The future of telehealth after the COVID public health emergency
By Carol Hoppe, CPC, CCS-P, CPC-I
MedLucid Solutions

Everyone is interested in what the future of telehealth will be like after the COVID-19 public health emergency (PHE), and it is difficult to stay abreast of all the changes. Some payers, such as Aetna, have resumed pre-COVID rates for telephone-only codes 99441-99443. Here is a quick snapshot of what other payers are doing.

Medicare: The CMS 2021 final rule included a number of changes to the list of covered Medicare telehealth services. Unless Congress approves additional changes, these temporary adjustments will revert back to pre-COVID policy at the end of the calendar year in which the PHE is declared to be over.

CMS extended temporary coverage for certain services through the end of the calendar year in which the PHE ends, including 
  • Emergency department visits
  • High-intensity home visits
  • Nursing facility discharge day management
  • Specialized therapy visits
Certain services that have been covered on a temporary basis during the PHE will not be covered on a permanent basis once the PHE ends:
  • Initial nursing facility visits
  • New-patient home visits
  • Radiation treatment management services
  • Telephone-only evaluation and management services
Under federal law, Medicare telehealth services must be delivered via a “telecommunications system.” CMS has long interpreted this as audio-only technology. Accordingly, prior to the PHE, the only audio-only services that CMS covered were communication technology-based services (CTBS) such as virtual check-ins, which are not considered Medicare telehealth services. 

However, during the PHE, recognizing that in-person visits pose a high risk of infection exposure and that not all providers and patients have access to video technology, CMS established temporary coverage for audio-only telephone evaluation and management (E/M) visits. In the Medicare Physician Fee Schedule that CMS is finalizing, at the end of the PHE, coverage for these audio-only telephone E/M visits will end given the statutory language regarding telecommunications systems, but CMS will add an additional CTBS virtual check-in code during CY 2021 for longer audio-only visits. (See 

Indiana Medicaid: In Bulletin BT202142 and Senate Enrolled Act 3 (SEA 3), the Indiana Health Coverage Programs (IHCP) announced expansion of telehealth services initially granted during the Governor’s Declaration of the PHE. SEA 3 was effective on April 20, 2021. To ensure health care providers had adequate time to implement these provisions and transition from the changes made during the PHE, per Executive Order 21-13, any directives granted in regard to telehealth will remain in place through July 10, 2021. 

Effective for dates of service on or after July 11, 2021, providers that can deliver health care services via telehealth must be among those listed as authorized practitioners in SEA 3. Providers not listed as authorized practitioners in SEA 3 are not permitted to practice telehealth and/or receive IHCP reimbursement for telehealth services, even under the supervision of one of the listed practitioners. For more information on which practitioners are authorized to utilize telehealth services per their scope of licensure, see BT202142 and SEA 3.

Indiana Code: The 2021 Indiana General Assembly codified many of the temporary waivers to telemedicine statutes permitted under Governor Holcomb’s COVID-19 executive orders. SEA 3 redefines “telemedicine” as “telehealth” and makes several changes to pave the way for the expanded role of telehealth services in the delivery of health care. Changes include allowing for audio-only modalities, removing the traditional “hub and spoke” model for Medicaid services, and protecting physicians’ professional judgment regarding the use of telehealth. For more information about these changes, read SEA 3.  

Anthem: Anthem continues to allow telehealth services both via audio-video and telephone only. The dates for cost-sharing waiver vary depending on the plan, so checking it is imperative to check eligibility and benefits before telehealth services are provided:

“Anthem will cover telephone-only medical and behavioral health services through June 30, 2023, from in-network providers and out-of-network providers when required by state law for fully-insured employer plans and individual plans. Self-funded plans are encouraged, [but not required], to participate. The cost sharing waiver includes copays, coinsurance and deductibles.”  (Information from Anthem for Care Providers about COVID-19)

Cigna: Cigna has a new permanent virtual care policy that was effective Jan. 1, 2021, which continues telehealth coverage with the same codes and modifiers we have become accustomed to during the PHE.

UnitedHealthcare: UHC will reimburse appropriate claims for telehealth services in accordance with the member’s benefit plan. For certain markets and plans, UnitedHealthcare is continuing its expansion of telehealth access, including temporarily waiving the CMS originating site requirements. Additional telehealth information may vary by plan. Please review the eligibility and benefits self-service tool by logging into your OPTUM/One Healthcare ID to verify member eligibility, help determine telehealth coverage, view care plans and get digital ID cards. You can also call the number on the back of the member’s ID card for more information.

The future of telehealth remains uncertain. While everyone believes it will continue, payer policy and reimbursement are not clear or consistent. Please contact your members of Congress and encourage them to support continued telehealth services between physicians and patients without an originating site and a distant site, as Medicare required for most telehealth services pre-COVID-19.

An updated Telehealth Quick Reference Guide is now available on the ISMA COVID-19 resources page.