Georgia Medicare Telehealth Services 2026 Guide

For every Georgia Medicare telehealth services user whose care now includes virtual visits with primary care physicians, mental health counselors, or specialists, every Georgia clinician whose practice has been transformed by post-COVID telehealth flexibilities, every health system operating telehealth programs, every Federally Qualified Health Center and Rural Health Clinic serving as a distant site provider, and every health policy stakeholder watching the recurring Congressional cliff over non-mental-health telehealth authority, Medicare telehealth is among the most consequential and unstable Medicare benefit categories today. Section 1834(m) of the Social Security Act provides the statutory foundation; the COVID-19 Public Health Emergency waivers and successive Congressional extensions overlay temporary flexibilities; mental health telehealth has been made permanent; other categories remain at risk of reverting to pre-pandemic restrictions.

By Brevy Care Team · Last verified May 22, 2026

This guide explains the federal authorities (Section 1834(m) of the Social Security Act, the Section 1135 Public Health Emergency waivers, Section 3703 of the CARES Act of 2020, Section 123 of the Consolidated Appropriations Act of 2021 establishing permanent mental health telehealth authority under Section 1834(m)(7), Section 4113 of the Consolidated Appropriations Act of 2023 extending non-mental-health flexibilities, the subsequent Continuing Resolution extensions, the annual Medicare Physician Fee Schedule final rules updating the telehealth services list), the pre-COVID statutory framework, the COVID-era expansion, the permanent versus temporary authorities, the communication-based technology services, Remote Patient Monitoring and Remote Therapeutic Monitoring codes, the FQHC and RHC distant site authority under Section 1834(o), the hospital-at-home program, the SUPPORT Act SUD telehealth authority, the Bipartisan Budget Act 2018 ESRD and acute stroke telehealth authorities, the DEA controlled substance prescribing framework, place of service codes and modifiers, beneficiary cost-sharing, state licensure considerations, the Georgia telehealth landscape (Georgia Composite Medical Board Rule 360-3-.07, Georgia Partnership for Telehealth, major Georgia health system telehealth programs), and how Georgia Medicare beneficiaries are affected by ongoing Congressional decisions on telehealth permanence.

Section 1834(m) of the Social Security Act

Section 1834(m) of the Social Security Act was added to the Social Security Act by the Balanced Budget Act of 1997 and substantially revised by the Benefits Improvement and Protection Act of 2000. Section 1834(m) establishes Medicare coverage of telehealth services with a tightly bounded set of permitted circumstances.

The pre-pandemic Section 1834(m) framework included four core restrictions:

Geographic Restriction: Telehealth services could only be furnished to a beneficiary located at an originating site in (1) a county that is not included in a Metropolitan Statistical Area, or (2) a Health Professional Shortage Area. The geographic restriction was intended to direct telehealth toward areas with provider shortages.

Originating Site Restriction: Authorized originating sites included only practitioner offices, hospitals, Critical Access Hospitals, Rural Health Clinics, Federally Qualified Health Centers, hospital-based renal dialysis centers (limited services only), skilled nursing facilities, and Community Mental Health Centers. The patient home was not an authorized originating site under the pre-pandemic statute.

Authorized Practitioner Restriction: Telehealth distant site practitioners are limited to physicians, nurse practitioners, physician assistants, clinical nurse specialists, certified nurse-midwives, registered dietitians and nutrition professionals (for medical nutrition therapy), clinical psychologists, clinical social workers, certified registered nurse anesthetists, audiologists, occupational therapists, physical therapists, and speech-language pathologists (the latter four categories added through subsequent legislation).

Services List Restriction: CMS maintains a list of Medicare telehealth services that may be furnished via telehealth, updated annually through the Medicare Physician Fee Schedule final rule. The services list is organized by category (Category 1, 2, and 3) reflecting the basis for inclusion.

The Original Telehealth Services List

Prior to the COVID-19 Public Health Emergency, the Medicare telehealth services list was relatively limited. Common Category 1 services included office and outpatient evaluation and management visits (CPT 99201-99215), psychiatric diagnostic interviews, psychotherapy services, prolonged services, neurobehavioral status examinations, end-of-life consultations, and follow-up inpatient consultations. The Medicare Physician Fee Schedule final rule each year considered requests to add or remove services from the list.

Medicare Telehealth Service Volume Pre-Pandemic

Before the pandemic, Medicare telehealth utilization was a tiny fraction of overall Medicare service utilization. Geographic and originating site restrictions effectively limited telehealth to a small population of rural beneficiaries. For current telehealth utilization data, consult the CMS Telehealth coverage page and recent Medicare Physician Fee Schedule rulemaking.

The COVID-19 Public Health Emergency

HHS declared a Public Health Emergency related to COVID-19 in early 2020. The PHE declaration unlocked Section 1135 waiver authority, allowing the Secretary to waive specific Medicare requirements during the PHE to ensure beneficiary access to services.

The Section 1135 Waivers

In the early weeks of the COVID-19 PHE, HHS issued Section 1135 telehealth waivers that:

• Waived the geographic restriction (allowing telehealth in any location, urban or rural)
• Waived the originating site restriction (allowing the patient home as an originating site)
• Allowed audio-only Medicare telehealth for many services (a major change given Section 1834(m)'s implicit audio-video requirement)
• Allowed FQHCs and RHCs to serve as distant sites (a fundamental change from pre-pandemic restrictions)

Section 1135 waivers also extended to other Medicare requirements not directly related to telehealth (such as enrollment, EMTALA, three-day hospital stays, etc.).

