Phone and messaging virtual care visits count as billable telehealth services under most U.S. payers, but the rules differ sharply from video visits. A phone call (audio-only) is generally covered when it replaces an in-person visit, while a messaging encounter (secure text or patient portal message) is only reimbursed if it meets specific criteria for a “brief check-in” or a “virtual check-in,” not for ongoing treatment. This article explains exactly which phone and messaging interactions qualify, how to document them, and what to watch for.
Background: How Telehealth Coverage Evolved
Before 2020, Medicare and most private insurers paid for telehealth only when it included live video, and only from approved locations. The COVID-19 public health emergency forced a rapid expansion: audio-only phone calls and secure messaging were suddenly allowed, often at the same rate as video visits. Many of those flexibilities were made permanent for Medicare in 2022 and 2023, but private insurers vary widely. Today, the key question is not whether phone or messaging “counts,” but whether the specific service you provide matches a defined Current Procedural Terminology (CPT) code.
Phone (Audio-Only) Visits: What Counts
Audio-only visits count when they meet the same medical necessity as an in-person visit and the patient cannot or prefers not to use video. Medicare now permanently covers audio-only telephone visits for behavioral health, and many commercial plans cover them for any condition. The two main codes are:
- CPT 99441-99443 – telephone evaluation and management (E/M) for new or established patients, 5-30 minutes. These are time-based and require a full history, exam (limited to what can be done by phone), and medical decision-making.
- CPT 98966-98968 – telephone assessment by a non-physician qualified health care professional (e.g., nurse practitioner, therapist).
What does not count as a phone visit: a call to schedule an appointment, refill a prescription, report a test result, or answer a simple question. Those are administrative or incidental services, not billable E/M visits. Also, a call that lasts under 5 minutes does not qualify for the codes above; it may qualify as a virtual check-in (see below).
Messaging (Secure Text/Portal) Encounters: What Counts
Messaging counts only when it involves a patient-initiated, documented evaluation that requires medical decision-making. The two recognized codes are:
- CPT 98970-98972 – online digital E/M service by a physician or qualified health professional, 5+ minutes of time. This is for new or established patients, and the service must be initiated by the patient (not the provider).
- CPT G2010 – brief virtual check-in (Medicare-specific) – a 5-10 minute communication via phone or secure messaging to decide whether an office visit is needed. This is not a full E/M service.
Simple messages like “Your lab results are normal” or “Please take this medication twice daily” do not count, because they are not an evaluation. Similarly, a message that says “I have a cough, what should I do?” followed by a one-line answer is usually not billable unless you document the medical decision-making involved. Many practices find that most portal messages do not meet the threshold, and they instead absorb them as patient communication.
How to Choose: Video vs. Phone vs. Messaging
Choose the modality based on clinical need and patient access, not convenience alone. Video is the default for most payers and is the only option that consistently covers all services. Phone is appropriate when video is not available or the patient prefers audio. Messaging is appropriate only for brief, non-urgent follow-up or triage. A practical rule:
- If you need to make a new diagnosis or change treatment, use video or phone (audio-only E/M).
- If the patient has a simple question about a symptom, use a virtual check-in (G2010) or online E/M (98970) if you document time and decision-making.
- If the message is purely informational (results, reminders), do not bill – it is part of the global service.
Common Problems and Misconceptions
Misconception: “Any phone call counts as a visit.” Not true. A 3-minute call to say “your prescription is ready” is not billable. A 10-minute call that involves reviewing symptoms, adjusting medication, and documenting a plan is billable as 99442 (if you are a physician) or G2010 (if it is a check-in).
Misconception: “Messaging is never billable.” It is billable, but only when it meets the criteria above. Many practices avoid billing for messaging because the burden of documentation is high relative to the reimbursement, and because patients may not expect a bill for a portal message. But the codes exist.
Common problem: Not documenting time accurately. For phone and online E/M codes, time is a key component. You must document the total time spent on the encounter (including reviewing records, calling back, and documenting). If you do not record time, the claim may be denied.
Costs and Reimbursement Differences
Reimbursement for audio-only phone visits is typically lower than for video visits. For example, Medicare pays about 75% of the video rate for 99441-99443. Messaging codes (98970-98972) are paid at a rate similar to a level 2 or 3 visit, but they require 5+ minutes of documented time. G2010 is a flat fee, usually around $14-20, which is less than a full visit. Private insurers vary; some pay the same for phone and video, others do not cover phone at all. Always check the specific payer contract.
Safety and Documentation Essentials
Accurate documentation protects both the patient and the provider. For any billable phone or messaging visit, document:
- Patient consent to receive services via that modality (can be verbal, noted in the chart).
- The reason for the encounter and that it was patient-initiated (for messaging) or that video was not available (for phone).
- The time spent (for time-based codes).
- The history, exam (limited to what is possible), and medical decision-making.
- The plan and follow-up instructions.
Do not bill for phone or messaging if you cannot meet the documentation standards. Incorrect billing can lead to audits and recoupment. If you are unsure, consult your compliance officer or billing specialist.
Frequently Asked Questions
Does a patient portal message count as a virtual visit? Only if it involves a documented evaluation with medical decision-making and meets the time threshold (5+ minutes) for codes 98970-98972. A simple question-and-answer exchange does not count.
Can I bill for a phone call that is less than 5 minutes? No, not as a full E/M visit. You may use G2010 (virtual check-in) for 5-10 minutes, but if it is under 5 minutes, it is not separately billable under Medicare.
Is audio-only phone coverage permanent? Medicare has made audio-only permanent for behavioral health, but for other conditions it is temporary and depends on the public health emergency waivers. Check current CMS guidance and your private payer policies.
What is the difference between a virtual check-in and a telehealth visit? A virtual check-in (G2010) is a brief 5-10 minute communication to decide if an office visit is needed. A telehealth visit is a full E/M service, typically 10+ minutes, and can be audio-only or video.
Do I need to document why we used phone instead of video? Yes, for Medicare and most payers, you should note that the patient did not have video capability or preferred audio, to justify the audio-only service.
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