Telehealth vs. Communication Technology-Based Services (CTBS): Implications for Medicare Reimbursement

With the recent extension of the telehealth waivers (until September 30, 2025) to allow services to continue being reimbursed without stringent rural and facility-based requirements, one key distinction deserves attention: Communication Technology-Based Services (CTBS). The Centers for Medicare and Medicaid Services (CMS) separated CTBS from traditional telehealth in 2019 when they announced through their 2019 Physician Fee Schedule (PFS) reimbursement for remote services that do not fall under “Medicare telehealth services.” These services, although delivered in an electronic format, don’t qualify as telehealth (in Medicare’s eyes) and providers won’t find the majority of these CTBS codes on the list of services eligible for telehealth coverage in Medicare. This is because CTBS services are classified as not having a direct in-person equivalent. As a result, they are exempt from the limitations and restrictions, and current waivers, that apply to traditional telehealth services, which Medicare identifies as services that have the potential to be provided both in-person and via telehealth.  This distinction — that CTBS codes lack an in-person equivalent — can also mean CTBS codes adopted by other payers may not be covered under state private payer laws requiring telehealth services to be reimbursed by private payers (and sometimes Medicaid) on the same basis and, in some cases, at the same rate as their in-person counterpart. Similar complications have come up in regard to the new 98000-98016 telehealth-specific code series created by the American Medical Association (AMA) CPT Editorial Board for 2025 (as discussed in CCHP’s Telehealth Billing newsletter – dated March 4, 2025) – though Medicare declined to cover the majority of the AMA codes as telehealth services in the 2025 PFS.

Additionally, while CTBS codes are not subject to Medicare telehealth requirements (see CCHP’s March 10^th newsletter for more information on these requirements), such as the patient needing to be in a rural area, each type of CTBS code has its own specific set of requirements that must be met and providers should be aware of. 

A breakdown of the different types of CTBS codes and some of their specific requirements is provided below, for the following sets of services:

• RPM/RTM
• Virtual Check-Ins
• E-Visits
• E-Consults
• CCM/TCM

• Requires an established patient relationship for RPM, but not RTM.
• RPM must monitor an acute or chronic condition, while RTM tracks therapeutic adherence and treatment response rather than physiological metrics. Monitoring must be deemed medically reasonable and necessary.
• For RPM, data must be collected for at least 16 days within a 30-day period, except for treatment management codes 99457, 99458, 98980, and 98981.
• Only one practitioner may bill for RPM per patient within a 30-day period.
• RPM and RTM cannot be billed together.
• RPM and RTM may concurrently be billed alongside care management services such as Chronic Care Management (CCM), Transitional Care Management (TCM), Behavioral Health Integration (BHI), and Chronic Pain Management (CPM) if time and effort are not counted twice.
• For global periods of surgery, RPM and RTM can be billed by practitioners not receiving the global service payment.
• Patient consent is required before furnishing RPM services, but not RTM services.
• For RPM and RTM, data must be electronically collected and automatically uploaded to a secure location for analysis by the billing practitioner.
• For RPM and RTM, the device used must meet the FDA’s definition of a medical device.
• RPM and RTM services may be provided by healthcare personnel under the general supervision of the billing practitioner.

RPM/RTM Billing Codes:

• Virtual check-ins are only available to established Medicare patients.
• Patients can communicate via telephone or digital communication, such as video or image exchange.
• The purpose is to prevent unnecessary in-person visits.
• Patient-initiated communication is required, though providers can educate patients about the service’s availability.
• Communication must not relate to a medical visit within the past seven days or lead to a visit within the next 24 hours.
• Verbal patient consent is required before providing the service.
• Medicare coinsurance and deductible apply.
• Remote evaluation of recorded video or images is billed using HCPCS code G2010.
• Brief synchronous communication is billed using CPT code 98016 (which recently replaced G2012).

Virtual Check-In Billing Codes:

E-Visits

E-visits allow established Medicare patients to communicate digitally with their providers over a patient portal for up to seven days. Requirements to receive Medicare reimbursement for e-visits include:

• E-visits must be patient-initiated, and the practitioner must already have an established relationship with the patient.
• Communication can occur over a seven-day period.
• Verbal patient consent is required before providing the service.
• Medicare coinsurance and deductible apply.
• Practitioners who may independently bill Medicare for evaluation and management visits, such as physicians and nurse practitioners, can bill using CPT codes 99421-99423.
• Clinicians who may not independently bill for evaluation and management visits, such as physical therapists, occupational therapists, speech-language pathologists, and clinical psychologists, can bill using HCPCS codes G2061-G2063.  

E-Visit Billing Codes:

 
For more information on e-visit services, see the Medicare Telemedicine Health Care Provider Fact Sheet.
 