Section 3703 of the CARES Act of 2020

The Coronavirus Aid, Relief, and Economic Security Act provided additional statutory authority complementing the Section 1135 waivers. Section 3703 of the CARES Act expanded telehealth authority during the PHE by removing certain pre-existing telehealth restrictions and authorizing additional flexibilities.

The combination of Section 1135 waivers and Section 3703 CARES Act provisions effectively created a new telehealth regime during the PHE, one in which most Section 1834(m) restrictions were waived, the services list was expanded, and providers across most settings could furnish telehealth services to beneficiaries in any location.

Telehealth Utilization During the PHE

Medicare telehealth utilization expanded dramatically during the PHE, growing from a small share of Part B services in the pre-pandemic baseline to a substantial share during the peak months. Behavioral health services saw particularly high telehealth utilization, with telehealth becoming the dominant delivery channel for many mental health categories. For specific utilization figures, consult the most recent CMS Telehealth coverage updates and Medicare Physician Fee Schedule final rules.

The dramatic expansion of telehealth utilization shaped Congressional and CMS policy responses. CMS extended many flexibilities through annual PFS rulemaking. Congress acted to make some flexibilities permanent and to extend others.

Georgia Medicare Telehealth Services for Mental Health: The Permanent Authority

Section 123 of the Consolidated Appropriations Act of 2021

The Consolidated Appropriations Act of 2021 included Section 123, establishing permanent Medicare coverage of mental health telehealth services through a new Section 1834(m)(7) of the Social Security Act.

Section 1834(m)(7) Mental Health Telehealth

Section 1834(m)(7) authorizes Medicare coverage of mental health telehealth services with the following key provisions:

• No geographic restriction (services can be furnished anywhere)
• Patient home as authorized originating site
• Distant site practitioners authorized include mental health professionals
• Audio-only authorized for certain mental health services (with subsequent CMS rulemaking expanding audio-only mental health)

The In-Person Visit Requirement

As originally enacted, Section 1834(m)(7) included an in-person visit requirement: the beneficiary must have received an in-person visit from the distant site practitioner within six months before the initial telehealth visit, and at least every twelve months thereafter, with limited exceptions. Congress and CMS have repeatedly delayed implementation of the in-person visit requirement to avoid creating barriers to mental health access. The current in-person visit requirement implementation has been delayed by successive Continuing Resolutions.

Behavioral Health Telehealth Expansions

Subsequent CMS rulemaking has expanded behavioral health telehealth coverage beyond the Section 1834(m)(7) baseline. Successive annual Medicare Physician Fee Schedule final rules have added behavioral health services to permanent telehealth coverage. Consult the most recent Medicare Physician Fee Schedule final rule for current coverage scope.

Behavioral Health Audio-Only

The mental health telehealth permanent authority specifically authorizes audio-only telehealth for certain behavioral health services, recognizing that some beneficiaries lack video capability and that audio-only services can be clinically appropriate for many mental health encounters. CMS has implemented audio-only mental health coverage through annual PFS rulemaking with specific clinical guidance.

The Non-Mental-Health Telehealth Extensions Saga

Section 4113 of the Consolidated Appropriations Act of 2023

When the COVID-19 Public Health Emergency ended in 2023, the Section 1135 waivers expired by operation of law. Mental health telehealth coverage continued through Section 1834(m)(7) permanent authority. Non-mental-health telehealth flexibilities were in jeopardy.

The Consolidated Appropriations Act of 2023 included Section 4113, extending COVID-era non-mental-health telehealth flexibilities past the end of the PHE. Section 4113 specifically extended:

• Geographic restriction waiver
• Originating site expansion (including the patient home)
• FQHC and RHC distant site authority
• Expanded telehealth services list
• Audio-only coverage authorization
• Various delayed effective dates for previously enacted requirements

Continuing Resolution Extensions

As the initial Section 4113 deadline approached without further substantive Congressional action on telehealth permanence, Continuing Resolutions successively extended the telehealth flexibilities on rolling deadlines. Each CR has pushed the expiration date forward by months at a time, and the flexibilities currently rest on continued Congressional action. For the operative current deadline, consult the CMS Telehealth coverage page.

The Recurring Telehealth Cliff

The pattern of CR-based extensions has created what stakeholders now call the "telehealth cliff," meaning successive deadlines at which non-mental-health telehealth would revert to the pre-pandemic Section 1834(m) framework absent further Congressional action. The pattern has created uncertainty for providers, beneficiaries, and health systems.

If Congress fails to extend or permanently authorize the COVID-era flexibilities, non-mental-health Medicare telehealth would lose:

• Geographic flexibility (return to rural HPSA / non-MSA restrictions)
• Originating site flexibility (return to pre-pandemic site restrictions including no patient home)
• FQHC/RHC distant site authority
• Expanded services list (Category 3 services would drop off)
• Audio-only coverage for non-mental-health services

Permanent vs Temporary Telehealth Authorities

Understanding which telehealth authorities are permanent versus temporary is essential:

Permanent Telehealth Authorities (codified statute):

• Section 1834(m)(7) mental health telehealth
• Section 1834(m)(8) Substance Use Disorder telehealth (added by the SUPPORT Act of 2018)
• ESRD home dialysis telehealth (Bipartisan Budget Act of 2018)
• Acute stroke telehealth (Bipartisan Budget Act of 2018)
• Communication-based technology services (separate Medicare benefits, not Section 1834(m))
• Remote Patient Monitoring (separate benefit category)
• Remote Therapeutic Monitoring (separate benefit category)

Temporary Telehealth Authorities (subject to Congressional extension):

• Geographic waiver for non-mental-health
• Originating site flexibility for non-mental-health
• FQHC/RHC distant site authority for non-mental-health
• Audio-only authorization for non-mental-health
• Expanded telehealth services list (some services permanent, others temporary)

The Annual Medicare Physician Fee Schedule and Telehealth Services List

Annual PFS Final Rule Telehealth Provisions

Each year, CMS issues a Medicare Physician Fee Schedule (PFS) final rule that addresses Medicare telehealth policy. The annual rule typically includes:

• Additions to or removals from the Medicare telehealth services list
• Coverage policy clarifications
• Payment rate determinations
• Reporting and documentation requirements
• Implementation of statutory telehealth provisions

The annual PFS rulemaking cycle includes proposed rule (typically published mid-summer), public comment period, and final rule (typically published in November for January 1 effective date).

