Coding and reimbursement for teledermatology

Teledermatology reimbursement rules are set by Medicare and individual private payers. The guidance below is on Medicare reimbursement.

Medicare reimbursement

The Academy has created a flowchart to help you identify and code teledermatology visits, along with a downloadable coding guide. Keep reading below for more guidance on how to use these documents.

Medicare virtual check-ins

During the PHE:

Clinicians can provide remote evaluation of patient video/images and virtual check-in services (HCPCS codes G2010 and G2012 for physicians and G2251 and G2252 are for non-physician practitioners) to both new and established patients.

After the PHE:

These services may only be provided to established patients.

Place of service code and modifier usage

Medicare telehealth services should all be reported with place of service (POS) code 11 and modifier 95 to indicate the encounter was performed via telehealth. These include CPT codes 99202 - 99215, 99421 - 99423, 99441 - 99443, 99446 - 99449, 99451 - 99452, G2010 - G2012.

Use the E/M service codes 99202 - 99215 to report a teledermatology synchronous service rendered via real-time two-way interactive audio and video that lasts longer than a virtual check-in (a virtual check-in lasts 5-10 minutes).

Other telehealth services

Medicare Telehealth Services List:

• Domiciliary, Rest Home, or Custodial Care Services, New and Established patients (CPT codes 99324- 99328; CPT codes 99336-99337 — CPT codes 99334 and 99335 were added permanently).

• Home Visits, New and Established Patient, All levels (CPT codes 99341- 99345; CPT codes 99349; CPT code 99350 — CPT codes 99347 and 99348 were added permanently).

Telephone calls

During the PHE:

Medicare allows telephone-only encounters (CPT codes 99441 - 99443) to be reimbursed at the same rate as established patient E/M codes 99212 – 99214 until the end of 2023.

Updates on whether these services remain on the Medicare Telehealth Services List for 2024 and beyond will be addressed through established processes as part of the 2024 Medicare Physician Fee Schedule (MPFS) proposed and final rules.

After the PHE:

The Consolidated Appropriations Act allows for all audio-only telehealth services for Medicare patients to be covered through December 31, 2024.

Medicare physician supervision requirements

CMS has temporarily modified the regulatory definition of direct supervision, which requires the supervising dermatologist or non-physician clinician to be “immediately available” to furnish assistance and direction during the service, to include “virtual presence” of the supervising dermatologist through the use of real-time audio and video technology. Per the 2024 MPFS Final rule, CMS will continue to allow direct supervision by a supervising practitioner through real-time audio and video interaction telecommunications through 2024.

Teaching physicians

During the PHE:

Teaching physicians can supervise up to four residents via audio/video real-time technology. Teaching physicians must be present during the key portion of the furnished service; virtual supervision satisfies this requirement. Teaching physicians can review the services provided with the resident during, or immediately after the visit through telecommunications. This policy does not apply in the case of surgical, high risk, interventional, or other complex procedures, services performed through an endoscope, and anesthesia services.

After the PHE:

Per the 2024 MPFS Final rule, CMS will continue to allow teaching physicians to use audio/visual real-time communication technology to be present when the resident furnishes Medicare telehealth services in all residency training locations through the end of 2024; teaching physicians and residents do not have to be co-located.

Modification of 60-day limit for substitute billing arrangements (locum tenens)

During the PHE:

CMS modified the 60-day limit to allow dermatologists to use the same substitute billing arrangements for the entire time they are unavailable to provide services, plus an additional period of no more than 60 continuous days after the PHE expires.

After PHE:

The substitute billing arrangement rule will require the regular dermatologist to use a different substitute or return to work in their practice for at least 1 day in order to reset the 60-day clock. The modified timetable applies to both types of substitute billing arrangements under Medicare fee-for-service (i.e., reciprocal billing arrangements and fee-for-time compensation arrangements, formerly known as locum tenens).

Private payer

We encourage practices to check with private payers before providing the service to ensure appropriate reimbursement expectations.

Additional Academy resources