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Telehealth and Covid-19

It is critically important to manage health system resources to ensure Tennesseans’ health and continue to flatten the curve as we respond to the COVID-19 pandemic. TMA is following the CDC and President Trump's direction in promoting the use of telehealth as the best tool to triage, diagnose, and ultimately treat COVID-19. We encourage all TMA member physicians to employ telehealth in efforts to clear waiting rooms, keep open vital ER beds and manage patients at the lowest possible risk and offer the following resources to help our members navigate telehealth use and payment.

Page last updated 11.23.2020
This correspondence and discussion of this issue should not be construed as legal advice or representation by the TMA. It does not constitute an attorney-client relationship between you or any TMA employee. This unwarranted material is provided only for informational purposes. Should you require legal advice or representation, you should contact your personal attorney.

Billing for COVID-19 Telehealth Encounters

Bill the appropriate CPT code for the visit and use a place of service (POS) code of 2 to designate that it was a telemedicine visit unless a plan provides different instructions. These will be noted in the charts below.

Blue Cross Blue Shield of Tennessee provided the following statement to TMA regarding the codes that may be used to bill for telemedicine services until further notice.

Providers may bill for telehealth in two ways. They can use codes 99441–99443 for telephonic provider-to-member consultation. This applies to all lines of business’ PCP or specialist benefits. They can also bill for virtual and telephonic consults with patients by using E&M codes 99201–99215 from now through April 30. For behavioral health consultations, use codes 90791, 90792, 90832, 90834 and 90837. Please use place of service 02 for all of these options. Pricing for these services would be consistent with their BlueCross fee schedule.

Approximately 80% of commercial insurance plans in Tennessee are considered ERISA plans and not subject to the policies of the plans listed in the grids below. At this time, we are unaware of the telehealth reimbursement policies of each employer ERISA plan and we recommend confirming telehealth benefits for each patient covered by an ERISA plan.


The Office of Civil Rights (OCR) announced that covered health care providers subject to the HIPAA rules may communicate and provide telemedicine for any healthcare service to patients through services that may not fully comply with the requirements of the HIPAA rules.  OCR will not impose penalties for noncompliance with the good faith provision of telehealth during the public health emergency effective immediately.  This allows a provider to use any product that is available to communicate with patients.  See the full statement from OCR for details on communication methods allowed. 

Coverage by Traditional Medicare

  • Virtual Check-in Services and Online Patient Portals are available for physician-patient communication as long as the patient has an established relationship with the physician; however, during the COVID-19 public health emergency HHS will not audit for this requirement. See page 3 of the CMS Fact Sheet dated 3/5/2020 on COVID-19for additional requirements that must be met in order tobill for these services.

  • CMS will allow beneficiaries to receive telehealth services in any healthcare facility including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes.This remains in effect until the President terminates the Public Health Emergency.

  • CMS will pay telemedicine visits the same as in-person visits. (Medicare Telemedicine Health Care Provider Fact Sheet under Key Takeaways).

  • CMS Telehealth Toolkit for General Practitioners contains links to telemedicine sources CMS considers reliable.

Coverage by Medicare Advantage Insurance Plans

CMS is allowing these plans to provide enrollees to access care via telemedicine in any geographic area and from any location, including the enrollee’s home. See page 5 of the CMS Fact Sheet dated 3/5/2020.

Telemedicine Informed Consent Template

The TMA Legal Department created a consent for member physicians to use with telemedicine patients.  To request a copy, email   

Coverage by Commercial Insurance Plans 

Insurance Plan Policy Effective End Date


• Patient may be located in his/her home during telemedicine visit
• $0 co-pay telemedicine visits for any reason through
o Aetna-covered Teladoc; and
o In-network provider delivering synchronous virtual care (live video-conference)
• Applies to all commercial plans and self-insured plans must opt-out
• Offering its Medicare Advantage brief virtual check-in and remote evaluation benefits to all Aetna Commercial members & waiving the co-pay (page 3 of the CMS Fact Sheet lists the requirements)
• Waiver of cost-sharing for covered in-network telemedicine visits for outpatient behavioral and mental health counseling services.
Refer to the Telemedicine Policy for services covered.
 Immediately None




• Patient may be located in his/her home during telemedicine visit
• Regular co-pay or coinsurance applies.   
• Applies to in-network primary care providers, specialists, and behavioral health providers.
• In-network physicians reimbursed at same level as in-person visits. 
• Reimbursement information has not been provided regarding virtual check-ins and e-visits

Until Further Notice


• Patient may be located in his/her home during telemedicine visit
• $0 co-pay & enrollee cost-sharing for telemedicine visits related to COVID-19
• Normal co-pay & cost-sharing for coverage of virtual visits to an in-network provider for non-COVID-19 related routine treatment
• Coding guidance available here for telemedicine, virtual check-ins and e-visits. 
• Cigna Virtual Care Reimbursement Policy (new)



• Patient may be located in his/her home during telemedicine visit
• Member cost sharing waiver for in-network primary care visits, in-network outpatient behavioral health visits, in-network telehealth visits.   

3/1/2020 12/31/2020

United Healthcare
• Physicians reimbursed per in-person contracted rates
• Patient may be located in his/her home during telemedicine visit 
• Appropriate reimbursement codes & modifiers are on UHC’s website
• Communication between patient and physician via virtual check-ins or an e-visit will be reimbursed. See UHC’s website for codes
3/17/2020 1/21/2021