The Telehealth Services List Categories

CMS organizes the Medicare telehealth services list into categories reflecting the basis for inclusion:

Category 1: Services similar to professional consultations, office visits, and office psychiatry services already on the telehealth list. New services proposed for Category 1 must be similar to existing telehealth services.

Category 2: Services not similar to services already on the telehealth list but for which CMS believes telehealth would be clinically beneficial. Category 2 additions require evidence demonstrating the clinical benefit of telehealth furnishing.

Category 3: Services added temporarily during the COVID-19 Public Health Emergency. Many Category 3 services have been permanently added (recategorized) based on utilization and clinical evidence; others remain as Category 3 with periodic CMS review.

Recent Telehealth Services List Additions

Recent Medicare Physician Fee Schedule final rules have made several Category 3 services permanently covered, including various behavioral health services, certain chronic care management services, and other previously temporary additions. CMS continues to evaluate Category 3 services for permanent inclusion. Consult the current Medicare Physician Fee Schedule final rule for the operative list.

Recent PFS Final Rule Telehealth Provisions

Recent Medicare Physician Fee Schedule final rules have addressed several telehealth issues:

• Extended various provisions consistent with Section 4113 CAA 2023 statutory extension
• Permanently added certain previously temporary services
• Implemented audio-only telehealth coverage for mental health services
• Established documentation requirements for audio-only services
• Addressed the in-person visit requirement implementation for mental health telehealth

Communication-Based Technology Services

Virtual Check-Ins (G2010 and G2012)

Virtual check-ins are brief patient communications using technology that do not require the patient to be at an originating site under Section 1834(m). They are separate Medicare benefits with their own coverage rules.

HCPCS G2010: Remote evaluation of recorded video and/or images submitted by an established patient (eg., store and forward), including interpretation with follow-up with the patient within 24 business hours, 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.

HCPCS G2012: Brief communication technology-based service, eg., 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.

E-Visits (Online Digital Assessment)

E-visits are patient-initiated online digital evaluation and management services. They are not Section 1834(m) telehealth services and not subject to geographic or originating site restrictions.

CPT 99421-99423: Online digital evaluation and management services by a physician or other qualified health care professional who can report E/M services, provided to an established patient for up to 7 days, cumulative time during the 7 days. 99421 (5-10 minutes), 99422 (11-20 minutes), 99423 (21 or more minutes).

HCPCS G2061-G2063: Online digital E/M services for non-physician practitioners who cannot bill E/M services. G2061 (5-10 minutes), G2062 (11-20 minutes), G2063 (21 or more minutes).

Asynchronous Telehealth

Asynchronous telehealth (store-and-forward) involves transmission of recorded patient information for later review. Limited Medicare asynchronous telehealth is covered (e.g., G2010 evaluation of recorded video/images, certain dermatology and radiology consultations in Alaska and Hawaii under separate authority).

Remote Patient Monitoring and Remote Therapeutic Monitoring

Remote Patient Monitoring (RPM)

Remote Patient Monitoring (RPM) under CPT codes 99453, 99454, 99457, and 99458 allows physicians and qualified health care professionals to monitor physiologic data (such as weight, blood pressure, blood glucose) collected by digital devices and transmitted electronically. RPM is a Medicare benefit separate from Section 1834(m) telehealth.

CPT 99453: Remote monitoring of physiologic parameter(s) (eg., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment.

CPT 99454: Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.

CPT 99457: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes.

CPT 99458: Each additional 20 minutes of RPM treatment management services.

Remote Therapeutic Monitoring (RTM)

Remote Therapeutic Monitoring (RTM) under CPT codes 98975-98981 allows monitoring of non-physiologic data (such as therapy adherence, response, and behavioral health symptoms). RTM was added to Medicare coverage in a recent CY Medicare Physician Fee Schedule final rule.

CPT 98975: Remote therapeutic monitoring (eg., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment.

CPT 98976: Device(s) supply with scheduled (eg., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days.

CPT 98977: Device(s) supply for musculoskeletal system, each 30 days.

CPT 98980: Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month; first 20 minutes.

CPT 98981: Each additional 20 minutes of RTM treatment management services.

RPM and RTM Documentation Requirements

RPM and RTM services have specific documentation requirements including: established patient relationship (with limited exceptions), physician/qualified health professional ordering, FDA-cleared monitoring devices (RPM) or FDA-cleared therapeutic devices (RTM), at least 16 days of monitoring data in a 30-day period for device supply codes, and interactive communication with the patient during the treatment management time.

The FQHC and RHC Distant Site Authority

Pre-Pandemic Restrictions

Prior to the COVID-19 Public Health Emergency, FQHCs and RHCs were generally restricted from serving as Medicare telehealth distant site providers. The Section 1834(m) framework did not authorize FQHC or RHC distant site billing; FQHCs and RHCs could serve as originating sites but not as the location of the practitioner furnishing the telehealth service.

