Lifted telehealth barriers helped ECPs see patients amid COVID-19

The government lifted numerous telehealth rules amid the pandemic. Here's what that means for eye care providers.
Published 4.8.2020

In the months since the coronavirus pandemic began in early 2020, telehealth has taken on new importance among a wide swath of healthcare providers.

The federal government eased telehealth rules and regulations amid the coronavirus outbreak in order to help providers such as optometrists and opticians continue treating patients. This effort to lift telehealth barriers ensured patients could continue receiving some level of care—even if were confined to their homes at the time.

The number of ECPs billing for telehealth services dropped from 70% in late April to 18% at the end of November, according to the Wave 17 Jobson Coronavirus ECP survey. However, certain high-risk communities continue to take steps to avoid the virus. As Covid-19 remains a constant presence, telehealth is an important option for certain patients.

This article was originally published on March 25, 2020, but has been updated to reflect the current state of the eye care industry amid the ongoing pandemic.

What HHS’s coronavirus response means for ECPs

The federal government’s initial response to the emergence of confirmed COVID-19 cases in the United States was an $8.3 billion emergency aid package signed into law on March 6.

The legislation included edicts furnishing physicians “with authority and reimbursement mechanisms through Medicare for remote and telehealth services to their patients,” according to the American Optometric Association. This and other measures in the legislation granted physicians new freedom to provide remote care. The AOA lobbied legislators to ensure optometrists would be recognized as physicians under the aid package.

In addition, The Centers for Medicare and Medicaid Services used an 1135 waiver in order to loosen existing rules around telehealth and make remote care more accessible for patients and providers.

Temporarily lifted HIPAA regulations make even Facetime OK for telehealth.
Temporarily lifted HIPAA regulations make even Facetime OK for telehealth.

HHS waives rules on HIPAA compliant telehealth software

The March 6 aid package and subsequent Department of Health and Human Services actions made the benefits of telehealth more accessible.

Is Zoom HIPAA compliant now? What about Facetime or Skype?

Previously, telehealth communications platforms had to meet strict HIPAA security rules: a Business Associate Agreement ensuring HIPAA compliance and a two-way, live, interactive telecommunications platform.

Some, such as Zoom, required the provider and platform to enter a BAA. Others, like Facetime, simply did not meet these criteria.

However, as the COVID-19 pandemic emerged OCR began waiving penalties for healthcare providers that use Facetime, Skype and similar technologies for telehealth visits. This made it easy—and affordable—for ECPs to offer telehealth services to patients.

That’s because temporarily updated rules changed the requirements for telehealth: Rather than two-way, live, interactive platforms providers could instead use “everyday communication technologies.” This opened up services such as Skype, Facetime and Zoom for healthcare.

ODs can furnish telehealth visits while patients are at home

In addition, CMS adjusted criteria for the locations of telehealth visits. For example, CMS expanded its telehealth coverage beyond designated and rural areas. ODs also saw expanded flexibility in where their patients could hold their telehealth visits.

Previously patients had to be in specific locations for telehealth services to meet CMS requirements—in a hospital, their doctor’s office, a critical access hospital, a rural health clinic, a federally qualified health facility, a hospital-based dialysis facility, a skilled nursing facility and a community mental health center, among several other locations. However, starting in March, CMS began allowing patients to engage in telehealth visits from the comfort of their own homes.

How will private insurance treat telehealth during the coronavirus crisis?

For the most part, many private payers stated they’d treat telehealth in a way akin to CMS during the public health emergency. An AOA webinar highlighted what you may expect private payers to have in common with CMS:

  • Many will apply the same rules as CMS.
  • Most insurers will require use of the modifiers GT, GQ, Go or 95.
  • Many will use the same CMS-designated originating sites. 
  • Most payers will recognize POS 2. 
  • Private insurers should follow federal and state guidelines. 
  • Most will not allow telephone services (99441-99443).
  • Some insurers may allow online digital evaluation and management services.
  • Some insurers may allow G2010 and G2012.

Be sure to check with the insurers you work with to ensure their exact approach to telehealth in your region during the ongoing coronavirus crisis.

The codes below will help you bill for telehealth services.
The codes below will help you bill for telehealth services.

Coding telehealth services for vision care

During the ongoing public health emergency, ECPs have been allowed to use everyday technologies such as Skype or Facetime in order to provide services to patients who are isolated at home. However, in order to generate revenue from this care, providers are going to have to understand which telehealth CPT codes they’ll need in order to adhere to telehealth billing rules.

