Level Selection for Office/Outpatient E/M Visits When Furnished Via Medicare Telehealth

AAPC Medical Coding Course

Current information as of March 30, 2020

During the public health emergency (PHE) for the COVID-19 pandemic, on an interim basis, the Centers for Medicare and Medicaid Services (CMS) has revised their policy so that office and outpatient evaluation and management (E/M) services (99201-99215) provided via telehealth (real time, interactive audio/visual) can be based on medical decision making (MDM) or time.

Interim guidelines

  • Time is defined as all of the time associated with the E/M on the day of the encounter
    • Does not need to be dominated by counseling services
    • Use typical times listed in the Current Procedural Terminology (CPT) Manual
    • Use only the total time that the practitioner spends on the service
  • Requirements of history and/or physical exam is removed
  • Document E/M visits as necessary to ensure quality and continuity of care
  • Current definition of MDM remains as currently defined

This policy CMS-1744-IFC 137 only applies to office/outpatient visits furnished via Medicare telehealth, and only during the PHE for the COVID-19 pandemic.

Regardless of the service provided, documentation and compliance for each service is an important reminder. Things to consider:

  • Consent to treat
  • Health Insurance Portability and Accountability Act (HIPAA) rules/regulations
  • Documentation requirements, including but not limited to medical necessity, history and exam (if applicable), MDM, and/or time
  • Monitoring of services provided prior to and/or following virtual visits (bundling of services)
  • Document where the provider and patient are located, include circumstance for type of service


Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.

Keep reading