COVID-Era FQHC/RHC Distant Site Authority

The Section 1135 waivers and Section 3703 of the CARES Act authorized FQHCs and RHCs to serve as distant sites during the PHE. This was a fundamental change with significant implications for safety-net telehealth access.

Section 1834(o) Permanent FQHC/RHC Distant Site Authority

Section 4113 of the Consolidated Appropriations Act of 2023 extended FQHC and RHC distant site authority on a temporary basis, with subsequent CR extensions. Some FQHC/RHC telehealth authorities have been made permanent through specific statutory provisions; others remain temporary.

For mental health services, Section 1834(o), as amended by recent appropriations acts, provides specific FQHC/RHC distant site authority for mental health telehealth.

Georgia FQHC/RHC Telehealth Programs

Georgia operates a meaningful network of FQHCs across the state and a substantial number of RHCs serving rural communities. Georgia FQHCs and RHCs have substantially expanded telehealth services since 2020, providing primary care, behavioral health, dental consultations, and specialty services to underserved Georgia populations. Continued statutory authorization for FQHC/RHC distant site telehealth is critical for safety-net access. For current Georgia FQHC and RHC counts, consult the HRSA Health Center Program directory and the Georgia State Office of Rural Health.

The Hospital-at-Home Program

Acute Hospital Care at Home (AHCAH) Waiver Program

The CMS Acute Hospital Care at Home waiver program, established during the COVID-19 PHE, allows hospitals to provide acute hospital-level care to patients in their homes through a CMS Section 1135 waiver of the hospital Conditions of Participation. AHCAH-participating hospitals must meet specific clinical criteria, provide in-home care equivalent to inpatient hospital care, and bill at hospital inpatient rates.

AHCAH Statutory Extension

The Consolidated Appropriations Act of 2023 extended the AHCAH waiver program past the end of the PHE, with subsequent Continuing Resolution extensions. The future of AHCAH depends on continued statutory authorization.

Georgia AHCAH Participants

Several Georgia hospitals participate in AHCAH including major academic medical centers and health systems. AHCAH allows treatment of patients with conditions including pneumonia, cellulitis, urinary tract infection, congestive heart failure exacerbation, and certain other diagnoses in the home setting with continuous remote monitoring and at-home nursing visits.

Substance Use Disorder Telehealth Authority

Section 1834(m)(8) SUD Telehealth

The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act of 2018 (the SUPPORT Act) added Section 1834(m)(8) authorizing Medicare telehealth for Substance Use Disorder treatment and co-occurring mental health services.

Section 1834(m)(8) provides:

• No geographic restriction for SUD telehealth
• Patient home as authorized originating site
• Permanent statutory authority (not subject to COVID-era cliff)
• Coverage of SUD treatment and co-occurring mental health services

Opioid Treatment Program Telehealth

Section 2003 of the SUPPORT Act and subsequent SAMHSA rulemaking have expanded telehealth flexibilities for Opioid Treatment Programs (OTPs) providing methadone and buprenorphine treatment. OTP telehealth supports access in rural and underserved areas.

DEA SUD Telehealth Prescribing

DEA temporarily allowed expanded telemedicine prescribing of buprenorphine and other controlled substances for SUD treatment during the PHE. The post-PHE framework includes specific accommodations for SUD telemedicine prescribing, with proposed and final DEA rulemaking addressing the rules for prescribing controlled substances for SUD treatment via telemedicine.

ESRD Home Dialysis Telehealth

Section 50302 of the Bipartisan Budget Act of 2018

Section 50302 of the Bipartisan Budget Act of 2018 authorized Medicare telehealth for End Stage Renal Disease home dialysis monthly clinical visits.

ESRD Home Dialysis Telehealth Coverage

For ESRD beneficiaries receiving home dialysis (peritoneal dialysis or home hemodialysis), Section 50302 authorizes monthly clinical visits via telehealth without geographic restriction, including the patient home as an authorized originating site. Initial in-person visits and certain other visits remain required.

Georgia ESRD Telehealth

Georgia has a substantial home dialysis population. ESRD home dialysis telehealth supports access to monthly nephrology clinical assessments, particularly valuable in rural Georgia where nephrology specialty access is limited.

Acute Stroke Telehealth

Section 50325 of the Bipartisan Budget Act of 2018

Section 50325 of the Bipartisan Budget Act of 2018 authorized Medicare telehealth for acute stroke evaluation and management without geographic restriction. The authority recognizes that acute stroke telestroke consultations require rapid expert evaluation regardless of geographic location.

Telestroke Implementation

Telestroke programs allow remote neurologists to evaluate suspected acute stroke patients via video, assess for thrombolytic therapy candidacy, and guide initial emergency department management. The Section 50325 authority provides Medicare payment for telestroke consultations without geographic restriction.

Georgia Telestroke Networks

Major Georgia health systems including Emory Healthcare, Augusta University, and Grady Health System operate telestroke networks providing remote acute stroke expertise to smaller community hospitals across Georgia. Telestroke programs are critical for rural Georgia hospitals lacking on-site neurology coverage.

