Coding and Payment of Communication Technology-Based Services

Communication technology-based services (CTBS) allow audiologists and speech-language pathologists (SLPs) to provide certain brief, virtual interactions that require a clinical decision through digital communication tools. These codes do not replace traditional evaluation or treatment; instead, they support clinical decision-making and patient management between visits when medically necessary.

Coverage for CTBS varies by payer—Medicare, Medicaid, and private insurers each set their own rules. Audiologists and SLPs must understand which services fall within their scope, how to code them correctly, and what documentation may be required to support their use. Here are the key things you need to know.

On this page:

• Overview
• Payer Coverage
• Coding and Compliance Guidelines
  • E-Visits (CPT codes 98970-98972)
  • Remote Evaluation of Patient Videos/Images (HCPCS code G2250)
  • Remote Therapeutic Monitoring (CPT codes 98975-98977, 98980, and 98981)
  • Virtual Check-Ins (HCPCS codes G2251 and G2252)
  • Telephone Assessment and Management (CPT codes 98966-98968)
• Billing Tips
• Resources

Overview

CTB services represent a set of brief, clinically driven interactions that allow audiologists and SLPs to support and monitor patients outside the structure of a full evaluation or treatment session. These services are designed to address patient needs in between regular visits—whether through a secure patient portal where the clinician reviews a message and provides guidance, an asynchronous review of a prerecorded video or audio sample submitted by the patient, or a short real-time communication intended to assess symptoms, offer recommendations, or determine whether a more comprehensive visit is warranted.

Although CTB services are delivered through communication technology, they are not the same as telehealth services. Unlike full telehealth sessions, CTBS interactions are typically shorter, more focused, and governed by their own distinct coding, documentation, and coverage rules. They are intended to supplement—not replace—formal diagnostic or therapeutic services.

Both audiologists and SLPs may use CTBS codes when those services fall within their professional scope and when the payer’s policies explicitly allow their use. Coverage varies widely across Medicare, Medicaid, and private insurers, making it essential for clinicians to verify code eligibility and requirements before providing CTBS.

Payer Coverage

Coverage of CTBS varies significantly across Medicare, Medicaid, and commercial insurance. Each payer determines whether the services are covered, which provider types may report them, and what documentation or billing requirements apply. Because of this variability, audiologists and SLPs must verify payer-specific coverage and guidelines before delivering CTBS services.

Medicare

Medicare has the most clearly defined, published rules for CTBS, and remains the primary payer that consistently covers these services for SLPs. However, the Centers for Medicare & Medicaid Services (CMS) confirmed that audiologists may not bill CTBS codes to Medicare. Although ASHA advocated for audiologists to have equal access to these services, CMS determined that CTBS codes fall outside the audiology diagnostic benefit category.

Medicare distinguishes CTBS from telehealth services. CTBS codes are not telehealth codes, and therefore the standard telehealth requirements (e.g., rural location, originating site rules, audiovisual criteria) do not apply. Instead, CTBS is treated like a virtual adjunct to in-person or full telehealth services.

Most CTBS codes may be billed to Medicare only for established patients and must be patient-initiated. This reflects Medicare’s intent that CTBS supplement, rather than replace, scheduled evaluations and treatments.

Medicare Guidelines for SLPs

SLPs may bill Medicare for many CTBS codes, including:

• E-visit codes (98970-98972)
• Virtual check-ins (G2251)
• Remote evaluation of recorded videos/images (G2250)
• Remote therapeutic monitoring (RTM) services (98975-98981)

Medicare requires the GN modifier for CBT services furnished under a speech-language pathology plan of care. Place of service (POS) codes should reflect the provider's physical location (e.g., office), not necessarily the patient's location.

In addition, SLPs must comply with Medicare rules regarding overlapping services. CTBS codes cannot be billed if:

• They occur within seven days of a related evaluation or treatment, or
• They prompt a scheduled evaluation or treatment service within 24 hours or the soonest available appointment.

Clinicians should consult the Medicare Fee Schedule and local Medicare administrative contractor (MAC) guidance for updates, as RTM coverage and policies continue to evolve.

