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Telehealth

Telehealth is an emerging area of practice for many health care professionals. Regulations, policies, and standards are in flux until a "gold standard" becomes consensus; but that has not stopped technology from entering into mainstream practice. It is not surprising that RDNs are asking themselves how their patients can benefit from Telehealth and Telenutrition.

Here, you will find information for providing telehealth care to your patients.

RDNs' Guide to Practicing Telehealth During the COVID-19 Pandemic

Updated December 22, 2020

This quick guide provides guidance about practicing telehealth in the context of the COVID-19 national public health emergency as Medicare, commercial/private payers, and some Medicaid programs temporarily modify their policies and rules to expand access to care via telehealth. The guide is for RDNs who are working in ambulatory health and outpatient settings and already providing in-person MNT to consumers with Medicare, commercial/private insurance, and/or Medicaid (e.g., already a network provider with payers).

  • In addition to the use of audio-visual interaction to provide MNT to Medicare Part B beneficiaries during the public health emergency, Medicare is permitting audio-only delivery for some services, including MNT (97802-4, G0270), as of March 1, 2020, in cases when audio and video are not possible. Check with other payers about the ability to provide MNT via telephone.
  • The following services can also be provided to Medicare beneficiaries by audio-only: DSMT (G0108, G0109), and IBT for obesity (G0447) services.
  • Medicare is temporarily covering specific CPT® codes for telephone assessment and management services (98966-98968) that can be used after seven days following an MNT visit. These codes were not previously paid under the Medicare Physician Fee Schedule. The telephonic codes are not used to submit claims for providing MNT. Check with other payers regarding coverage for these codes.
  • The Coronavirus Aid, Relief and Economic Security (CARES) Act increases payments to RDNs and others by two percent by temporarily suspending sequestration.
  • If you are an RDN working in a hospital outpatient setting, please refer to your organization for specific guidance. If your organization is providing other services via telehealth, RDNs may be able to leverage internal resources.
  • RDNs in all Federally Qualified Health Centers and Rural Health Centers can provide MNT via telehealth to patients of the health centers in which they work.
  • If you are Medicaid/CHIP provider in your state, refer to your state Medicaid program to understand whether CMS waivers affect the delivery of service (e.g., via telehealth) broadly or for specific populations.
  • If you are interested in becoming a Medicare provider, Medicare has expedited the Medicare Part B provider enrollment process to offer temporary Medicare billing privileges.
  • If you are not already providing MNT services to consumers and billing insurance, visit the Academy's Payment section.

RDNs will need to confirm policies with each private payer, including Medicare Part C (Medicare Advantage) plans, or respective Medicaid programs. Policies and rules are changing daily, so check Academy updates on a regular basis for the most current information.

This information should not be interpreted as a change in benefits and coverage for Medical Nutrition Therapy, but rather how the MNT can be provided. Payment for MNT and other services provided by RDNs is still dependent on several factors including, but not limited to, individual patient benefits, individual policy coverage specifics, provider status (in network vs out of network), and related payer policies. In addition to numerous temporary changes related to telehealth delivery, many insurance companies are also waiving copayments and cost sharing for many services.

First Steps
  • Check with your professional liability insurance carrier to ensure your policy covers providing MNT via telemedicine. The professional liability insurance offered through the Academy's Member Advantage Program (Proliability administered by Mercer Consumer) does not exclude telehealth/telemedicine services.
  • Determine your needs for cyber and data breach coverage. The use of telehealth exposes providers and organizations to additional risk of cyber theft and data breaches of sensitive client information. General and professional liability insurance does not protect providers from damages that may result from cyber/data breaches. Read more information
  • Familiarize yourself with the interim telehealth policies with any payers for whom you are a network provider. See "Coding, Billing, and Payment for MNT and DSMT When Delivered via Telehealth During COVID-19", Private/Commercial Payers for more information.
  • Ensure that you are providing services in accordance with your state laws and regulations.
  • Licensure:
    • If you are licensed in the state where the patient is located, there are no additional requirements.
    • If you are not licensed in the state where the patient is located, you are likely to be required to become licensed either (1) to provide MNT at all to clients or patients in that state or (2) to be eligible to provide nutrition care services via telehealth in that state. View the Academy’s interactive Licensure Map for help in answering the question, “Can I practice in this state?”
    • To support the delivery of nutrition services across state lines and via telehealth by RDNs during the COVID-19 national emergency, the Academy has itemized certain licensure requirements and exemptions in a state-by-state table.
    • Information will continue to be updated as policies and interpretive guidance evolve. In addition, there are often specific rules requiring a license to provide telehealth services to Medicaid beneficiaries. Medicaid waivers to these requirements must be requested by the individual state that wants to use them. Although many states have temporarily relaxed regulations related to the provision of certain telemedicine services, we recommend you contact your state department of health, state dietetics board, or state medical association for up-to-the-minute information in your state.
Telehealth Platform/Vendor Selection

This content is designed to provide information only and not intended to endorse any specific products or services.