DEA Controlled Substance Telemedicine Prescribing

The Ryan Haight Act of 2008

The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 generally requires an in-person medical evaluation prior to prescribing controlled substances via telemedicine. The Act includes exceptions for certain practitioners and circumstances:

• Patients located in DEA-registered hospitals or clinics
• Patients located in the presence of another DEA-registered practitioner
• Indian Health Service or Veterans Affairs practitioners
• Practitioners with DEA Special Registration for telemedicine
• Practitioners practicing telemedicine in accordance with HHS-designated public health emergencies
• Other specific circumstances

DEA Special Registration

The Ryan Haight Act contemplated a Special Registration framework allowing certain practitioners to prescribe controlled substances via telemedicine without the in-person evaluation requirement. The DEA Special Registration framework has been incompletely implemented; DEA has issued proposed rules and pending final rules.

COVID-Era Telemedicine Prescribing Flexibilities

During the COVID-19 PHE, DEA temporarily allowed expanded telemedicine prescribing of controlled substances. These flexibilities were extended after the PHE through specific DEA actions and proposed rules.

Post-PHE Telemedicine Prescribing Framework

DEA has proposed and revised rules establishing the post-PHE telemedicine controlled substance prescribing framework. Current rules (subject to further DEA action) generally allow:

• Schedule III-V medications via telemedicine for ongoing therapy with limited in-person visit requirements
• Schedule II medications generally requiring in-person evaluation with specific exceptions
• SUD telemedicine prescribing accommodations
• Various transitional provisions

Georgia DEA-Registered Practitioners

Georgia DEA-registered practitioners can prescribe controlled substances via telemedicine within the federal framework and Georgia Composite Medical Board standards. Georgia practitioners should follow current DEA guidance and Georgia state requirements for telemedicine prescribing.

Place of Service Codes and Modifiers

Place of Service (POS) Codes

Medicare telehealth claims must include appropriate Place of Service (POS) codes:

• POS 02 (Telehealth Provided Other than in Patient's Home): Used when the patient is at a location other than their home during the telehealth encounter
• POS 10 (Telehealth Provided in Patient's Home): Used when the patient is in their home during the telehealth encounter

Modifier 95

Modifier 95 indicates synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system. Modifier 95 should be appended to telehealth service codes to identify the service as telehealth-furnished.

Modifier 93

Modifier 93 indicates synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. Modifier 93 is used for audio-only telehealth services where audio-only is authorized.

Modifier FQ and FR

Modifiers FQ (telehealth service was furnished using audio-only communication technology) and FR (a supervising practitioner was physically present via real-time two-way, audio/video communication technology) are additional Medicare telehealth modifiers.

Beneficiary Cost-Sharing

Standard Part B Cost-Sharing

Medicare telehealth services generally have the same beneficiary cost-sharing as in-person services:

• The annually-indexed Part B deductible applies (see Medicare.gov for the current-year amount)
• A standard Part B coinsurance applies after the deductible for most services
• Coinsurance applies regardless of whether the service is in-person or telehealth

PHE-Era Cost-Sharing Waivers

During the COVID-19 PHE, CMS allowed providers to waive Medicare cost-sharing for certain telehealth services. The PHE-era cost-sharing waiver authority ended with the PHE.

Medicare Advantage Plan Cost-Sharing

Medicare Advantage plans may waive or reduce cost-sharing for telehealth services, often as part of plan supplemental benefits. Specific telehealth cost-sharing varies by plan; beneficiaries should review their plan documents.

State Licensure and Standards of Care

Federal Telehealth and State Licensure

Federal telehealth coverage rules (Medicare, Medicaid, etc.) operate within state licensure frameworks. Generally, the practitioner furnishing telehealth must be licensed in the state where the patient is located at the time of the encounter, subject to:

• Interstate licensure compacts
• State-specific telehealth licensure exceptions
• Emergency authorizations
• Federal preemption in specific circumstances

Interstate Medical Licensure Compact

The Interstate Medical Licensure Compact (IMLC), administered by the IMLC Commission, provides expedited multi-state licensure for qualifying physicians. Georgia is a member of the IMLC. Physicians qualifying through the IMLC can obtain full medical licenses in multiple member states more efficiently than through individual state applications.

Georgia Medical Licensure Requirements

Georgia generally requires physicians furnishing telehealth services to patients located in Georgia to hold a Georgia medical license. Georgia accepts IMLC-issued licenses. Specific limited telehealth license categories exist for certain circumstances. Practitioners should consult the Georgia Composite Medical Board for current licensure requirements.

Georgia Composite Medical Board Telehealth Rules

Rule 360-3-.07 Telehealth

The Georgia Composite Medical Board Rule 360-3-.07 establishes Georgia-specific telehealth standards for licensed physicians, physician assistants, and respiratory care professionals practicing telemedicine in Georgia.

Telehealth Modality Definitions

Rule 360-3-.07 defines telehealth modalities:

• Telemedicine: Real-time, two-way interactive audio-video communication
• Telephonic: Audio-only communication
• Asynchronous: Store-and-forward (recorded video, images, or other digital data)
• Remote Patient Monitoring: Physiologic or other patient data collection and transmission

Standard of Care Requirements

Rule 360-3-.07 establishes that the standard of care for telehealth services must be equivalent to in-person care. Specific provisions address:

• Establishment of practitioner-patient relationship
• Informed consent
• Patient identification
• Medical history and examination requirements
• Prescription requirements
• Recordkeeping
• Privacy and HIPAA compliance

Telehealth Informed Consent

The Georgia rules require specific telehealth informed consent including: explanation of telehealth modality, limitations of telehealth, patient option to refuse or terminate, security considerations, and other elements. Practitioners should document telehealth informed consent in the medical record.

