Telemedicine Coding and Coverage

During the COVID-19 crisis, telemedicine and telehealth services will allow you to continue to care for your patients from a distance.  The NYSCA Insurance Committee continues to interact with various NYS offices, commercial carriers and TPAs to discuss and seek their guidelines relative to the application and coverage of telemedicine services for doctors of chiropractic.

Many of you have recognized this vital need and have expressed interest in learning about related policies and procedures.  Please note that the process of defining, adding or expanding this service is very fluid – just in the last 48 hours we have seen a number of updates from some of the largest insurance carriers in New York.  To better assist you, the NYSCA Insurance Committee has assembled the following resources.

As you might imagine, the parameters and requirements of coverage varies significantly by case type (Workers' Compensation, Commercial, No Fault) or by carrier (which may be further segregated by benefit type).  As such, your best source of information may be a contemporaneous call or internet access to an individual patient’s insurance carrier.

Please also note that the Current Procedural Terminology (CPT) code set is owned and maintained by the American Medical Association.  If you do not already own a CPT manual you may obtain one directly from the AMA, optum360, or a variety of other sources.

 The AMA created the following guide to Telemedicine in Practice which includes practice implementation, policy coding and payment, and additional resources on their web portal.

Workers' Compensation and No Fault

Perhaps the simplest application of telemedicine applies to Workers' Compensation cases (and by extension, No Fault).  As previously communicated by the NYSCA, the Workers' Compensation Board (WCB) incorporated telemedicine services via emergency amendment of Section 325-1.8 of Title 12 NYCRR.  Telemedicine services rendered consistent with that amendment are to be billed via CPT Code 99441. We understand that this E/M service is not listed in the Chiropractic Fee Schedule and have received permission from the WCB to publish this information.

The Relative Value for CPT Code 99441 is 5.07.  Recall that reimbursement rates vary per region based upon the conversation factor.  To determine reimbursement for your geographic region, simply multiply the RVU of 5.07 x regional E/M Conversion Factor.  5.07 x CF = $_____.   That conversion factor is available within your copy of the WC Fee Schedule; it is the same one used to calculate your other E/M services.  

The telemedicine examination must be audio and visual, and a physical examination must not be necessary for the treatment.


The following communication was received from Aetna:

Thanks to you and your membership for continuing to serve patients during this difficult time.

 We continue to monitor and change our telemedicine review policies and processes on almost a daily basis. Our policy is posted on our provider portals such as Navinet. There are, and will continue to be, new state variations. I cannot comment authoritatively on NY specific issues, but in general we are paying for the services in the attached latest external policy.

In addition to the office E&M codes, I would also point you and your membership to these services we are allowing on a temporary basis regardless of diagnosis:

G2012  Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

99441   Telephone evaluation and management service by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.

99442   … 11-20 minutes of medical discussion.

99443  … 21-30 minutes of medical discussion

99421: Online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5 – 10 minutes

99422: … 11 - 20 minutes

99423: … 21 or more minutes  

Aetna also provided additional information relative to Telemedicine and Direct Patient Contact.  It is an excellent read, and includes information relative to their telemedicine policies including waiver of copayments

Blue Cross Blue Shield (BCBS)

Blue Cross Blue Shield is an association of independent companies (some of which are non-profit).  Although they often have similar policies, they are separately managed.  Anthem BCBS and Empire BCBS provide services for a large population of NY Insureds.  Given the variety of plans and terms of coverage (e.g., self-insured plans can opt out of certain provisions), it is best to contact the payor on a case by case basis.  Please also note that some of the BCBS plans are managed by third party administrators such as American Specialty Health. 

Anthem and Empire include the following statement relative to telemedicine and telehealth coverage:

Exceptions include chiropractic services, physical, occupational, and speech therapies. These services require face-to-face interaction and therefore are not appropriate for telephone-only consultations. Self-insured plan sponsors may opt out of this program.

This organization has also noted: Based on standard coding guidelines from the AMA and HCPCS, office visit (99201-99215) telehealth claims will require Place of Service (POS) code “02” and either modifier 95 or GT.

Audio-only telephonic codes 99441, 99442, 99443, 98966, 98967, 98968 do not require a telehealth modifier to be appended.  Place of service would be the location where the provider initiates such a call.

The NYSCA is engaging BCBS and their 3rd party administrator, American Specialty Health, to ensure their decision-makers comprehend the value of telemedicine services for chiropractic patients - a service that many of our patients now request and require.  We look forward to further discussion on the comprehensive, consultative nature of the care that we render.  Doctors of Chiropractic are not simply technicians of spinal manipulation.


