Virtual Visit E/M Coding Overview
Virtual visits use the same E/M codes as in-person encounters (99202-99215 for new/established patients). The 2021 E/M guideline changes allow providers to select E/M level based on either medical decision-making (MDM) complexity or total time spent on the encounter. For telehealth, time-based billing includes all time on the date of the encounter: pre-visit chart review, the video session, post-visit documentation, and care coordination.
Code Selection for Virtual Visits
- 99213 (established, low complexity) — straightforward follow-ups: medication refills, stable chronic conditions, lab review. 20-29 minutes total time.
- 99214 (established, moderate complexity) — conditions requiring adjustment: new symptoms, medication changes, multiple chronic conditions. 30-39 minutes total time.
- 99215 (established, high complexity) — complex visits: multiple comorbidities, diagnostic uncertainty, or care coordination with specialists. 40-54 minutes total time.
- 99204/99205 (new patient, moderate/high) — initial telehealth evaluations for new patients. 45-59 minutes (99204) or 60-74 minutes (99205).
Documentation Requirements
Document the visit modality (synchronous audio-video), platform used (must be HIPAA-compliant), patient consent for telehealth, and the clinical encounter note. For time-based billing, document total time in the note: "Total time for this encounter: 35 minutes including pre-visit chart review, 22-minute video visit, and post-visit medication reconciliation." Include modifier 95 and the correct POS code on the claim.
Common Denials
CO-16 occurs when the POS code does not match the telehealth modifier. CO-6 flags incorrect place of service. CO-50 indicates the service is not on the payer's telehealth-eligible list. See telehealth setup for initial configuration and telehealth payers for coverage details by carrier.
Common Questions About Virtual Visit Coding
Can I bill a higher E/M level because telehealth visits take more time?
Yes, if using time-based billing. All time on the date of encounter counts — chart review, the video session, documentation, and coordination. If the total time supports 99214 (30-39 minutes), bill 99214 regardless of session length alone. Document the total time.
Do telehealth visits reimburse at the same rate as in-person?
Medicare reimburses telehealth E/M at the same rate as in-person when POS 10 is used. Most commercial payers (UHC, Anthem, Aetna) also reimburse at parity. Some state Medicaid programs reimburse at reduced rates. Check the payer's telehealth fee schedule.
Simplify Telehealth Billing
Altair validates coding rules and identifies issues before you submit. See how it works.
← Back to Telehealth Reference
This reference is for informational purposes. Always verify against current payer policies, CPT guidelines, and CMS documentation. Last updated: 2026-04-06.