Medicaid and Commercial (Private) Insurance

Medicaid programs and private insurers have considerable flexibility in determining whether and how CTBS codes are covered. Because these policies vary widely from state to state and plan to plan, clinicians should verify coverage and billing requirements with each non-Medicare payer before providing services. Some Medicaid programs and commercial plans have expanded their virtual care or telepractice benefits to include certain CTBS codes, while others may limit coverage based on diagnosis, provider type, or technology used. Given this inconsistency, it is essential to confirm payer guidelines in advance to ensure that CTBS services delivered by audiologists or SLPs are reimbursable.

Because Medicare policies often inform or influence how other payers structure their coverage, the Medicare guidance outlined here provides a useful baseline for understanding potential CTBS requirements across insurers.

Coding and Compliance Guidelines

Because Medicare has the most clearly defined and widely published rules for CTBS, the guidelines below draw primarily from Medicare policy and Current Procedural Terminology (CPT®; American Medical Association) standards.

The CPT and Healthcare Common Procedure Coding System (HCPCS) Level II codes for CTB services describe brief, technology-enabled clinical interactions. These codes do not replace comprehensive evaluation or treatment services delivered in person or via telehealth. For example, they do not substitute for full evaluation or treatment codes such as 92523 for a comprehensive speech and language assessment. CTB services are intentionally limited in scope, representing short check-ins or consultations that require clinical decision-making but fall outside the structure of a full visit.

All CTB services must be delivered using Health Insurance Portability and Accountability Act (HIPAA) compliant platforms, and they must be medically necessary—that is, they must involve clinical judgment rather than administrative tasks such as scheduling or routine reminders. Patient consent is required, and clinicians should document whether consent was provided verbally or in writing. Consent may be obtained annually and should include a discussion of any associated cost-sharing.

In many cases, CTB services must also be patient-initiated. Clinicians may inform patients that these services are available and appropriate for certain concerns, but the patient or caregiver must initiate the actual request for clinical input through the approved communication technology.

Most CTB codes apply only to established patients. CMS generally defines an established patient as someone who has received professional services within the past three years from the clinician—or another provider of the same specialty within the same group practice. Before initiating CTB services for new patients, clinicians should review state practice acts and applicable regulations, as many jurisdictions require an initial in-person or full telehealth evaluation before providing clinical recommendations or treatment.

E-Visits (CPT Codes 98970-98972)

E-visits describe brief, online assessments that are reported for cumulative time spent over the course of up to 7 days. SLPs may bill these codes to Medicare for established patients.

• 98970: Qualified nonphysician healthcare professional online digital assessment and management, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes
• 98971: Qualified nonphysician healthcare professional online assessment and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 11–20 minutes
• 98972: Qualified nonphysician qualified healthcare professional assessment and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

To correctly use 98970-98972, you should:

• Ensure the service was patient-initiated by an established patient.
• Conduct e-visits through a patient portal. Other forms of real-time or digital communications, such as e-mails outside of a portal or text messages, are not billable with these codes. CMS provides no additional guidance regarding the definition of a patient portal. Clinicians should check with their local MACs or payers directly to verify whether there is flexibility to provide these services without a patient portal.
• Store the exchange and document the medical necessity, your clinical decision-making and recommendations, and the amount of cumulative time spent providing e-visit services to each patient.
• Report an e-visit code only once per 7 consecutive days. Select the appropriate CPT code based on the cumulative time spent providing e-visit services to each patient, through a patient portal, over the course of the 7 days. Day 1 of the 7 days begins on the first date you provide an e-visit. Telephone calls do not count toward the time for e-visits.
• Review ASHA’s clinical scenarios describing examples of services that could be reported with 98970-98972.

Do not bill 98970-98972 if the e-visit:

• was not patient-initiated;
• involves a new patient;
• takes less than 5 cumulative minutes;
• is related to another evaluation or treatment service provided within the last 7 days; or
• leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

98970-98972 are not separately billable to Medicare or the patient under these circumstances because they are bundled into the associated services.

Remote Evaluation of Patient Videos/Images (HCPCS Code G2250)

HCPCS G2250 allows clinicians to bill for remote review of prerecorded images and videos from the patient. SLPs may bill these codes to Medicare for established patients.

