Telehealth in Home Health
Telehealth in home health is the use of telecommunications technology, including real-time audio-video and audio-only interactions, to deliver services under a Medicare home health plan of care. Medicare permits telehealth as a supplement when it is ordered on the plan of care, but telecommunications encounters cannot substitute for ordered in-person visits and do not count as visits for payment purposes.
What Medicare actually allows
Since the CARES Act of 2020, home health agencies may provide services via telecommunications technology as long as the use is on the plan of care, is tied to patient-specific needs, and does not replace in-person visits ordered by the certifying practitioner. That framing is precise: telehealth is a documented adjunct, not an alternate visit type. A video check-in between skilled nursing visits to reinforce teaching or monitor a wound is permitted and reportable. Cutting an ordered three-visit week to two visits plus a video call is not, unless the practitioner changes the order and the plan of care reflects the new frequency.
How telehealth is reported on claims
CMS created three G-codes for reporting telecommunications technology on home health claims. Reporting was voluntary starting January 1, 2023 and became mandatory on claims from July 1, 2023:
- G0320: services furnished via synchronous audio-video telecommunications
- G0321: services furnished via synchronous audio-only telecommunications (telephone)
- G0322: collection of physiologic data digitally stored or transmitted by the patient, meaning remote patient monitoring
These lines carry no separate payment. CMS uses them to understand how telecommunications are used across episodes, and agencies should expect the data to inform future policy.
The payment reality
Telehealth encounters do not count toward the LUPA (Low Utilization Payment Adjustment) visit threshold, do not generate per-visit payment, and do not change the 30-day period payment. That creates a real operational tension: replacing in-person visits with telehealth near the LUPA threshold can convert a full period payment into per-visit payments. Agencies should treat telehealth as a clinical quality and efficiency tool, useful for monitoring, teaching reinforcement, and triage between visits, while keeping the ordered in-person visit pattern intact. Any frequency change belongs on the plan of care through a physician order, not in an informal substitution.
Where telehealth works well in practice
The strongest use cases sit between visits rather than in place of them. Video wound checks between weekly in-person wound care visits catch deterioration early. Audio-only calls after a medication change confirm tolerance and adherence. Virtual attendance by a specialist or wound-care-certified nurse during another clinician's in-person visit extends scarce expertise across a large territory. Telehealth also supports triage: a video assessment of a reported symptom can determine whether a PRN visit or physician contact is needed the same day. Document every telecommunications encounter, its plan-of-care basis, and the clinical response, both for compliance and to support the mandatory G-code reporting.
Frequently asked questions
Can a telehealth visit count toward the LUPA threshold?
No. Only in-person visits count toward the LUPA threshold and per-visit payment. A telecommunications encounter, whether audio-video or audio-only, never counts as a visit for Medicare home health payment purposes.
Does telehealth use need to be on the plan of care?
Yes. Medicare requires that any services furnished via telecommunications technology be included on the plan of care, tied to patient-specific needs, and incapable of substituting for ordered in-person visits. Undocumented or off-plan telehealth creates compliance exposure.
Is telehealth reporting on home health claims optional?
No. Reporting with G0320, G0321, and G0322 became mandatory on home health claims effective July 1, 2023, whenever telecommunications technology is used as part of the episode. The codes are informational and carry no separate payment.