You will need to use communications technology that complies with payer requirements to provide MNT to your patients remotely. Medicare and several payers have relaxed requirements during the public health emergency. Services delivered via the telephone may not be included as state laws and payer policies typically require audio-video interactions. Medicare is permitting audio-only delivery for MNT services (97802-4, G0270), as of March 1, 2020. Make sure to get clarification from private payers and state Medicaid programs regarding the ability to provide MNT telephonically.

  • If you are currently using a practice management system or electronic health record, check with the vendor about telehealth functionality.
  • Carefully review Business Associate Agreements for any telehealth platforms you are considering. Understand who has access to, and owns any data generated during a patient visit.
  • Ask colleagues what telehealth platforms they are using. Inquire with other Academy members via DPG list servs and the Reimbursement online community.
  • Consider ease-of-use for both the RDN and clients.
  • Consider whether you need a document sharing feature in a telehealth product.
  • Get clear on the pricing structure (e.g., monthly rate, subscription, per visit fees).
  • Confirm you have internet service that is optimal for supporting any telehealth platforms or any approved temporary communications technologies. The amount and speed of the internet connection, along with Wi-Fi signal strength where utilized, will impact the video quality and amount and speed of data transfers.
  • Compare the technical support available from telehealth vendors.

Non-public Facing Communications Technology to Provide Services via Telehealth

Medicare is allowing temporary use of non-public facing communications technology to provide services via telehealth. The Department of Health and Human Services Office for Civil Rights will temporarily waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday non-public facing remote communications technologies during the emergency. Keep in mind you may still have state requirements to meet.

Under Medicare, RDNs may temporarily use popular applications that allow for video chats. RDNs should notify patients that these third-party applications potentially introduce privacy risks. Take all steps to use available encryption and privacy modes when using the following applications. These include:

  • Apple FaceTime
  • Facebook Messenger video chat
  • Google Hangouts video
  • Whatsapp video chat
  • Zoom
  • Skype

Text messaging may temporarily be used to communicate with patients, including to provide online assessment and management services (G2061-G2063), using the following commonly used applications:

  • Signal
  • Jabber
  • Facebook Messenger
  • Google Hangouts
  • Whatsapp
  • iMessage

The following applications should not be used as they are public facing:

  • Facebook Live
  • Twitch
  • TikTok and similar video communication
  • Chat rooms such as Slack

Additional notes about selecting technology platoforms:

  • RDNs should seek clarification with commercial payers and Medicaid programs regarding rules and standards.
  • Be aware that if you are using personal devices to access any of the temporarily approved communications technologies, clients/patients may have access to your personal telephone numbers. There are apps available, such as Doximity, that allow clinicians to securely contact patients while also masking your own cell phone number and replacing it with your office number in the caller ID.
  • Ensure you and your client/patient have adequate battery/power and bandwidth if using cell phones or tablets.
  • RDNs who wish to provide MNT via telehealth beyond the time frame of the public health crisis will want to identify a telehealth platform that meets standard HIPAA and payer requirements. The list below includes some vendors that represent that they provide HIPAA-compliant video communication products and that they will enter into a HIPAA BAA:
    • Skype for Business / Microsoft Teams
    • Updox
    • VSee
    • Zoom for Healthcare
    • Doxy.me
    • Google G Suite Hangouts Meet
    • Cisco Webex Meetings / Webex Teams
    • Amazon Chime
    • GoToMeeting
    • Spruce Health Care Messenger
Workflow and Patient Care

Review and update all processes associated with appointments. Streamline processes. Try to use the same processes for in-person and telehealth visits (e.g., registration, obtain insurance information, share policies, obtain consent, documentation, issue receipts and superbills, and collect payments).

