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COVID-19 Telehealth Service Changes

During the COVID-19 Pandemic the availability of telehealth services was expanded in order to further facilitate the 

provision of care beyond diagnosis and treatment for COVID-19. See the Centers for Medicare & Medicaid Services (CMS) 

Telehealth changes video and the CMS Telemedicine Toolkit. 

Below please find an overview of the key changes:

Topic Telehealth Policy before COVID-19 Telehealth Policy after COVID-19

Restrictions 

on Telehealth 

Under normal circumstances Medicare could 

only pay for telehealth on a limited basis: 

when the person receiving the service is in a 

designated rural area and typically when they 

leave their home and go to a clinic, hospital, 

or certain other types of medical facilities 

for the service.

The Coronavirus Preparedness and Response 

Supplemental Appropriations Act, 2020 

(P.L. 116-123) included a waiver removing 

restrictions on Medicare providers allowing 

them to offer telehealth services to beneficiaries 

regardless of whether the beneficiary is in a 

rural community.

Rural Health Clinics 

(RHC) and Federally 

Qualified Health 

Centers (FQHC)

Under normal circumstances, healthcare 

services reimbursed by Medicare must be 

provided by the RHC and FQHC in a faceto-face encounter between the healthcare 

professional and the patient. 

During the period of the COVID-19 pandemic 

RHCs and FQHCs can serve as “distant site” 

telehealth providers and provide services via 

telehealth where such services otherwise would 

have been required to be provided in person.   

Services Available 

via Telehealth

Under normal circumstances, a limited set 

of services are available via telehealth 

(i.e., providers may only bill codes authorized 

on the list of telehealth services).

During the period of the COVID-19 pandemic 

CMS will now allow for more services to be 

delivered via Telehealth. You can find the list 

of services here. 

Established 

Relationship 

Requirement

Under normal circumstances, Telehealth 

services are limited to qualified providers 

who have furnished Medicare services to 

the individual in the three years prior to the 

telehealth service.

As written, the CARES Act requires the patient 

and provider to have an existing relationship 

for the waiver authority to apply. The U.S. 

Department of Health and Human Services 

has announced that it will use its enforcement 

discretion to not conduct audits to ensure that 

such a prior relationship existed for claims 

submitted during this public health emergency. 

Use of Everyday 

Communication 

Technology

Under normal circumstances, when serving 

Medicare patients the provider must use an 

interactive audio and video telecommunications 

system that permits real-time communication 

between the distant site and the patient at home.

The U.S Department of Health and Human 

Services waived potential penalties for HIPAA 

violations against health care providers that 

serve patients through everyday communications 

technologies during the COVID-19 nationwide 

public health emergency. This exercise 

of discretion applies to widely available 

communications apps with two-way audio and 

video capabilities, such as FaceTime or Skype.
Together, America Prospers

Topic Telehealth Policy before COVID-19 Telehealth Policy after COVID-19

Flexibilities for 

Cost Sharing

Under normal circumstances, practitioners are 

subject to administrative sanctions for reducing 

or waiving any cost-sharing obligations.

The Office of Inspector General’s (OIG) in 

response to the COVID-19 pandemic notified 

physicians and other practitioners that they 

will not be subject to sanctions for reducing 

or waiving any cost-sharing obligations 

beneficiaries may owe for telehealth during 

the pandemic.

Location of 

the Patient and 

Site Limitations 

Under normal conditions, a beneficiary must 

travel to an actual site of care – the originating 

site -- to receive telehealth services. 

The Secretary has waived the geographical site 

restrictions on Medicare telehealth services to 

allow beneficiaries to receive services wherever 

they are during the emergency patients in their 

homes will be eligible for telehealth services.

Services by Phone Under normal circumstances, telehealth can 

only be provided in rural areas with specific 

audio-visual equipment.

The waiver allows telehealth services to be 

provided to Medicare beneficiaries by phone, but 

only if the phone allows for audio-video interaction 

between the qualified provider and the beneficiary. 

For example, using the phone or smartphone with a 

shared link to enable video.

Direct Supervision 

of Staff

Under normal circumstances, direct 

supervision requires a physician to be present 

in the office suite and immediately available to 

furnish assistance and direction to supervised 

clinical staff. 

During the period of the COVID-19 pandemic 

CMS is allowing physicians to supervise their 

clinical staff using virtual technologies

when appropriate, instead of requiring an 

in-person presence.

Remote Patient 

Monitoring (RPM)

Under normal circumstances, Medicare 

coverage of RPM services is limited to 

patients with one or more chronic conditions. 

According to CMS Guidelines RPM can be used 

for patients with both acute and/or chronic 

conditions, not just limited to patients with only 

chronic conditions. Additionally, RPM could be 

provided to new patients as well as established 

patients. The FDA, on March 20, issued updated 

guidance that allows for quicker entry into the 

market for digital remote monitoring equipment. 

Hospice Providers 

face-to-face

Under normal circumstances, Hospice 

providers have to deliver services in person.

Hospice providers can provide services to a 

Medicare patient receiving routine home care 

through an expanded range of telehealth 

services for the duration of the pandemic. 

Home Health 

Agencies 

Under normal circumstances, Home Health 

Agencies can deliver some services in person.

Home Health Agencies can provide more 

services to beneficiaries using telehealth.

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Last Updated April 2020