The AOA held a webinar that reviewed the telehealth codes for a variety of common remote care services. The webinar also outlined the telehealth reimbursements offered by CMS for these services.

There are four non-face-to-face visit codes in the CPT manual, according to Rebecca Wartman, O.D., an active member of the AOA coding and reimbursement committee. We’ll take a look at some of the common telehealth billing codes she described in the AOA webinar. We’ll also review what Medicare covers and reimburses—please check with insurance payers in your area to better understand their coverage and reimbursements for telehealth services.

Medicare virtual check-in services

Virtual check-ins give patients opportunities to connect with providers other than office visits. These appointments are covered for established patients only. Additionally, you should have documented consent from the patient for remote visits. Update this consent annually.

These services should not be related to a prior visit in the previous seven days, nor should they lead to one in the following 24 hours. They’re typically short, follow-up check-ins to confirm improving conjunctivitis or discuss a medication.

Medicare coinsurance and deductibles apply to these services. The deductible for virtual check-ins is $198. Medicare does not have an attached CPT code for these visits. Instead, you can use G-Codes. There are two channels through which these visits may be furnished:

G2012: Telephone

These visits are handled via phone and may last between five and 10 minutes. Medicare’s typical reimbursement for these visits is $15.

G2010: Captured video or image

These services are conducted a bit differently—through remote evaluation of recorded images or video. The standard Medicare reimbursement for G2010 is $12.

Medicare online digital evaluations

This is set of telehealth visits covered by Medicare. These services must be patient initiated, although it is alright to educate them on the availability of online digital evaluations.

These evaluations can stretch over the course of a seven-day period. However, they shouldn’t be tied to a visit over the previous week nor should they result in a visit within the following 24 hours.

During the ongoing crisis providers can waive the coinsurance and deductible—$198—for these visits. However, normally they apply. Here is more on each billing code for online digital evaluations:


This billing code applies to evaluations that add up to between five and 10 minutes over the course of seven days. The national average reimbursement is $15.52.


This is a billing code for evaluations that total between 11 and 20 minutes over a seven-day stretch. The national average reimbursement is $31.04.


This billing code covers visits that amount to 21- minutes-or-more over a seven-day-period. The national average reimbursement is $50.16.

Telephone services are not covered by Medicare, and most Medicaid and private carriers.
Telephone services are not covered by Medicare, and most Medicaid and private carriers.

Telephone services

Medicare and most Medicaid carriers do not cover telephone services. However, some state Medicaid carriers and private insurance payers may include telephone services among their covered services. You should check with carriers to see whether or not they cover these visits.

These visits are non-face-to-face evaluation and management services conducted via telephone. They’re also initiated by the patient. They should not be furnished as a result of a visit in the prior seven days nor should they lead to another appointment in the following 24 hours.


This billing code refers to telephone services that contain between five and 10 minutes of medical discussion. The national average reimbursement is $14.44.


Telephone services that include between 11 and 20 minutes of medical discussion are covered by this billing code. The national average reimbursement is $28.15.


This billing code applies to evaluations that contain 21-or-more minutes of medical discussion over the phone. The national average reimbursement is $41.14.

Do not bill televisits as telephone services if…

If any of the following applies to a visit then do not report it as any of billing codes 99441, 9942 or 9943:

  • If the call results in an appointment within the next 24 hours or in the next available urgent appointment. This call would be considered pre-service work for the resultant visit.
  • If the call is within the postoperative period of a completed procedure.
  • If the call refers to evaluation and management services provided in the last seven days—whether you requested it or not. 
  • If you reported a 99441-99443 within the prior seven days for the same problem.

Sustaining patient care during the coronavirus

HHS and Congress took to easing healthcare regulations in order to ensure people across the country have access to care without increased risk of catching the coronavirus. Additionally, the looser rules offer vision care providers opportunities to continue billing for services at a time when AOA recommends all in-person, routine eye care be postponed.

These changes, although for the most part temporary, will help ECPs continue caring for patients and running their businesses to the best of their abilities. It can also help you set up your practice for a longer future in telehealth.

The steps you take now can help you build a foundation for the future when regulations shift back to normal.

Connor McGann
Connor McGann, Content Marketing Manager
Connor McGann is Anagram's content marketing manager. He joined Anagram in February 2020. Previously he was a finance writer and animation project manager at a marketing agency, and managed content for a live chat provider that serviced various industries including health care and plastic surgery.

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