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April 2020

CMS April 3rd Correction to Previous Telehealth Billing Guidance - Modifier 95 Required

Last updated April 5, 2020

On April 3, 2020 the Centers for Medicare & Medicaid Services (CMS) corrected its earlier guidance regarding the provision of telehealth services during the COVID-19 public health emergency (discussed in CSG’s previous alert here). CMS previously advised that no modifiers were generally necessary to bill Medicare for telehealth services and that place of service (POS) 2 should be used to indicate the service was rendered via telehealth. CMS is now requiring the following:

  • A POS code equal to what the POS would have been had the service been furnished in-person; and

  • Modifier 95, indicating that the service rendered was actually performed via telehealth.

A list of services that Medicare will cover via telehealth during the COVID-19 public health emergency is available here.

For additional information pertaining to the coronavirus outbreak, please visit CSG's COVID-19 Resource Center.


This publication contains general information on recent legal developments and is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. Attorney Advertising. Prior results do not guarantee a similar outcome.

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Visit CSG's COVID-19 Resource Center.