Georgia Medicare Telehealth Services: The Georgia Landscape

Georgia Partnership for Telehealth (GPT)

The Georgia Partnership for Telehealth (GPT), headquartered in Waycross, Georgia, operates one of the country's largest statewide telehealth networks. GPT is a 501(c)(3) nonprofit that:

• Connects rural healthcare providers with urban specialists
• Provides telehealth infrastructure and connectivity
• Supports school-based telehealth programs
• Coordinates statewide telehealth education
• Operates telehealth carts and equipment throughout Georgia

Major Georgia Health System Telehealth Programs

Emory Telehealth: Emory Healthcare operates a comprehensive telehealth program including primary care virtual visits, urgent care telemedicine, specialty consultations, telestroke services, behavioral health telemedicine, and other services. Emory eICU provides remote critical care support to multiple Georgia hospitals.

Wellstar MyChart Virtual Visits: Wellstar Health System provides virtual visits through MyChart, supporting primary care, urgent care, behavioral health, and various specialty telehealth services across the Wellstar network.

Piedmont Telemedicine: Piedmont Healthcare offers telemedicine for primary care, urgent care, behavioral health, and specialty consultations.

Northside Hospital eVisits: Northside Hospital provides virtual care including primary care, behavioral health, and specialty services.

Augusta University Telemedicine: Augusta University Health operates telemedicine programs including the Telestroke Network, telepsychiatry, teledermatology, and various specialty consultation services. AU has been a pioneer in Georgia telemedicine since the 1990s.

Grady Health Telemedicine: Grady Health System operates urban safety-net telemedicine programs in Atlanta.

Rural Georgia Telehealth Initiatives

Rural Georgia counties depend heavily on telehealth for access to specialty care. Rural Hospitals participating in telehealth networks include those affiliated with Phoebe Putney Health, Tift Regional Health System, Memorial Health (Savannah), and various Critical Access Hospitals. For the current count and roster of Georgia rural hospitals, consult the Georgia State Office of Rural Health and the Georgia Hospital Association.

Georgia Department of Public Health Telehealth

The Georgia Department of Public Health operates telehealth initiatives through its Public Health Districts, supporting:

• School-based telehealth programs (often partnering with GPT)
• Public health nurse case management
• Maternal and child health telehealth
• Communicable disease consultation
• Behavioral health crisis response

Georgia Senate Resolution 49 and State Telehealth Policy

The Georgia General Assembly has periodically addressed telehealth policy through legislation and resolutions. Recent state legislative attention has addressed payer parity for commercial insurance telehealth coverage, telehealth licensure portability, and other state policy issues.

Worked Example 1: Rural Georgia Beneficiary Specialty Consult Via Telehealth

A 72-year-old Medicare beneficiary in rural Coffee County, Georgia, has been referred by her primary care physician to an endocrinologist for evaluation of complex diabetes management. The nearest endocrinologist is 90 miles away in Tifton.

Pre-COVID Section 1834(m) framework: Coffee County, as a non-MSA county, qualified as a permitted originating site location. The beneficiary would need to travel to her primary care physician's office (an authorized originating site) to receive telehealth services from the endocrinologist. The patient home would not be authorized.

Current framework (under temporary extensions): With the geographic restriction waived and the patient home authorized as an originating site, the beneficiary can receive the telehealth endocrinology consult from her home. The endocrinologist in Tifton furnishes the consult via real-time audio-video using a HIPAA-compliant telehealth platform. The endocrinologist bills a consultation code with modifier 95 and POS 10 (Telehealth Patient Home). Medicare pays the consultation rate under the Medicare Physician Fee Schedule.

Cost to beneficiary: Standard Part B cost-sharing applies after the deductible.

Reversion risk: If Congressional telehealth extensions lapse, this scenario reverts to the pre-pandemic framework. The beneficiary would need to travel to a permitted originating site, potentially abandoning the consult due to transportation challenges.

Worked Example 2: Mental Health Telehealth With Permanent Authority

A 68-year-old Medicare beneficiary in Atlanta with major depressive disorder is receiving psychotherapy from a licensed clinical social worker (LCSW). The beneficiary prefers telehealth due to mobility limitations and the social worker's practice is across town.

Section 1834(m)(7) permanent authority: Mental health telehealth is permanent under Section 1834(m)(7), with no geographic restriction and the patient home as an authorized originating site. The LCSW furnishes weekly psychotherapy via video using a HIPAA-compliant platform. The LCSW bills a psychotherapy code with modifier 95 and POS 10.

Audio-only sessions: For occasional sessions when video is not feasible, the LCSW can furnish audio-only psychotherapy under CMS audio-only mental health authorization. Audio-only sessions are billed with modifier 93 indicating audio-only delivery.

In-person visit requirement: Section 1834(m)(7) as originally enacted requires an in-person visit within six months before initial telehealth and at least annually thereafter. Congress has repeatedly delayed implementation of the in-person visit requirement. Practitioners should consult current CMS guidance for current requirements.

Permanence advantage: Unlike non-mental-health telehealth subject to recurring Congressional cliffs, mental health telehealth has permanent statutory authority, and beneficiaries and practitioners can rely on continued coverage regardless of CR action.

Worked Example 3: Audio-Only Telehealth for Vulnerable Patient

An 82-year-old Medicare beneficiary in rural Telfair County lives alone, has limited technology literacy, and lacks broadband internet for video telehealth. She does have a landline telephone. Her primary care physician wants to provide follow-up care without requiring her to drive to the office.

Audio-only mental health telehealth (permanent): For mental health services, audio-only telehealth is permanently authorized. The PCP can refer the beneficiary to a behavioral health practitioner who can furnish audio-only psychotherapy under Section 1834(m)(7).

