Telemedicine vs Telehealth – CMS Rules Made Easy

Telemedicine vs Telehealth – CMS Rules Made Easy

Many questions have been raised about the confusion between telehealth and telemedicine. Most people are unsure about what rules apply to which services within these two benefit categories. While there is a perceived relation between them they are distinctly different.


Technically speaking Telemedicine refers to services that may be provided to a patient without any physical contact. Services may be provided via phone (audio) or online communication such as a patient/provider portal or email. Typically, most telemedicine services are not covered by Medicare. However, CMS has opened some of the codes for coverage during the COVID-19 public health emergency (PHE).


Telehealth refers to a group of services that were traditionally performed via face-to-face interactions between patient and the practitioner. This group of services are now grouped together to allow limited amount of traditional face-to-face interactions (services) to be performed via an audio and video channel as a replacement to in-person (face-to-face) interaction. Telehealth allow interactions to still occur face-to-face but via audio/video channel.


This benefit was set as a specific addition to the Medicare policy in SSA 1834 (m). The criteria requires real-time communication between the patient and practitioner (audio/video) for patients located in a rural or non-metropolitan area (ZIP Code eligibility) who provide consent for such services.


Patient location is considered originating site while the practitioner location is considered a distant site. Practitioners may bill Q3014 to cover the cost of a professional to set up the audio/video system and assist with the service provided, if required. The practitioner can bill for service based on the list of approved telehealth services.


Please take a look at CMS’s MLN Telehealth Booklet to gain further insights into coverage criteria, eligible originating sites, eligible distant site practitioners that may perform telehealth services. This booklet contains a listing of allowed telehealth procedure codes and allowed patient location.


Please note that during the current public health emergency, the list allowed services have been temporarily expanded. The Telehealth Booklet includes the complete list of codes that are temporarily identified as such.

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