Chronic Care Management (CCM)

Chronic Care Management (CCM) is a Medicare service designed to assist patients with two or more chronic conditions that are expected to last at least 12 months or until death. These services provide ongoing care coordination, symptom management, and improved quality of life. CCM involves structured, non-face-to-face services such as phone calls, secure emails, and access to an online patient portal.
Requirements to receive Medicare reimbursement for CCM include:

• Chronic conditions that place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline.
• A comprehensive care plan must be established, implemented, revised and monitored.
• Primary care practitioners typically bill CCM services, though some specialists may also provide them. 

CCM Billing Codes:
 

 
For more details, see CMS’ booklet on CCM Services.
 

Transitional Care Management (TCM)

Transitional Care Management (TCM) supports patients transitioning from an acute care setting, such as a hospital, back into the community or home setting. The goal of TCM is to improve patient outcomes, reduce hospital readmissions, and provide necessary post-discharge support. Requirements to receive Medicare reimbursement for TCM include:

• TCM services cover the 30-day period that begins when a physician discharges a Medicare patient from an inpatient stay and continues for the next 29 days.
• Required TCM services include ensuring a smooth transition, addressing medical or psychosocial concerns, and taking responsibility for the patient’s continued care.
• After an inpatient discharge, the patient must return to their community setting. These could include a home, domiciliary, nursing facility or assisted living facility.
• TCM involves moderate or high-complexity medical decision-making, which is essential for effective patient recovery.
• Providers eligible to provide TCM include physicians, certified nurse-midwives, clinical nurse specialists, nurse practitioners, physician assistants.
• Auxiliary personnel may assign them for TCM non-face-to-face services under the general supervision of the physician or NPP subject to applicable state law, scope of practice, and the Medicare Physician Fee Schedule incident to rules and regulations.

There has been some confusion regarding Transitional Care Management (TCM) codes 99496 and 99495, as they can be considered both CTBS and telehealth under Medicare. These codes require communication with the patient and/or caregiver—either through direct contact, telephone, or electronic means—within two business days of discharge. A face-to-face visit must then follow within 7 or 14 days. Unlike other CTBS codes, these TCM codes (99496 and 99495) are also included in the Medicare telehealth list. This means that if they are billed as telehealth services (because the face-to-face visit was conducted via telehealth), with the 02 or 10 place-of-service (POS) codes and/or the 95 or 93 modifiers, Medicare telehealth restrictions apply. However, if it is only the communication with the patient that occurs within two business days of discharge that is provided via telephone or electronic means, and the telehealth POS codes or modifiers are not used (because the face-to-face visit was in-person), Medicare telehealth restrictions would not apply. 

TCM Billing Codes:
 

 
Other care management services can be billed concurrently with TCM services when medically necessary, if time and effort aren’t counted more than once. The commonly used codes that can be billed concurrently are listed below.
 

 
For more details, see CMS’ booklet on TCM Services.
 

Staying Ahead of Billing Changes and Compliance

While CTBS codes offer expanded opportunities for remote patient care beyond the services CMS defines as “telehealth,” they also present unique reimbursement challenges. This is also the case for other payers beyond Medicare. As noted previously, CTBS codes (and the AMA telemedicine codes) do not have in-person counterparts, often making them exempt from state payment parity laws that require telehealth services to be reimbursed at the same rate as in-person care.

Medicare has also utilized its authority to expand access to services via technology by creating additional distinctions specific to federally qualified health center (FQHC) and rural health clinic (RHC) visits to maintain FQHC/RHC ability to provide services via technology outside of statutory telehealth limitations (see more information on this issue and related billing confusions in CCHP’s March 10^th Newsletter). However, as we see payers making these kinds of coding distinctions between telehealth and technology-based services, billing can become increasingly complicated. To truly integrate telehealth and technology into healthcare, and simplify billing, it is important for policymakers to note that these complicated payer policies are often arising to combat limitations created by legislative bodies around the use of technology to provide care.

CMS regularly updates telehealth and CTBS codes, as well as their respective requirements, through its annual Physician Fee Schedule (PFS) process. To stay informed on potential changes for 2026, including any updates to both telehealth and CTBS policies, be sure to follow CCHP newsletters for a detailed breakdown of the upcoming proposed PFS, which is typically released in July. To sign up for CCHP’s weekly #TelehealthTuesday emails, please do so via the online form at the bottom of the contact us page.

For more on telehealth billing, including a section dedicated to CTBS codes, see CCHP’s Medicare Telehealth Billing Guide (note that the document was published in September 2024, prior to the latest extension of Medicare’s telehealth waivers to September 30, 2025 and policy changes finalized in the 2025 PFS).