COVID-19: Virtual visits

Last updated: Feb. 28, 2023

At Priority Health, we've long supported virtual care.

We're updating our virtual care billing process and policy

Billing for virtual services

As we continue to evolve our response to COVID-19, we've transitioned back to our normal billing process for virtual services but continue to reimburse at the higher non-facility rate. Submit your virtual service billing with the correct place of service code as follows:

• POS 02: for virtual services performed with a patient who's in a location other than their own home
• POS 10: for virtual services performed with a patient who's in their own home

Notes: (1) Commercial billing no longer requires the GT and 95 modifiers for professional services. (2) All telemedicine services for Medicaid members must be reported with POS 02 and modifier GT per MDHHS policy.

Virtual care policy changes

We're also expanding the list of services that are payable when done virtually. We're making this change because more providers are offering more virtual services to ensure patients get the care they need during the COVID-19 pandemic. Our updated list follows recommendations from the AMA, CMS and MDHHS for care that is safe and effective virtually.

Not all services are covered when provided virtually. The codes we cover are those that are medically appropriate and can be accomplished as described by the code being used. For example, preventive medicine visits (codes 99381-99397) may not be suitable when done virtually because age and gender exam elements required for these services can't be accomplished through virtual methods. In addition, urgent care is no longer a covered virtual service.

This policy applies to all product lines, including commercial group, individual, Medicare and Medicaid.

Virtual care billing and reimbursement

Professional providers:

For existing virtual care codes, we'll continue to pay the same rates paid prior to the COVID-19 pandemic. For expanded virtual care codes:

• From Mar. 26, 2020 - Apr. 30, 2020: We paid at the standard facility-based rate. Bill with a Place of Service 02.
• From May 1, 2020 - Feb. 28, 2021: We paid the same rate for virtual visits as you're accustomed to receiving for in-person visits (using the 95 modifier to identify the visit as virtual, or the GT modifier for Medicaid). Providers who bill using the Place of Service 02, instead of the 95 or GT modifier, will be reimbursed at the standard facility-based rate.
• Starting Mar. 1, 2021 - Dec. 31, 2021: We're transitioning back to our normal billing process for virtual care but will continue to reimburse at the higher non-facility rate. Starting Mar. 1, 2021, you can return to submitting your virtual service billing with the correct site of service code (02). Commercial billing no longer requires the GT and 95 modifiers.
• Starting Jan. 1, 2022: We’re continuing to reimburse the higher non-facility rate for virtual care. Submit your virtual service billing either POS 02 (for patients who are at a location other than their own home) or POS 10 (for patients who are in their own home). Commercial billing still doesn’t require GT or 95 modifiers.

See our fee schedules for rates.

Facilities (RHC, FQHC, facility-based providers)

Continue to bill as you did prior to COVID-19. Use a GT or 95 modifier to indicate facility services were done virtually.

• RHC/FQHCs: Use the following codes for virtual visits: G0071, 99421, 99422, 99423, 99441, 99442, 99443, G2012.
• Distant site telehealth services furnished by facility-based providers, RHC and FQHCs are reported with the appropriate CPT or HCPCS code that falls within their scope of practice and within their fee schedule. Effective July 1, retrospective to Jan. 27, 2020, G2025 can be billed for distance services.

Virtual visit coding guidelines

Visits must follow the guidelines of each code, including the time requirements.

Providers and facilities cannot:

• Use codes that specify in-person or describe services that can only be performed in-person
• Bill for services they are not contracted to provide
• Perform services outside scope of practice, licensure or credentialing
• Bill for a code that requires both an audio and visual component if both audio and visual components are not present throughout the entirety of the visit

Coding guidelines for audio-only visits

You can bill real-time, interactive audio-only virtual visits that have been requested by the patient, so you can serve your patients who don't have internet access or audio-visual capabilities.

Effective Jul. 1, 2020, all audio-only visits must be billed using audio-only visit codes (99441 - 99443, 98966 - 98968). No other codes can be billed for audio-only visits for commercial and Medicaid members. You should bill for these visits using the place of service you normally would, based on your office location.

For Medicare members, additional codes are accepted. See CMS's list of services that can be provided using audio only.

HIPAA compliance

Given the government's notification, we're temporarily suspending the requirement for Health Insurance Portability and Accountability Act (HIPAA)-compliant systems through the end of the public health emergency. This means if providers do not have a virtual care tool in place, they can use non-public facing tools, like FaceTime, Facebook Messenger video chat, Skype, etc. Providers cannot use public-facing tools like Facebook Live, TikTok or chat rooms, like Slack. All other elements of our medical policy remain in effect, including documentation requirements. See the Office of Civil Rights FAQ for more information.

Care management virtual and phone visits

To support ongoing care management, we've expanded your options. The following codes can be performed via telehealth G9001, G9002, G9007, G9008, 99484, 99490, 99492, 99493, 99494, 99495, 99496, 98966, 98967, 98968.

Make sure to review the other information on this page for information on member cost share, audio-only options, and billing virtual services. 

More information

See our telemedicine/virtual visit policy for more information and learn more about billable codes on our virtual visits billing page. Behavioral health providers, see our behavioral health virtual care policy and outpatient billable codes.

For information about how we're covering virtual visits for our members in response to COVID-19, see our provider information page on COVID-19 coverage for our members.

Frequently asked questions: Virtual care