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Non-Face-to-Face Services

Jamie Posted Wed 18th of March, 2020 00:43:50 AM
With Covid-19 our providers are wanting to start providing non-face-to-face services to patients. We reviewed the guidelines in CPT 99441-99443. Are non face to face visits considered TeleHealth/Telemedicine? As we have come across a dilemma regarding Telehealth/Telemedicine. Per the Alaska Statues 2019 AS 44.33.381. "If you provide telemedicine services to Alaska-based clients a valid Alaska business license is required.It is illegal to deliver telemedicine services in Alaska without an active Alaska Business License and Telemedicine Business Registration." CPT Manual does not state whether these codes are regulated by the state so do these non-face-to-face CPT codes fall in this Telemedicine category? We would be providing the service from our "office" so we would use POS 11 unless they are considered Telemedicine POS 02 would be more appropriate? Please advise as we are new to this telemedicine coding. Thank you
SuperCoder Answered Thu 19th of March, 2020 03:47:33 AM

Hello Jamie,

Thank you for your question.


CMS guidelines does not allow reimbursement for telephone services which are non-face-to face evaluation and management services by a Physician or Other Qualified Health Care Professional reported with CPT codes 98966-98968 or 99441-99443. They are non-reimbursable codes according to the CMS Physician Fee Schedule (PFS) and are considered an integral part of other services provided.


Note: AMA does not consider these codes (99441-99443) as a telemedicine code.


Hope that helps.



Jamie Posted Tue 24th of March, 2020 11:42:51 AM
Since 99441-99443 as not considered Telemedicine codes. Do we still use place of service 11 for office or would 02-Telehealth apply since we are communicating over the telephone?
SuperCoder Answered Wed 25th of March, 2020 04:09:42 AM

Hello Jamie,

Thank you for your additional query.


CPT® code 99441-99443 are Non-Covered Medicare Services. Coverage varies per commercial plan.


The place of service would be 02 (per CMS telehealth guidelines, you are required to append place of service (POS) code 02 Telehealth to indicate “the location where health services and health related services are provided or received, through telecommunication technology).


Hope that helps.


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