Communication Technology-Based Services (CTBS): Not Traditional Telehealth Services

Telehealth services have received significant attention since the COVID-19 public health emergency was declared and ended. While the focus of telehealth has been direct patient care, many opportunities exist to provide care via communication technology-based services (CTBS), which may or may not be used directly with the patient. To clarify the differences between traditional telehealth services and CTBS, the Centers for Medicare & Medicaid Services (CMS) defined telehealth services as professional services equivalent to direct in-person patient services, like office visits and consultations. These visits are synchronous and happen in real time. Because CTBS are asynchronous and are provided in an electronic format, they are not considered a direct in-person equivalent; therefore, most CTBS are not part of the Medicare list of telehealth services.¹

The types of CTBS codes are varied and are either defined with Current Procedural Terminology (CPT®) codes from the American Medical Association (AMA) or Healthcare Common Procedure Coding System (HCPCS) codes from CMS.^2,3 Each set has its own criteria for utilization and documentation, and coverage by CMS and commercial payers may vary, as most payers prefer services provided directly to the patient. Because of the indirect nature of CTBS, coverage may not be as extensive for beneficiaries as services that are considered direct.

Utilization of these services for oncology patients will also vary. Some services may work well for hematology/oncology patients, but not radiation oncology patients. This is due to other billable management services provided to radiation oncology patients during the course of treatment. Once treatment is completed, however, there may be opportunities for more services.

The Center for Connected Health Policy recently published a synopsis of CTBS compared to traditional telehealth services.⁴ Highlights of the document and whether these services may or may not apply to oncology (eg, hematology/oncology and radiation oncology patients) are provided below. Their website offers many resources explaining telehealth, CTBS, and coverage that is specific to Medicare beneficiaries and commercial payers. Full descriptions of the codes are included in the Table.

Remote Physiologic Monitoring (RPM): CPT^® Codes 99091, 99453- 99458

• Requires an established patient relationship and patient consent before furnishing services.
• Monitors and analyzes a patient’s physiologic data such as blood pressure, O₂ saturation, glucose levels, and weight fluctuations using non–face-to-face technology.
• Medicare requires that monitoring of an acute or chronic condition must be deemed medically necessary, only 1 practitioner can bill for RPM per patient in a 30-day period, the patient must provide consent, and the collection and transmittal device must meet the FDA’s definition of a medical device.
• These services do not apply to radiation oncology patients during the course of treatment; they apply to hematology/ oncology patients only.

Remote Therapeutic Monitoring (RTM): CPT^® Codes 98975-98981

• Monitors a patient’s non-physiologic data related to therapeutic treatment, including treatment adherence and treatment response.
• Medicare requires that monitoring must be deemed medically necessary, RPM and RTM codes cannot be reported together, and the collection and transmittal device must meet the FDA’s definition of a medical device.
• These services do not apply to radiation oncology patients during the course of treatment; they apply to hematology/ oncology patients only.

Virtual/Brief Check-Ins: HCPCS Code G2010 and CPT^® code 98016 (HCPCS G2012 prior to 2025)

• Requires an established patient relationship and verbal consent before providing the service.
• Patients must initiate communication and use telephone or digital communication (eg, video or image exchange).
• To bill for this visit, Medicare requires that the reason for the communication cannot relate to an Evaluation and Management (E/M) visit within the past 7 days or lead to an E/M service or procedure within the next 24 hours or soonest available appointment.
• These services apply to all oncology patients after the treatment regimen or course is completed. E-Visits: CPT® Codes 99421-99423 and 98970-98972
• Patients must initiate communication and communicate digitally with providers through a patient portal for up to 7 days

E-Visits: CPT^® Codes 99421-99423 and 98970-98972

• Patients must initiate communication and communicate digitally with providers through a patient portal for up to 7 days.

• Requires an established patient relationship and verbal consent before providing the service.
• Requires a clinical decision that typically would have been conducted in the medical office, but does not cover more administrative support in scheduling appointments, disseminating tests, etc.
• Includes 2 sets of codes: (1) for providers who can bill independently to CMS and (2) for those who cannot.
  • CPT® codes 99421-99423 are reported by practitioners who can independently bill E/M services (ie, physicians and nurse practitioners).
  • CPT® codes 98970-98972 are reported by clinicians who cannot independently bill E/M services (ie, physical and occupational therapists, speech-language pathologists, and clinical psychologists).
• These services apply to all oncology patients after the treatment regimen or course is completed.

