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TeleHealth Advisory


National Health Epidemic
Advisory on Telehealth Visits

Telehealth Visits

From a definitional standpoint, telehealth is a means by which a provider can conduct patient visits without being in the physical presence of the patient.  There is no telehealth code set in the CPT coding manual; rather, several existing code sets within that manual may come under the telehealth rubric when certain conditions are met.  Some of those codes include the primary evaluation and management (E/M) codes used in chronic pain clinics, such as the office/outpatient codes for new and established patients 99201–99205 and 99211–99215, respectively.  Medicare payment under telehealth for these codes will be the same as had the services been rendered face-to-face.

The primary condition under telehealth is that the provider must conduct the patient visit using real-time, two-way communication that includes BOTH audio AND visual components.  This can be accomplished by way of technologies such as Skype or FaceTime on an iPhone.  Another condition of billing telehealth is that the provider and patient must be in different locations (e.g., the provider is in the office and the patient is at home).  A third condition is that the telehealth service must be initiated by the patient, though the provider is encouraged to advise the patient of the availability of such services.  As far as patient consent to such services, a recent CMS fact sheet states:

Beneficiary consent should not interfere with the provision of telehealth services. Annual consent may be
obtained at the same time, and not necessarily before, the time that services are furnished.

Narcotics Waivers

According to the Drug Enforcement Agency (DEA) and HHS, telehealth may now be used to prescribe certain controlled narcotics.  As of March 16, and continuing for the duration of the NHE, DEA-registered practitioners may issue prescriptions for all schedule II-V controlled substances to patients for whom they have not conducted an in-person medical evaluation, provided all of the following conditions are met:

  • The prescription is issued for a legitimate medical purpose by a practitioner acting in the usual course of his/her professional practice;
  • The telemedicine communication is conducted using an audio-visual, real-time, two-way communication
  • The practitioner is acting in accordance with applicable federal and state laws


Interventional Pain and Regenerative Medicine Specialists
1635 North George Mason Drive, Suite 150
Northern Virginia

Arlington, VA 22205
Phone: 571-732-0044
Fax: 866-850-1049

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