Audio-only non-mental-health (temporary): Under current temporary extensions, audio-only is authorized for various non-mental-health Medicare services including certain E/M visits. The PCP can furnish a telephone follow-up E/M visit under appropriate audio-only Medicare codes with modifier 93. If extensions lapse, audio-only non-mental-health would revert to pre-pandemic restrictions.

Brief check-in alternative: Even without telehealth extensions, the PCP could furnish a virtual check-in under HCPCS G2012 (5-10 minutes of medical discussion via telephone or other technology). G2012 is a permanent Medicare benefit not subject to Section 1834(m) restrictions.

Cost to beneficiary: Standard Part B cost-sharing applies after the deductible.

Worked Example 4: Remote Patient Monitoring for Chronic Disease

A 70-year-old Medicare beneficiary with congestive heart failure and hypertension is enrolled in her cardiologist's Remote Patient Monitoring program. She receives a Bluetooth-enabled scale and blood pressure cuff that transmit daily readings to the cardiology practice.

Initial setup: The cardiologist bills CPT 99453 once for the initial set-up and patient education on the monitoring equipment.

Device supply: The cardiologist bills CPT 99454 each 30 days for the device supply with daily recordings transmitted (requires at least 16 days of monitoring data in the 30-day period).

Treatment management time: When the cardiologist or qualified clinical staff spend at least 20 minutes in a calendar month reviewing data and providing interactive communication with the patient, the cardiologist bills CPT 99457. Additional 20-minute increments are billed as CPT 99458.

Permanent benefit: RPM is a permanent Medicare benefit not subject to Section 1834(m) telehealth restrictions. RPM operates regardless of whether non-mental-health telehealth extensions are in place.

Beneficiary cost-sharing: Standard Part B cost-sharing applies after the deductible.

Worked Example 5: FQHC Distant Site Telehealth Visit

A 65-year-old Medicare beneficiary in rural Hancock County, Georgia, is established with a primary care physician at the local FQHC. She has been experiencing chronic back pain and her PCP wants to consult with an orthopedist. The FQHC has a telehealth relationship with an orthopedist in Macon.

Pre-COVID framework: The FQHC could serve as an originating site (the patient location) but not as a distant site. The orthopedist would furnish the consult from his Macon practice.

Current framework with FQHC distant site authority (temporary extension): Under Section 4113 CAA 2023 and subsequent CR extensions, FQHCs are authorized to serve as distant sites for Medicare telehealth. If the FQHC's contracted orthopedist furnishes the consult while at the FQHC, the FQHC can bill the distant site service. The FQHC bills under the FQHC payment methodology with applicable modifier indicating telehealth.

Mental health FQHC distant site (permanent): For mental health services, FQHC distant site authority is permanent under Section 1834(o) (as amended). Mental health services can be furnished as distant site FQHC services regardless of non-mental-health extension status.

Reversion risk: If non-mental-health telehealth extensions lapse, FQHCs lose distant site authority for non-mental-health services. Safety-net telehealth access in rural Georgia would be substantially affected.

Worked Example 6: Hospital-at-Home Enrolled Patient

A 75-year-old Medicare beneficiary in Atlanta presents to the Emory University Hospital emergency department with pneumonia and is determined to meet inpatient admission criteria. Emory participates in the CMS Acute Hospital Care at Home waiver program.

AHCAH enrollment: After clinical evaluation determining the patient meets AHCAH inclusion criteria and providing informed consent, the patient is enrolled in the AHCAH program. The patient is transported to her home with continuous remote monitoring equipment and a dedicated AHCAH care team.

At-home care delivery: The AHCAH program provides:

• Twice-daily in-person nursing visits
• Continuous remote vital signs monitoring
• 24/7 access to the AHCAH care team via telephone or video
• Daily physician evaluations (in-person or via telemedicine)
• IV antibiotics, oxygen, and other inpatient-equivalent interventions
• Laboratory and imaging as needed (mobile or arranged)

Hospital billing: Emory bills the inpatient stay under DRG-based hospital inpatient payment as if the care were furnished in the brick-and-mortar hospital. The CMS Section 1135 waiver allows AHCAH billing under the hospital Conditions of Participation framework.

Permanence status: AHCAH waiver authority is subject to statutory extension. The Consolidated Appropriations Act of 2023 extended AHCAH past the end of the PHE, with subsequent CR extensions. Continued AHCAH operation depends on Congressional reauthorization.

Best Practices for Georgia Medicare Beneficiaries

1. Ask your physician about telehealth options. Many Georgia providers offer telehealth for primary care, behavioral health, and various specialties.
2. Verify your insurance coverage. Medicare telehealth coverage applies to Original Medicare; Medicare Advantage plans may offer broader or different telehealth benefits.
3. Plan for the technology. Telehealth visits require working video and audio equipment, a stable internet connection (for video), and a private location.
4. Schedule a technology check if needed. Many providers offer pre-visit technology testing.
5. Use mental health telehealth confidently. Mental health telehealth has permanent statutory authority and remains covered regardless of Congressional CR action.
6. Understand the temporary nature of some flexibilities. Non-mental-health telehealth (especially home-based and audio-only) depends on continuing Congressional extensions.
7. Bring complete information to telehealth visits. Medication lists, vital signs (home blood pressure, weight), symptom logs, and questions help maximize visit value.
8. Document important visit information. Take notes during the visit and ask the provider to summarize plans and follow-up.
9. Know when in-person care is necessary. Telehealth has limitations; some conditions require physical examination, procedures, or imaging.
10. Ask about Remote Patient Monitoring if you have chronic conditions. RPM for hypertension, diabetes, congestive heart failure can support better disease control.
11. Consider telehealth for follow-up visits. Many follow-up visits (post-hospitalization, medication adjustments, lab review) can be efficiently delivered via telehealth.
12. Use virtual check-ins for brief questions. HCPCS G2012 virtual check-ins (5-10 minute telephone conversations) are convenient for quick clinical questions.
13. Document informed consent. Some Georgia practitioners obtain specific telehealth informed consent before visits.
14. Know your rights. You have the right to refuse telehealth and request in-person care, the right to terminate a telehealth visit, and the right to confidential treatment.