Interprofessional E-Consults: CPT^® Codes 99446-99449, 99451- 99452; G0546-G0551

• Medicare requires a verbal or written request for the consultation documented in the patient’s medical record, with the reason for consultation and a verbal and written report to the patient’s requesting/treating physician or qualified health care professional (QHP). These codes cannot be reported for a transfer of care.
• The consulting physician or QHP must not have had a face-to-face service with the patient within the past 14 days and cannot be billed if the consult leads to a face-to-face service in the next 14 days.
• These are time-based interprofessional electronic patient consultations using the telephone, internet, or electronic health assessment and management services provided by a physician or other QHP. The physician or QHP requests the clinical opinion of a practitioner with specialty expertise without the patient being seen.
  • CPT® codes 99446-99449, 99451 are reported by the consulting physician or QHP. CPT® code 99452 is reported by the treating/requesting physician or QHP.
  • HCPCS codes G0546-G0550 are reported by the consulting physician or QHP for mental illness. HCPCS code G0551 is reported by the treating/requesting physician or QHP for mental illness.
• These services apply to all oncology patients; work cannot be counted in other services or evaluation and management visits.

Chronic Care Management (CCM): CPT^® Codes 99490, 99439, 99491, 99437; 99487, 99489; HCPCS Codes G3002-G3003

• Medicare requires an initiating visit for a new patient or for a patient who has not been seen by the billing practitioner within the previous year; written or verbal consent by the patient for CCM services; and a comprehensive care plan that is established, implemented, revised, and monitored.
• Time-based medical or psychosocial services are provided to patients with 2 or more chronic conditions expected to last at least 12 months or until the patient’s death, and that place the patient at significant risk of death, acute exacerbation, decompensation, or functional decline. These extensive services involve non–face-to-face communication between the patient and practitioner and include phone calls, secure emails, and the online patient portal.
  • CPT® codes 99490, 99439 are reported for non-complex CCM services directed by a practitioner or QHP.
  • CPT® codes 99491, 99437 are reported for non-complex CCM services performed by a practitioner or QHP.
  • CPT® codes 99487, 99489 are reported for complex CCM services directed by a practitioner or QHP which require moderate to high complexity medical decision-making (MDM) as defined in the E/M guidelines by the practitioner.
  • HCPCS codes G3002-G3003 are reported for chronic pain management services.
• Applicable to all oncology patients, but may vary depending on the patient’s current diagnosis of the chronic disease.

Transitional Care Management (TCM): CPT^® Codes 99495-99496

• TCM encompasses services provided to a patient transitioning from an inpatient hospital setting to the patient’s “community setting,” such as home, assisted living, or a nursing facility. These services involve both face-to-face visits by the practitioner and non–face-to-face services either by the practitioner or auxiliary personnel who are under general supervision by the practitioner.
• Medicare requires an initiating visit for a new patient or for a patient who has not been seen by the billing practitioner within the previous year; written or verbal consent by the patient for CCM services; an initial communication between the patient/ caregiver and the practitioner by direct in-person contact, telephone, or email within 2 business days of discharge from an inpatient hospital setting; and MDM by the practitioner that is of moderate or high-level complexity.
• Unlike the other CTBS categories, TCM services can be considered both CTBS and Medicare telehealth services. Codes 99495 and 99496 are included in the Medicare list of telehealth services. How the TCM services are provided and reported makes a difference in how they are adjudicated for payment:
  • If these codes are reported as telehealth services because the initial communication was performed via telehealth with the place of service (POS) 02 (telehealth in facility other than patient’s home) or 10 (telehealth in patient’s home) and/or modifiers 93 (audio-only) or 95 (audiovideo), the telehealth restrictions would apply.
  • If the initial communication was performed in-person or via email (outside telehealth) and the POS 02 or 10 and/or the modifiers 93 or 95 are not reported, the telehealth restrictions would not apply.
• These services apply to all oncology patients after the treatment regimen or course is completed.

CMS updates telehealth and CTBS codes and requirements through its annual Medicare Physician Fee Schedule (MPFS) proposed and final rules, which are typically issued in July and November, respectively. Telehealth frequently asked questions for calendar year 2025 are available on the CMS website; they are current as of April 9, 2025. Note that the extensions and waivers for telehealth services extended by Congress are set to end September 30, 2025; the upcoming MPFS proposed rule (expected July 2025) will hopefully shed some light on the path forward for telehealth and CTBS, but significant changes may be made by Congress.

References

1. The Centers for Medicare and Medicaid Services (CMS). List of telehealth services. Updated December 11, 2024. Accessed May 2, 2025. https://www.cms.gov/ medicare/coverage/telehealth/list-services

2. American Medical Association 2025 CPT® manual. September 10, 2024. Accessed May 2, 2025. https:// www.ama-assn.org/press-center/ama-press-releases/ ama-releases-cpt-2025-code-set

3. The Centers for Medicare and Medicaid Services (CMS), healthcare common procedure coding system (HCPCS) quarterly update. Updated May 2, 2025. Accessed May 2, 2025. https://www.cms.gov/ medicare/coding-billing/healthcare-commonprocedure-system

4. The Center for Connected Health Policy (CCHP). Accessed May 2, 2025. https://www.cchpca.org/