2020Yes
92508Treatment of speech, language, voice, communication, and/or auditory processing disorder; groupAdded 3/3/2020Yes
92521Evaluation of speech fluency (eg. stuttering, cluttering)Added 3/3/2020Yes
92522Evaluation of speech sound production (eg. articulation, phonological process, apraxia, dysarthria)Added 3/3/2020Yes
92523Evaluation of speech sound production (eg. articulation, phonological process, apraxia, dysarthria); with evaluation of language comprehension and expression (eg. receptive and expressive language)Added 3/3/2020Yes
92524Behavioral and qualitative analysis of voice and resonanceAdded 3/3/2020Yes
92526Oral function therapyTemporary addition for PHE, added 3/30/2021-
92607Exam for speech device Rx, 1 hr.Temporary addition for PHE, added 3/30/2021 -
92608Exam for speech device Rx, additional timeTemporary addition for PHE, added 3/30/2021-
92609Use of speech device serviceTemporary addition for PHE, added 3/30/2021-
92610Evaluate swallowing functionTemporary addition for PHE, added 3/30/2021-
96105Assessment of aphasiaTemporary addition for PHE, added 3/30/2021-
96125Cognitive test by HC proTemporary addition for PHE, added 3/30/2021-
97129Therapeutic cognitive function intervention (ivntj), 1st 15 minsTemporary addition for PHE, added 3/30/2021-
97130Therapeutic ivntj, each additional 15 minsTemporary addition for PHE, added 3/30/2021-

Other Allowable Communication Technology-Based Services for Physical or Occupational Therapy

CMS has issued the following disposition for these CTBS CPT codes:

“These HCPCS/CPT codes are designated for use only for the duration of the COVID-19 public health emergency (PHE) and are applicable for claims beginning March 1, 2020. The following HCPCS/CPT codes are for services furnished virtually that represent therapy services collectively termed ‘communication technology-based services’ (CTBS) – including E-visits (G2061 – G2063) and telephone assessment and management services (Codes 98966 – 98968).  These codes are ‘always therapy’ services when furnished by a therapist and in these situations require the use of a therapy modifier − GP, GO, or GN − in order to indicate the service is furnished under a physical therapy, occupational therapy, or speech-language pathology plan of care, respectively.

“[These codes] are not therapy services when both of the following conditions are met:

  • It is not appropriate to bill the service under a therapy plan of care, and
  • They are billed by practitioners who are not therapists, such as physicians, clinical nurse specialists, nurse practitioners, physician assistants, psychologists, social workers, etc., who may also be able to report them.

“These codes may be used when the related service is furnished by a therapist who established/ establishes the therapy plan or who assumes responsibility for the plan, including the therapist in private practice who independently bills for [their] services and the therapist whose services are billed by the institutional provider of therapy services.  Although these services are furnished virtually, they must continue to meet documentation and reasonable and necessary criteria for therapy services as outlined in therapy manuals.”

CodeShort Descriptor
98966A telephone assessment and case management service of about 5-10 mins conducted by a qualified non-physician healthcare professional. *
98967A telephone assessment and case management service of about 11-20 mins of medical discussion, provided by a qualified nonphysician health professional. *
98968A telephone assessment and case management service of about 12-30 mins provided by a qualified nonphysician health professional. *
98970An online digital assessment and management service conducted by a qualified nonphysician healthcare professional for an established patient, taking about 5-10 mins for up to 7 days or cumulative time during those 7 days.
98971An online digital assessment and management service conducted by a qualified nonphysician healthcare professional for an established patient, taking about 11-20 mins for up to 7 days or cumulative time during those 7 days.
98972An online digital assessment and management service conducted by a qualified nonphysician healthcare professional for an established patient, taking 21 or more mins for up to 7 days or cumulative time during those 7 days.
G2250Remote evaluation of recorded video and/or images submitted by an established patient, including interpretation with follow-up with the patient within 24 business hrs. *
G2251Brief CTBS, such as a virtual check-in, by a physician or other qualified healthcare professional who cannot report evaluation and management services, provided to an established patient for about 5-10 mins of medical discussion. *

*CMS: Visit must not originate from a related assessment or service (including emergency medical, or e/m) provided within the previous 7 days, nor leading to an assessment or procedure within the next 24 hrs. or soonest available appointment.

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