  • Investigate options for HIPAA-compliant electronic communication if not already established.
  • Obtain client consent to provide services using telehealth. For more information about state requirements regarding consent to provide services using telehealth visit State Telehealth Laws and Reimbursement Policies from the Center for Connected Health Policy.
    • Check to see if your telehealth vendor can support electronic consent.
    • Provided are sample telehealth consent forms from the Agency for Healthcare Research and Quality and the American Academy of Pediatrics.
    • If you are unable to obtain written consent, verbal consent is temporarily permitted during the COVID-19 PHE. Be sure to document how and when consent was obtained as part of the patient/client record.
  • Review the Office of Civil Rights announcements regarding temporary adjustments under HIPAA.
  • Confirm that MNT provided via telehealth is a covered benefit (in addition to verifying benefits and the coverage details for MNT) under each patient's individual insurance policy.
    • Clarify patient copayments and cost sharing for MNT or any other services you provide via telehealth during the COVID-19 PHE.
    • Billing instructions may differ (with the same insurance company) based on the type of individual plan a patient has (commercial, self-funded, Medicare Advantage, or other type). Clarifying billing instructions for services provided via telehealth can help to ensure accurate payments. Some payers are waiving copayments for certain services provided via telehealth during PHE.
  • Review and update policies as applicable.
  • Conduct a practice session before using any new platform.
  • Update voicemail, website, and social media to let your patients know your practice is now offering telehealth services.
  • Provide instructions or "tips" to help your clients access telehealthservices based on your practice's technology to maximize appointment time and avoid disruptions to care.
  • Consider data collection for the purposes of demonstrating effectiveness of your services when they are provided using telehealth. If you are already collecting data for outcomes evaluation in your practice and using both in-person and telehealth modalities to provide MNT, consider taking steps that will allow you to sort, analyze and compare outcomes based on the delivery modality. Practice level data may be helpful in your own contract negotiations. Academy members have free access to ANDHII, a registry that enables RDNs to track nutrition care outcomes and advance evidence-based nutrition practice research. ANDHII can help you track outcomes in your own practice and support the collective efforts to demonstrate effectiveness and value.
  • Identify and set up a quiet and professional space. Notice what your patients/clients will see.
  • Review tips for effective telehealth sessions
  • Identify teaching aides (labels, food/product photos) for telehealth purposes.
  • Determine how information (e.g. action plan, recommendations, written educational materials) will be provided to the client (e.g., email, provider portal, website) if not using a telehealth platform that enables document sharing.
  • Consider employing multiple monitors to accommodate client visibility as well as documentation requirements.
  • Ensure you are still properly documenting visits as you normally would with an in-person visit.
Medicare Rules Around Telehealth Delivery During COVID-19

Medicare pays RDN Medicare providers for covered services furnished to beneficiaries in all areas of the country in most settings.

