Telehealth reimbursement and policy updates

Telehealth flexibilities extended through Dec. 31, 2027

CMS will continue reimbursing eligible Medicare clinicians for covered telehealth services through Dec. 31, 2027. These flexibilities apply retroactively, as though there had been no interruption.

Originating site/geographic location and audio-only

• Patients may receive telehealth services anywhere in the U.S. and its territories including in their homes.

• Audio-only services remain permitted when appropriate.

• Telehealth services provided to patients in their homes are paid at the non-facility rate.

Remote evaluation and virtual check-ins

Clinicians may provide remote evaluation and virtual check-in services to new and established patients, including:

• G2010 – Remote evaluation of recorded video/images (physicians)

• G2012 – Virtual check-in (physicians)

• G2251, G2252 – Virtual communication services (non-physician practitioners)

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.

Billing and coding guidance

Place of Service (POS)

• POS 02 – Telehealth provided outside the patient’s home

• POS 10 – Telehealth provided in the patient’s private residence

Use of home address

Clinicians may continue billing telehealth services using their enrolled practice address through Dec. 31, 2027.

Supervision and teaching physician policies

Direct supervision

Effective Jan. 1, 2026, CMS allows direct supervision via real-time audio-video technology for:

• Most incident-to services

• Many diagnostic tests

• Certain hospital outpatient services

* Note that audio-only does not qualify. This flexibility does not apply to services with a 010- or 090-day global surgery period.

Teaching physicians

Teaching physicians may meet Medicare presence requirements virtually (via real-time audio-video) during the key portion of telehealth services across all residency training locations.

Substitute billing arrangements (locum tenens)

Following the end of the COVID-19 Public Health Emergency on May 11, 2023, Medicare returned to the standard 60-day rule for locum tenens (substitute physician) arrangements:

• The same substitute physician may provide services for up to 60 continuous days.

• After 60 days, the original physician must return or a new substitute must be used.

Private payer

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

Contact us

Please contact us with questions.

Additional Academy resources