Table I.

Updates in telehealth policy in the COVID-19 crisis^∗,+

	Pre-COVID-19 telehealth policy∗	COVID-19†
Physician licensure	Providers must be licensed in state of the patient	Waived but state regulations apply.
Patient population	Established patient of the practice (within 3 years)	New or established patients
Patient location	Eligible originating sites Rural communities (HRSA)	All settings, including patient's home.
Technology1	Synchronous (live-interactive) Asynchronous (store & forward)	No change.
Privacy and security	HIPAA compliance	Not enforced.
Synchronous E-visit (provider to patient)	Codes: 99201-99215 Only for established patients in eligible originating sites and geographic locations. Place of Service code: POS 02 Co-insurance/deductibles apply	May be reimbursed at the same amount as in-person visits, when using an interactive audio and video telecommunications system permitting real-time communication between distant site and patient at home.^ Providers have flexibility in reducing/waiving out-of-pocket costs for patients. New or established patients Place of Service code: POS 11> Modifier: 95< E/M level selection can be based on MDM or time∗∗
Asynchronous E-visit using patient portal (provider to patient)	Codes: 99421-3 Place of Service code: POS 02 Established patients only.	New or established patients Place of Service code: POS 11> Modifier: 95<
Interprofessional E-consultations (provider to provider)	Synchronous, asynchronous, or telephone New or established patients Codes: 99446-99452 Place of Service code: POS 11	Place of Service code: POS 11> Modifier: 95<
Virtual check-in (provider to patient)	Synchronous, asynchronous, or telephone - Patient initiated - Established patients only - Brief, 5-10 minutes - Cannot result from/lead to E/M service within previous 7 days or next 24 hours. - Low reimbursement Codes: G2010 (asynchronous) G2012 (synchronous) Place of Service code: POS 02	New or established patients Place of Service code: POS 11> Modifier: 95<
Other payers
Medicaid	By state2	Evolving by state
Private	By state2 Billing modifier 95 (synchronous)	Evolving1

E/M, Evaluation and management; HIPAA, Health Insurance Portability and Accountability Act; HRSA, Health Resources and Services Administration.

^∗Medicare policy unless otherwise stated.

⁺Please see AAD Teledermatology Toolkit for the most up to date codes and resources.^1†CMS is expanding telehealth on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act. The Department of Health and Human Services (HHS) is announcing a policy of enforcement discretion for Medicare telehealth services furnished pursuant to the waiver under section 1135(b)(8). Changes also include the Interim Rule issued March 30, 2020. ^{^}Retroactive coverage to March 6, 2020. ^>Practitioners who bill Medicare telehealth services should report POS code that would have been reported had the service been furnished in person. ^<Before COVID-19, Medicare used POS 02 to identify telehealth services; however, due to the change in POS code to increase reimbursement, Medicare requests the use of modifier 95 to describe services furnished by telehealth.

^∗∗Time defined as all of the time associated with E/M on the day of service.