  • Coverage and payment for telehealth is no longer limited to rural areas during this public health emergency.
  • Temporary rules allow RDNs to provide MNT and other Medicare Part B covered services via telehealth to patients in expanded settings. The clients/patients can use temporarily approved communications technologies from their homes
  • RDN Medicare providers who shift their practice location to their home do not need to update their Medicare enrollment file to include their homes as the place of service. They can continue to bill from their currently enrolled location.
  • Temporary rules allow RDNs to provide the following services using the telephone (audio-only technology) for services rendered as of March 1, 2020, when audio and video are not possible: MNT (97802, 97803, 97804, G0270), DSMT (G0108, G0109), and IBT for obesity services (G0447). As a reminder, RDNs are not recognized billing providers by Medicare for IBT.
  • Medicare will temporarily reimburse RDNs for providing telephone assessment and management services (98966-98968) with new or established patients, after at least seven days following an MNT visit. These codes are not to be used when providing MNT. Examples of use:
    • 98966 (5-10 minutes): A 67-year-old female with diabetes requested assistance in how to incorporate a new food product into her meal plan established 3 weeks ago with the Registered Dietitian Nutritionist (RDN).
    • 98967 (11-20 minutes):A 68-year-old male with insulin dependent diabetes, called the Registered Dietitian Nutritionist (RDN) with a complaint of several mid-morning low blood sugar readings following the implementation of his 30-minute, new exercise regimen.
  • CMS is temporarily offering expedited enrollment for new Medicare providers to receive temporary billing privileges. RDNs can call the toll-free hotline for the Medicare Administrative Contractor that services their geographic area and enroll over the phone. They will be notified of their approval or rejection during the phone conversation.
  • The temporary changes (CMS waivers) and the CARES Act allow Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to temporarily act as distant site providers for Medicare telehealth services. This means that RDNs who work in FQHCs can provide MNT to patients of their own health centers, and patients can be in their homes. Providers can deliver services from their home if they are working from home on behalf of the health center. CMS still needs to issue further guidance around how they will be implementing these changes.
  • Services are not limited to patients with COVID-19.
  • For suppliers and beneficiaries enrolled in a Medicare Diabetes Prevention Program (MDPP) as of March 1, 2020, CMS is making the following temporary changes to MDPP:
    • The limit to the number of virtual make-up sessions is waived.
    • MDPP beneficiaries may receive a maximum of one regular session per day and a maximum of one virtual make-up session per week during the core session period. Beneficiaries may receive one make-up session on the same day as a regularly scheduled session.
    • Virtual make-up sessions may only be furnished to achieve attendance goals and may not be furnished to achieve weight-loss goals.
    • An MDPP supplier may offer to an MDPP beneficiary no more than:
      • 16 virtual make-up session offered weekly during the core session period
      • 6 virtual make-up sessions offered monthly during the core maintenance session interval periods
      • 12 virtual make-up sessions offered monthly during the ongoing maintenance session interval periods
    • MDPP beneficiaries who were receiving services as of March 1, 2020 and whose sessions were paused or cancelled during the public health emergency are permitted to obtain the set of MDPP services more than once per lifetime.
    • Virtual services must be furnished in a manner that is consistent with the CDC Diabetes Prevention Recognition Program (DPRP) standards for virtual sessions, follow the CDC-approved DPP curriculum requirements, and be provided upon the individual MDPP beneficiary's request.
    • The requirement for in-person attendance at the first core service remains in effect.
Coding, Billing and Payment for MNT and DSMT When Delivered via Telehealth During COVID-19
  • MNT provided via telehealth is still MNT. The CPT® codes used to submit claims to Medicare (most private payers and Medicaid) for in-person visits are the same codes used for telehealth: 97802, 97803, 97804, G0270. Find more information about CPT® and G codes for RDNs.
  • CMS1500 Claims: During the COVID-19 emergency you do not need to use Place of Service code 02 - Telehealth when submitting claims to Medicare. Continue to use the same Place of Service code you would use if the service had been provided in-person. Modifier 95 should be applied to claim lines that describe services furnished via telehealth, regardless of whether the MNT or DSMT was provide using approved audio-visual technology or audio-only communication (telephone).
  • Outpatient (hospital) – UB-04 Form: On April 30, 2020 CMS announced that MNT and DSMT can be provided in the hospital outpatient setting (Provider-Based Departments) remotely to a patient in their home, effective for services rendered March 1, 2020. Services should be billed the same as if they were provided in-person. Patients must be registered as hospital outpatients. RDNs can seek further direction from and collaborate with compliance/regulatory and billing staff at their hospitals. For more information read the CMS Guidance.
  • Get clarification from private payers and state Medicaid programs for how to submit claims for MNT provided via telehealth.
    • Place of service code, if other than (02), and/or
    • Use of any modifiers. For example, modifier 95 describes synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system.
  • Rural Health Centers (RHCs): When RDNs in RHCs provide MNT via telehealth to Medicare beneficiaries, the RHC will be paid $92.03 for the telehealth interaction. The All-Inclusive Rate (AIR) will be paid, but these claims will automatically be reprocessed in July with the new payment rate.
    • Use the HCPCS code G2025 with modifier “CG” on the claim for services furnished via telehealth through June 30, 2020. After July 1, 2020, the CG modifier does not need to be used.
    • The home became an eligible originating site on March 6, 2020.
    • For more information read the CMS guidance.
    • Confirm policies for Medicaid and private payers.