Most of you should have received a letter from Dr. Bennett from CDPHP noting the steps CHDPD is taking to protect both their membership and their ‘provider partners’.  Copayments and coinsurance has been waived for all telehealth and mental health services.  Understanding the fiscal implications to our practices, Dr. Bennett has instructed his team to ‘develop a plan for ensuring you remain fiscally solvent during these times’.  He further noted that 100% of withhold payments would be sent on March 31, 2020.  The NYSCA applauds CDPHP’s commitment to ‘support jour community, our members, and our providers’.

CDPHP's Telemedicine policy should be reviewed in its entirety. Highlights include:

CDPHP will reimburse for telemedicine services billed during the COVID-19 crisis as outlined in the coding requirements and reimbursement section below.

Telemedicine services billed during the interim of the COVID-19 virus will be reimbursed per this policy, regardless of whether the treatment is related to COVID-19 or other covered medical services.

 Evaluation and management services must follow standard CPT guidelines in order to be reimbursed via telemedicine.  See payment policy, Evaluation and Management Services, 1550/20.000180 for guideline details.

During this crisis, telephonic and digital only communications without a video component which were previously excluded will be allowed.

 Reimbursement for services billed as outlined above will be paid at the same rate as a service done face-to-face in the office setting.

The following services will not be reimbursed if done via telemedicine including but not limited to:

Chiropractic manipulation services (CPT codes 98940, 98941,98942)

Physical therapy and manipulation services including the following:Modalities (97010-97039, G0283)

Therapeutic Procedures (97110-97546)

Tests & Measurements: (97750, 97755)

Orthotic & Prosthetic Management: (97760, 97761, 97763)


EmblemHealth is "committed to partnering with you to ensure our members have access to the services they need, especially during the coronavirus (COVID-19) outbreak. As this public health emergency continues to unfold, we will keep you informed with fact-based and regularly updated information." 

EmblemHealth forward an email to providers on 3/31/20, including a variety of links to their website for their temporary COVID-19 policies on telemedicine, coding, cost-sharing and FAQ's

Note the inclusion of physicians and providers who can bill for E/M services (we are verifying that this includes doctors of chiropractic).  Emblemhealth also references the use of CPT Codes 99441, 99442 and 99443.  The NYSCA Insurance Committee continues to engage Emblemhealth and Palladium for any further direction and guidance on telemedicine services.


As you are aware, Medicare limits chiropractic coverage to spinal manipulation of the spine to correct subluxation.  There are only 3 reimbursable codes for Medicare recipients – 98940, 98941, and 98942.   These services require face to face time with your patients and cannot be delivered via phone or other means of electronic communication.  As such, telemedicine services, at present, is a non-covered service for Medicare patients.

For patients covered under a Medicare Advantage plan, contact the carrier to see if telemedicine services are covered.   Note that Medicare Advantage coding for either telehealth or audio-only telephonic claims could change in the future based on guidance from CMS.

Non-covered services: Although an Advanced Beneficiary Notice may not be required for non-covered services (such as E/M services rendered by a doctor of chiropractic), it is prudent and best practice to advise the patient in writing prior to the delivery of such service.   Please note the information below for a sample document from ChiroUp.


March 23, 2020 COVID-19 Update from UnitedHealthcare's Chief Medical Officer

No cost share for COVID-19 testing and testing related visits: In addition to covering the test itself for our members, we’re waiving their copays, coinsurance and deductibles for COVID-19 testing related visits, whether the care is received in a physician’s office, an urgent care center, a telehealth visit or an emergency department.

Expanded provider telehealth access: Through June 18, 2020, eligible medical care providers who have the ability and want to connect with their patient through synchronous virtual care (live video-conferencing) can do so. Benefits will be processed in accordance with the member’s plan.

This notice can be reviewed in its entirety.

Like most carriers, UnitedHealthcare frequently updates their information.  The NYSCA recommends their COVID-19 provider link.

UHC Bottom line: Coverage varies per plan type. Contact the applicable UnitedHealthcare call center to ascertain telehealth service coverage.

In Conclusion

We hope that availability of telemedicine services will help you serve your patients during the COVID-19 crisis. We would also like to extend our thanks to Dr. Tim Bertlesman of ChiroUp for educating providers on proper telemedicine procedures and offering resources via the ChiroUp website.  Click on free trial, once on the site go to provider resources, search ‘telemedicine’.  You will find scripts, office procedures, and other great resources to assist you in getting up and running. 

Stay well and keep taking great care of your patients, even when done from a distance.

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