Operationalizing Virtual Visits During a Public Health Emergency


Providing options for remote access to care can keep your practice running and your patients healthy when an infectious disease outbreak prevents you from seeing them in person.

Fam Pract Manag. 2020 May-June;27(3):5-12.

Author disclosure: no relevant financial affiliations disclosed.

Published online ahead of the May/June 2020 issue on March 30, 2020.

Editor’s note: On April 30, the Centers for Medicare & Medicaid Services issued further updates to its telehealth policies, making Medicare payments for audio-only telephone E/M visits (CPT codes 99441-99443) equal to payments for similar office/outpatient visits (CPT codes 99212-99214). This article has been updated.

To reduce the risk of exposure during a public health crisis like the COVID-19 pandemic, providing care through virtual visits is a key part of clinic workflow. Remote access to care is important for patients who are symptomatic and may be contagious, as well as those who are scheduled for preventive care and other visits but do not want the risk of exposure.

As part of its interim guidance for COVID-19, the Centers for Disease Control and Prevention (CDC) encouraged health care facilities to explore alternatives to in-person visits by using patient portals, interacting with patients through telephone or telehealth video appointments, and developing an algorithm to identify which patients can be managed by virtual visits.1 (For a virtual visit algorithm, see "A virtual visit algorithm: how to differentiate and code telehealth visits, e-visits, and virtual check-ins.")

There are two main categories of virtual visits:

  • Face-to-face video visits, traditionally identified by Medicare as telehealth,

  • Non-face-to-face e-visits and other digital communication, or “non-telehealth,” which don't require real-time audio and video interaction. This category includes online evaluation and management (E/M) visits; brief virtual check-ins (by telephone or other telecommunication device); and telephone E/M visits (which payers have traditionally resisted reimbursing but Medicare and others are now allowing during this public health emergency). For physicians who are treating most patients remotely for the first time, it can be difficult to determine what type of services are being provided, and how to bill for them.

This article describes the coding and billing requirements for virtual visits, including recent changes to expand their use, so that physicians can continue to be paid for their services while providing the best patient care during the COVID-19 public health crisis and beyond. (See “Comparison of virtual visits.”)


  • Recent legislation has decreased telehealth restrictions in response to the COVID-19 pandemic, allowing more clinics to provide telehealth (video) services that are reimbursed at the same rate as in-person services.

  • Alternatives to video visits are also available to clinics, including online digital evaluation and management services, virtual check-ins, and remote evaluation services. Some require only a phone.

  • Correct diagnosis coding for suspected or confirmed cases of COVID-19 is important for patient management and data collection on the disease burden.



Dr. Magoon is the medical director for outpatient clinical documentation improvement at Baylor Scott & White Health in central Texas. She is also part-time clinical faculty for Texas A&M University's family medicine residency in Round Rock, Texas.

Author disclosure: no relevant financial affiliations disclosed.


show all references

1. Interim guidance for healthcare facilities: preparing for community transmission of COVID-19 in the United States. Centers for Disease Control and Prevention. February 29, 2020. Accessed March 18, 2020. https://www.cdc.gov/coronavirus/2019-ncov/healthcare-facilities/guidance-hcf.html...

2. Centers for Medicare & Medicaid Services. Telehealth Services. Medicare Learning Network; March 2020. Accessed March 27, 2020. https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/TelehealthSrvcsfctsht.pdf

3. Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, HR 6074, 116th Cong, 2nd Sess (2020). Accessed March 27, 2020. https://www.congress.gov/116/bills/hr6074/BILLS-116hr6074enr.pdf

4. Medicare telemedicine health care provider fact sheet. Centers for Medicare & Medicaid Services. March 17, 2020. Accessed March 27, 2020. https://www.cms.gov/newsroom/fact-sheets/medicare-telemedicine-health-care-provider-fact-sheet

5. FAQs on telehealth and HIPAA during the COVID-19 nationwide public health emergency. U.S. Department of Health and Human Services. Updated March 30, 2020. Accessed March 30, 2020. https://www.hhs.gov/sites/default/files/telehealth-faqs-508.pdf

6. List of telehealth services. Centers for Medicare & Medicaid Services. Accessed March 27, 2020. https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

7. CMS Manual System. Transmittal 3929: Elimination of the GT modifier for telehealth services. Centers for Medicare & Medicaid Services. Accessed March 27, 2020. https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2017Downloads/R3929CP.pdf

8. Centers for Medicare & Medicaid Services. Medicare Fee-for-Service Response to the Public Health Emergency on the Coronavirus (COVID-19). Medicare Learning Network. Accessed March 27, 2020. https://www.cms.gov/files/document/se20011.pdf

9. Medicare telehealth frequently asked questions. Centers for Medicare & Medicaid Services. March 17, 2020. Accessed March 27, 2020. https://edit.cms.gov/files/document/medicare-telehealth-frequently-asked-questions-faqs-31720.pdf

10. American Medical Association. CPT 2020 Professional Edition. Revised ed. Optuminsight Inc; Sept. 23, 2019.

11. New ICD-10-CM code for the 2019 novel coronavirus (COVID-19). Centers for Disease Control and Prevention. Updated April 1, 2020. Accessed April 1, 2020. https://www.cdc.gov/nchs/data/icd/Announcement-New-ICD-code-for-coronavirus-3-18-2020.pdf


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