G2250: Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment 

To correctly use G2250, you should:

• Ensure the service was patient-initiated by an established patient.
• Review prerecorded images or videos sent asynchronously by the patient. This code should not be reported for real-time review and discussion of images or video over an audiovisual platform.
• Follow-up with the patient within 24 business hours to provide clinical recommendations based on your review and interpretation of the images or videos. Follow-up does not have to be asynchronous and can be done through other modes of communication, such as an email, phone call, or patient portal.
• Store the images/videos and document medical necessity, your interpretation of the images/videos and clinical recommendations, and that follow-up occurred within the required 24 business hours.

Do not bill G2250 if the review of images or video:

• was not patient-initiated;
• involves a new patient;
• is related to another evaluation or treatment service provided within the last 7 days; or
• leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

G2250 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Remote Therapeutic Monitoring (CPT Codes 98975-98981)

The remote therapeutic monitoring (RTM) family of CPT codes allows clinicians who cannot bill for E/M services to report remote monitoring of health conditions and adherence and response to treatment during an episode of care. The data collected should inform a patient's treatment plan during an episode of care. It's important to note that there will be significant changes and additions to the code set, effective January 1, 2026, that will support shorter monitoring periods and briefer clinician–patient interactions. For more information, see Speech-Language Pathology CPT and HCPCS Code Changes for 2026.

• 98975: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment
• 98976: Remote therapeutic monitoring (e.g., therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
• 98977: Remote therapeutic monitoring (e.g., therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
• 98978: Remote therapeutic monitoring (e.g., therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor cognitive behavioral therapy, each 30 days
• 98980: Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
• 98981: Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes (listed separately in addition to code for primary procedure)

To correctly use 98975-98978, you should:

• Report these codes only for monitoring that occurs for 16 or more days. Do not report 98975-98978 for monitoring of less than 16 days.
• Ensure the device used to monitor and collect objective data is defined as a medical device by the U.S. Food and Drug Administration (FDA). Check directly with the manufacturer for a device's FDA status.
• Report the initial set-up and patient education only once per episode of care. For RTM, an episode of care begins when remote monitoring of a specific condition or treatment goal is initiated and ends when the targeted data is collected and/or treatment goals are met.
• Determine whether the device used is described by 98976 (respiratory system monitoring), 98977 (musculoskeletal system monitoring), or 98978 (cognitive behavioral therapy). 98976, 98977, and 98978 represent the cost of supplies for specific types of monitoring systems, however, they may not apply to speech-language pathology related services. Do not report these codes for other devices or systems not described here. CPT codes 98980 and 98981 may still be reported for RTM treatment management services, even if the FDA-approved monitoring device used is not listed in the CPT code set.
• Report the device supply codes only once per 30-day period (not each calendar month). These codes reflect the cost of the device and supplies, not the time the clinician spends reviewing and integrating the data collected or communicating with the patient/caregiver.
  
  • Unlike the other RTM codes, CPT code 98978 for CBT related devices has not been assigned a specific value and will be contractor priced by Medicare. Clinicians should verify coverage and billing for this code with their local Medicare contractor and other non-Medicare payers.

To correctly use 98980 and 98981, you should:

• Ensure the device used to monitor and collect objective data is defined as a medical device by the U.S. Food and Drug Administration (FDA). Check directly with the manufacturer for a device's FDA status.
• Spend time communicating directly with the patient/caregiver. These codes require at least one interactive communcation to provide clinical feedback to the patient/caregiver based on the data collected during monitoring.
• Count cumulative time spent in data review and patient/caregiver interaction in a calendar month (not each 30 days). Use these codes to count the initial and each subsequent 20-minute increment of time spent reviewing and integrating the data collected during remote monitoring to inform treatment goals; monitoring the patient’s progress and adherence to the treatment plan; and interacting with the patient/caregiver. Report the base and add-on codes together on the claim, based on total time, at the end of each calendar month. The base code (98980) may only be reported once per calendar month.

Do not report RTM services if the:

• device/system used is not FDA-approved;  
• time is related to any other services, such as a speech-language evaluation or treatment session; or 
• RTM treatment management services total less than 20 minutes in a calendar month.

