CurrentMedicarePolicy N/A

Risk Adjustment Telehealth and Telephone Services — 2023 Benefit Year

Defines which telehealth and telephone-only services and related CPT/HCPCS codes are valid for submission to the HHS-operated risk adjustment program for the 2023 benefit year, subject to applicable state law, and explains validation equivalence with face-to-face services.

Policy Summary

PayerMedicare

PolicyRisk Adjustment Telehealth and Telephone Services — 2023 Benefit Year

Policy CodePolicy N/A

Change TypeExtension of existing telehealth/telephone code designations

Effective Date2023 benefit year

Next Review DateN/A

Key ActionSubmit telehealth and telephone-only services that are reimbursable under applicable state law and meet risk adjustment data standards to issuers' EDGE servers for inclusion and validation equivalent to face-to-face visits.

SourceLink

POLICY UPDATE CHANGES

Extension of prior telehealth and telephone-only coding policies (including specific e-visit and telephone CPT codes) through the entire 2023 benefit year for HHS-operated risk adjustment data submissions.

2023policy coverage extended through

98970-98972, 99421-99423e-visit codes designated valid

98966-98968, 99441-99443telephone-only codes designated valid

Equivalenttelehealth equivalence

Inclusion Criteria for Risk Adjustment Submissions

Inclusion criteria

Covered when ALL of the following are met:

ALL of the following

Service must be reimbursable under applicable state law (state of issuer licensure and provider licensure rules apply)
Service must otherwise meet applicable HHS risk adjustment data submission standards and diagnostic value requirements
ALL of the following
- Examples include
  - E-visit CPT codes: 98970-98972, 99421-99423

Policy Summary

PayerMedicare

PolicyRisk Adjustment Telehealth and Telephone Services — 2023 Benefit Year

Policy CodePolicy N/A

Change TypeExtension of existing telehealth/telephone code designations

Effective Date2023 benefit year

Next Review DateN/A

SourceLink

On This Page

Trek Health ingests and normalizes Transparency in Coverage data and payer policy updates to give provider organizations a clear view of how commercial reimbursement behaves across markets, payers, and services. Our platform transforms raw payer disclosures into structured intelligence that supports contract evaluation, payer negotiations, and service line strategy. By combining market benchmarks with ongoing policy visibility, Trek helps teams identify variability, risk, and opportunity in commercial reimbursement. The result is faster insight, stronger negotiating positions, and more informed financial decisions.

Valid Codes and Applicability

E-visit CPT codesCPTCovered

98970-98972	CPT e-visit codes (online assessments)
99421-99423	CPT e-visit codes (online digital communication)

Telephone-only CPT codesCPTCovered

98966-98968	Telephone-only service CPT codes
99441-99443	Telephone E&M CPT codes

Additional telehealth HCPCS/modifier indicationsHCPCS

G0425-G0427, G0406-G0408, G0459, G0508-G0509	Telehealth-related HCPCS codes (ED and inpatient telehealth consultations, follow-up telehealth consultations)
Modifiers 93/95/GQ/GT; POS 02/10	Modifiers and place-of-service codes indicating telehealth

inv-05: applicability — codes valid for risk adjustment if reimbursable under applicable state law and meet submission standards.

Applicability for risk adjustmentCodes are valid for inclusion in HHS-operated risk adjustment data submissions only if the service is reimbursable under applicable state law and otherwise meets HHS risk adjustment data submission standards.

Benefit year scopeDesignations apply for the full 2020–2023 benefit years (policies extended through the entire 2023 benefit year due to operational complexities).

Submission pathwayServices meeting the conditions may be submitted to issuers' EDGE servers for HHS-operated risk adjustment processing.

Validation parityDiagnosis codes from these codes will be validated in the same manner as diagnoses from in-person services for risk adjustment purposes.

Submission Requirements and Equivalence

Documentation Required

Submit telehealth/telephone-only services as equivalent to face-to-face when reimbursable and standards met

Telehealth and telephone-only services that are reimbursable under applicable state law and meet HHS risk adjustment data submission standards may be submitted to issuers' EDGE servers and are treated as equivalent to face-to-face visits for diagnostic inclusion and validation.

Services must be reimbursable under applicable state law (state of issuer licensure and provider licensure rules apply).
Services must meet applicable HHS risk adjustment data submission standards and diagnostic value requirements.
Diagnosis codes submitted via allowable telehealth or telephone-only services will be validated the same as in-person services.

Terms and Modifiers

inv-07: Definition of telehealth visits — services via telecommunication technologies considered equivalent to face-to-face for diagnosis inclusion and validation.

DefinitionTelehealth visits are services provided via telecommunication technologies that are reimbursable under applicable state law and are considered equivalent to face-to-face interactions for risk adjustment diagnosis inclusion and validation.

Diagnostic equivalenceDiagnoses furnished via allowable telehealth services are treated as equivalent to face-to-face diagnoses and are subject to the same provider-type and diagnostic-value requirements for validation.

Code examplesCPT e-visit codes (98970-98972, 99421-99423) have been designated valid for risk adjustment filtering and are examples of telehealth/virtual services used for online assessments and E&M.

inv-08: Modifiers and place-of-service codes — use of modifiers (93/95/GQ/GT) and POS codes '02' or '10' to indicate telehealth without affecting inclusion.

Accepted modifiers and POSModifier codes 93, 95, GQ, GT and place-of-service codes '02' or '10' may be used to indicate services furnished via telehealth.

Impact on inclusionChanging the modifier or place of service for an otherwise acceptable face-to-face service to indicate telehealth does not affect the service's inclusion for HHS risk adjustment purposes.

Audio-only treatmentServices eligible to be provided as audio-only (telephonic) with modifier 93 are considered equivalent to other telehealth services for inclusion in risk adjustment.