Common Telehealth Issues and Solutions

1. Internet connectivity problems: Many rural Georgia areas have limited broadband. Use telephone-only options when video is unavailable.
2. Technology literacy challenges: Providers can arrange pre-visit technology setup, family member assistance, or community telehealth sites at FQHCs or partner organizations.
3. Privacy concerns: Conduct telehealth visits from a private location at home; if no private location available, use a community telehealth site.
4. Hearing impairment: Many telehealth platforms support live captioning; alternative formats include relay services and asynchronous messaging.
5. Cognitive impairment: Family caregivers can assist with telehealth visits with patient permission and HIPAA-compliant arrangements.
6. Lack of equipment: Various programs provide telehealth equipment to underserved beneficiaries; ask your provider, local Area Agency on Aging, or GeorgiaCares SHIP about resources.
7. Insurance coverage questions: Contact 1-800-MEDICARE, your Medicare Advantage plan, or GeorgiaCares SHIP for coverage information.
8. Out-of-state providers: Generally, the practitioner furnishing telehealth must be licensed where the patient is located. Practitioners participating in the IMLC may have multi-state licensure.
9. Cross-county telehealth: Within Georgia, telehealth can be furnished across counties, subject to provider licensure and practice arrangements.
10. Telehealth records access: You have the same right to telehealth visit records as in-person visit records.
11. Medication prescription via telehealth: Most medications can be prescribed via telehealth following the practitioner's standard of care. Controlled substance prescribing has specific DEA rules.
12. Follow-up coordination: Ensure clear understanding of follow-up care, referrals, and next steps before ending telehealth visits.
13. Audio-only billing for vulnerable patients: Practitioners can bill audio-only Medicare services for patients lacking video capability under current authorities.
14. Telehealth cost transparency: Ask your practitioner about expected costs (deductible, coinsurance) before telehealth visits.

A few more common questions:

What is Medicare telehealth? Medicare telehealth refers to clinical services furnished to Medicare beneficiaries via two-way, real-time interactive audio-video telecommunications technology (and in some cases audio-only). Section 1834(m) of the Social Security Act governs Medicare coverage of telehealth services, with substantial COVID-era expansions and ongoing Congressional extensions.

What is the telehealth cliff? The phrase refers to the recurring deadlines at which non-mental-health Medicare telehealth flexibilities would expire without Congressional extension. The pattern of CR-based extensions has created uncertainty for beneficiaries, providers, and health systems.

What is audio-only telehealth? Audio-only telehealth involves telephone or other audio-only communication (without video). Pre-pandemic Medicare generally required real-time audio-video for telehealth. The PHE waivers authorized audio-only for various services. Audio-only mental health is permanently authorized for certain services; audio-only non-mental-health remains subject to Congressional extension.

What is Remote Patient Monitoring (RPM)? RPM under CPT codes 99453, 99454, 99457, and 99458 is a permanent Medicare benefit allowing physicians and qualified health care professionals to monitor patient physiologic data (such as blood pressure, weight, blood glucose) collected by digital devices and transmitted electronically. RPM is not subject to Section 1834(m) telehealth restrictions.

What is a virtual check-in? Virtual check-ins under HCPCS G2010 (remote evaluation of recorded video/images) and G2012 (5-10 minutes of medical discussion via telephone or other technology) are brief patient-practitioner communications not subject to Section 1834(m) telehealth restrictions. They are permanent Medicare benefits.

How are controlled substances prescribed via telemedicine? The Ryan Haight Act of 2008 generally requires an in-person medical evaluation prior to prescribing controlled substances via telemedicine, with specific exceptions. DEA expanded telemedicine prescribing during the PHE; the post-PHE framework includes SUD telemedicine accommodations and various transitional provisions. Practitioners should consult current DEA rules.

Do I pay anything for Medicare telehealth? Yes. Standard Part B cost-sharing applies (the annual deductible plus standard coinsurance for most services). PHE-era cost-sharing waivers ended with the PHE. Medicare Advantage plans may offer reduced or waived telehealth cost-sharing.

Brevy: Your Partner in Understanding Georgia Medicare Telehealth Services

At Brevy (brevy.com), our mission is to provide Georgia families with comprehensive, up-to-date guidance on Medicare, Medicaid, VA benefits, and the broader eldercare landscape. Medicare telehealth coverage has transformed dramatically since 2020 and continues to evolve through Congressional reauthorization action and CMS rulemaking. For Georgia Medicare beneficiaries, understanding the difference between permanent and temporary telehealth authorities is essential for planning care.

If you have questions about whether your physician offers Medicare telehealth, what telehealth services your Medicare or Medicare Advantage plan covers, or how to access telehealth despite technology challenges, contact your physician's office directly, call 1-800-MEDICARE, or reach out to GeorgiaCares SHIP for free unbiased counseling. The Georgia Partnership for Telehealth and various community-based programs provide additional telehealth support resources. Brevy continuously updates content to reflect Congressional action on telehealth permanence, CMS rulemaking, and emerging telehealth practice patterns.

Find personalized help navigating Georgia Medicare telehealth services at brevy.com.