Virtual Check-Ins (HCPCS Codes G2251 and G2252)

HCPCS code G2251 describes brief communications initiated by the patient to help determine whether they need to be seen for a full evaluation or treatment service. SLPs may bill G2251 to Medicare for established patients. CMS also implemented G2252, which describes extended virtual check-ins. However, G2252 may only be billed to Medicare by physicians or providers who can report E/M services. SLPs may not report G2252 under the Medicare benefit.

• G2251: Brief communication technology-based service, e.g. virtual check-in, by a qualified health care professional who cannot report evaluation and management services, provided to an established patient, not originating from a related service provided within the previous 7 days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of clinical discussion
• G2252: Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion (not billable to Medicare)

To correctly use G2251, you should:

• Ensure the service was patient-initiated by an established patient.
• Participate in real-time discussion with the patient. Unlike G2250, services reported with G2251 should be synchronous. There are various ways this can be done, including through a phone, other audiovisual technology, secure text messaging, or a patient portal.
• Store the exchange, if available, and document the medical necessity, your clinical decision-making and recommendations, and the amount of time spent participating in the virtual check-in.

Do not bill G2251 if the virtual check-in:

• was not patient-initiated;
• involves a new patient;
• takes less than 5 minutes;
• is related to another evaluation or treatment service provided within the last 7 days; or
• leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

G2251 is not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Telephone Assessment and Management (CPT Codes 98966-98968)

Report these codes for lengthier discussions to address more complex or emergent issues identified by the patient or caregiver or when the patient does not have access to other modes of communication technology, such as a patient portal. Although these codes represent lengthier interactions, they should not fully replace a face-to-face visit (whether in-person or via telepractice). Note that SLPs may not bill these services to Medicare.

• CPT 98966: Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion
• CPT 98967: Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion
• CPT 98968: Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 21-30 minutes of medical discussion

To correctly use 98966-98968, you should:

• Ensure the service was patient-initiated by an established patient.
• Determine whether other CTBS codes may better reflect your services. The telephone assessment codes should be reported when the patient has no access to other modes of communication or if the nature of the problem requires a lengthier discussion with the patient or caregiver.
• Participate in real-time, audio-only discussion with the patient and/or caregiver. This is the only set of CTBS codes that allows payment when discussion occurs with a caregiver without the patient present.
• Document the medical necessity, your clinical decision-making and recommendations, and the amount of time spent participating in the telephone assessment and management service.

Do not bill 98966-98968 if the telephone discussion:

• takes less than 5 minutes;
• involves a new patient;
• is related to another evaluation or treatment service provided within the last seven days; or
• leads to an evaluation or treatment service within the next 24 hours or at the next available appointment.

 98966-98968 are not separately billable to Medicare or the patient under these circumstances because it is bundled into the associated services.

Billing Tips

Append the modifier -GN to indicate Medicare services provided by an SLP.

CMS considers these CTBS codes as “sometimes therapy” codes. As a result, SLPs should include the GN modifier on claims for CTBS codes. To append the GN modifier, place it in the "modifier" section of the claim, on the same line as the CTBS code. 

Use the place of service (POS) code that reflects the location of the billing provider.

When entering a POS code on a claim to describe where services occurred, clinicians should use the code that reflects where you provided the service, not where the patient received the service. If a clinician provides the service from their own home, enter the POS code to reflect where you normally would have provided the service.  For example, if a clinician would have provided the service from their private practice, enter POS 11 for “office”. Do not enter POS 12 for the patient’s home or the clinician's home.

Medicare Part B (outpatient) pays for these services through the Medicare Physician Fee Schedule (MPFS).

See ASHA's analysis of the MPFS for national payment rates for CTBS codes. Actual rates will vary slightly depending on your locality. CTBS codes are subject to Medicare’s 20% coinsurance payment from the patient. The MPFS does not deduct this amount, so the actual payment by Medicare is 20% less than outlined in the fee schedule. You must make reasonable efforts to collect the 20% coinsurance from the Medicare beneficiary.

Resources

ASHA provides the information on this page based on published guidance in the CPT codebook and from CMS. Contact your local MAC or non-Medicare payer for specific information and guidance related to implementation and payment for communication technology-based services.

Contact reimbursement@asha.org for additional information. ASHA also provides information on payment and coverage of telepractice services for audiologists and SLPs.