  • Federally Qualified Health Centers (FQHCs): When RDNs in FQHCs provide MNT via telehealth to Medicare beneficiaries, the FQHC will be paid$92.03 for the telehealth interaction. The Prospective Payment System (PPS) rate will be paid, but these claims will automatically be reprocessed in July with the new payment rate
    • Claims should include the following information:
      • Provide the respective PPS specific payment system codes (GO466, G0467), and
      • The HCPCS/CPT code that describes the services furnished via telehealth (e.g., MNT; 97802, 97803, G0270, or DSMT G0108) with modifier 95; and
      • HCPCS G2025 with modifier 95
    • Beginning July 1, 2020, FQHCs will only be required to submit G2025 where modifier 95 may be appended but is not required.
    • The home became an eligible originating site on March 6, 2020
    • For more information read the CMS guidance.
    • Confirm policies for Medicaid and private payers.
  • Medicare will temporarily reimburse RDNs for providing telephonic assessment and management services (98966-98968). CMS is temporarily relaxing enforcement of the restriction of use of these codes to established patients. As a reminder, the assessment and management codes are not to be used when providing MNT. Rather, they should be used for telephone interactions initiated by patients, families and caregivers more than 7 days following an MNT visit to address questions that arise between visits. Check with other payers regarding coverage for these codes. Examples of use:
    • 98966 (5-10 minutes): A 67-year-old female with diabetes requested assistance in how to incorporate a new food product into her meal plan established 3 weeks ago with the Registered Dietitian Nutritionist (RDN).
    • 98967 (11-20 minutes): A 68-year-old male with insulin dependent diabetes, called the Registered Dietitian Nutritionist (RDN) with a complaint of several mid-morning low blood sugar readings following the implementation of his 30-minute, new exercise regimen.
  • There are new online digital assessment and management services codes (98970, 98971, 98972) for which RDNs may be reimbursed by private payers for electronic communication with established patients. For more in-depth information, read the November 2019 issue of the MNT Provider In the Medicare Physician Fee Schedule CY21 Final Rule, CMS noted RDNs are not eligible to bill for these codes for Medicare patients. Examples of use with non-Medicare patients:
    • 98970 A 70-year-old male with insulin dependent diabetes submits an online query through his registered dietitian nutritionist’s (RDN) EHR portal reporting nausea and vomiting due to the flu and seeking guidance on diabetes self-management.
    • 98971 A 65-year-old male with congestive heart failure submits an online query through HIPAA-compliant encrypted email to his RDN regarding a recent 7-lb weight gain.
    • 98972 A 40-year-old female with newly diagnosed type 2 diabetes submits an online query through her registered dietitian nutritionist’s EHR portal after noticing her morning fasting blood glucose levels were gradually increasing.
  • Medicare pays for MNT provided via telehealth at the same rate as in-person visits. See the Medicare physician fee schedule for more information. The Coronavirus Aid, Relief and Economic Security (CARES) Act increases payments to RDNs and other Medicare providers by two percent by temporarily suspending sequestration. Clarify rates with private payers and Medicaid as they may or may not pay for telehealth services at the same rate as an in-person encounter.
  • Certified providers of accredited Diabetes Self-Management and Training programs can provide DSMT and submit claims to Medicare using codes G0108 and G0109. Services can be provided by any provider type under the accredited and recognized DSMT program (RDNs, RNs, pharmacists, etc.). Programs contracted with private payers and Medicaid programs should seek clarification regarding telehealth policies.
  • RDNs providing MNT to Medicare Advantage (Medicare Part C) enrollees should contact Medicare Part C plans directly as CMS has issued guidance allowing these plans to provide enrollees access to Medicare Part B services via telehealth in any geographic area and from a variety of places, including beneficiaries' homes.
  • Private/commercial payers:
    • Current telehealth policy information may be accessed through provider portals.
    • If you are out of network with a client/patient's health insurance company or other provider network, do not assume that temporary telehealth policies apply.
    • The America's Health Insurance Plans website provides broad summaries of private payer policies in response to COVID-19.
    • The Blue Cross Blue Shield Association website has an interactive map to connect with state franchise policies in response to COVID-19.
    • Sample policies from major national payers. Note: Benefits and coverage for MNT and DSMT when delivered via telehealth may vary from these national policies based on the client/patient’s specific health plan.
  • The Center for Connected Health Policy website provides a quick glance at state telehealth actions in response to COVID-19 with links to further information.

    • Key questions to ask private payers and Medicaid about billing for services provided via telehealth (Make sure to contact provider services and not customer service):

    • Is the fee schedule for MNT delivered using telehealth the same as in-person visits?
    • What place of service code should I use?
    • Is a modifier required? If so, which modifier?
    • What communications technologies are allowed?
    • Can services be provided telephonically? (e.g., if client does not have access to technology or internet).
Additional Telehealth Resources

  • Medicare Telehealth Services and Registered Dietitians

    The Medicare Part B program allows several services provided by RDNs and nutrition professionals to be offered via telehealth. When providing these services via telehealth, all of the CMS requirements for such services still must be met.

  • Practicing Telehealth

    Practice tips and resources for RDNs interested in telehealth, including information about telehealth and ethics.

  • Telehealth and Payment

    Information and resources about HIPAA, Medicaid, Medicare and payment topics as they relate to telehealth.

  • Telehealth Practice Survey 2015 Summary

    The Telehealth Practice Survey provided valuable insight into current knowledge and service delivery for nutrition and health practice. It also helped identify needs that will be used to inform Academy strategies on both the education and advocacy fronts.

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