. 2022 Apr 25;49(4):517–530. doi: 10.1016/j.pop.2022.04.002

Table 1.

Comparison of Centers for Medicare & Medicaid Services telehealth regulations before and after March 2020

Before March 2020	After CARES Act and CMS 1135 Waiver
Who can perform and receive telehealth
Only certain licensed providers	Any type of clinician can bill for Medicare services
Patients and providers who have a preexisting relationship	No preexisting relationship will be required
Where can telehealth be done
Only at prespecified sites (ie, designated rural areas, certain medical facilities)	Telehealth may originate and be conducted from any site, including patient’s home
Physicians must conduct telehealth from their place of practice	Physicians may conduct telehealth from home
Telehealth may not cross state lines	Telehealth can now be provided to patient in another state (state-specific restrictions may still apply)
What must be used for telehealth visits
Must be audio-visual (ie, video technology)	Audio-visual OR audio-only are allowed
Only approved technology platforms	Expanded approved platforms, including FaceTime, Skype, and Zoom
How is telehealth reimbursed
Medicare coinsurance and deductibles apply to telehealth visits	Providers may waive cost-sharing for telehealth paid for by federal programs
Reimbursements for telehealth services is lower than for in-person services	All telehealth visits, including audio-only, will be reimbursed as if the service was furnished in person