While the Center for Connected Health Policy (CCHP) has long tracked federal and state-level telehealth policies for Medicare and Medicaid, as well as state telehealth private payer laws through our Policy Finder, we have not historically examined private payer reimbursement policies for individual payers. This is due in part to the fact that private payer telehealth coverage policies are often treated as proprietary. Many insurers provide only high-level, publicly available summaries of their telehealth coverage, or simply promote their own direct-to-consumer telehealth application option, offering little insight into the specific services covered or the conditions for reimbursement for individual providers. Additionally, private payer telehealth policies can be highly variable and complex. Coverage may differ not only by insurance company but also by the state in which the plan operates and the type of plan (e.g., fully insured commercial plans versus self-funded employer plans). Because of this variability and lack of transparency, tracking these policies in a standardized format has historically been challenging.
However, in recent months, we have come across several detailed private payer telehealth reimbursement policies available online. Based on this publicly available information, we can now provide a high-level overview of the reimbursement policies of 4 private insurers—UnitedHealthcare (UHC), Aetna, Blue Cross Blue Shield of North Dakota (BCBSND), and Blue Cross Blue Shield of Illinois (BCBSIL). The intent of this review is to identify commonalities and differences across payers, highlight unique features, and provide insight into the evolving landscape of private payer telehealth coverage. Note that these insurers were selected based on the availability and clarity of their telehealth policy information at the time of this writing. While other health plans—such as Blue Shield of California—also had telehealth policies available, we limited our analysis to the four found with the most comprehensive and readily accessible information for this write-up.
Note that health plan policies are subject to change, and there is no guarantee that the policies described here remain current. Readers are strongly encouraged to consult directly with each payer for the most up-to-date information and to review the original source material for further detail. This summary should not substitute for payer-specific guidance.
UnitedHealthcare (UHC)
UnitedHealthcare applies its Telehealth/Virtual Health Policy across all commercial and individual exchange benefit plans. The policy uses the terms "telehealth" and "telemedicine" interchangeably and includes a broader category called "Virtual Health," which encompasses synchronous (real-time audio and video), asynchronous (e.g., store-and-forward), and Remote Physiologic Monitoring (RPM). Reimbursement is based on a combination of guidelines from the Centers for Medicare and Medicaid Services, American Medical Association CPT coding rules, and additional services identified by UHC as eligible.
For reimbursement, providers must use place of service (POS) codes 02 or 10, which distinguish between services delivered outside the patient’s home and those provided at home, respectively. While UnitedHealthcare (UHC) accepts modifiers such as 95, GT, GQ, and G0 for informational purposes, they are not required for reimbursement—except for modifier 93, which is necessary for audio-only visits.
UHC defines the originating site as the location where the patient is located during the telehealth encounter, typically with a telepresenter. However, later in the policy, UHC also recognizes the patient’s home, even without a telepresenter, as a valid originating site. Claims for the originating site facility fee (code Q3014) can be submitted for CMS-recognized originating sites (as listed on page 2 of UHC’s Telehealth Reimbursement Policy), though this fee is not reimbursed when POS 10 is reported, indicating the patient is at home.
UHC aligns with CMS in allowing the same types of distant site providers to be reimbursed for telehealth delivered services (see the CMS list of eligible providers in their regulations defining a ‘practitioner’), and goes even further by also recognizing therapy providers (physical therapists, occupational therapists and speech therapists) as eligible. All therapy telehealth visits must be conducted via live, interactive video with real-time audio and visual communication.
Additionally, UHC reimburses for audio-only telehealth and a range of communication technology-based services (CTBS), including electronic visits, virtual check-ins, interprofessional consultations (via phone, internet, or EHR), and remote physiologic monitoring (RPM). Because CTBS and RPM services are never provided in person, they should not be billed with POS 02 or 10, nor with telehealth modifiers such as 95, GT, GQ, or G0.
In regard to the new evaluation and management (E/M) codes 98000-98015 for telehealth visits, UHC indicates in its Replacement Codes Policy that these codes will not be reimbursed consistent with CMS guidance and that instead existing telehealth eligible codes should be used (E/M visit codes 99202-99205, 99211-99215 appended with POS 02 or 10 to identify them as telehealth).
Additionally, the end of the UHC Telehealth Reimbursement Policy includes links to eligible codes that United Healthcare will reimburse, including different lists for the following:
Aetna
Aetna’s Telemedicine and Direct Patient Contact Payment Policy applies to both commercial and Medicare Advantage plans and offers clear distinctions among telehealth modalities, including synchronous video, audio-only services, and asynchronous telecommunications. Their reimbursement policy is based on CMS guidance and CPT/HCPCS code sets, with Aetna providing additional criteria and coding methodologies when appropriate.
The policy includes specific lists of eligible CPT/HCPCS codes and the required modifiers, such as:
- GT – Interactive audio and video telecommunications system
- 95 – Synchronous telemedicine via real-time interactive audio and video
- FR – Supervising practitioner present via two-way audio/video
- 93 – Real-time interactive audio-only telemedicine
- FQ – Service delivered using audio-only communication
- GQ – Asynchronous telecommunications system
The Aetna Telemedicine Policy specifies that the code lists provided in the document do not necessarily apply to fully insured commercial plans, which are subject to individual state telehealth coverage parity mandates. Additionally, for Medicare Advantage members, Aetna defers to the CMS list of reimbursable telemedicine services. Services not included on that list and lacking direct in-person patient contact are considered incidental and not eligible for payment. The policy specifies that transmission and telehealth facility fees—such as Q3014 and T1014—are not reimbursable. These charges are considered incidental to the evaluation and management of the patient. They also specify that tele-stroke services are reimbursable when billed with the G0 modifier. However, Aetna explicitly excludes other services, including care plan oversight (unless a case management exception is granted by Patient Management), concierge or boutique medicine, and missed appointments.
Finally, Aetna includes a list of eligible remote patient monitoring (RPM) codes, even though the policy document primarily focuses on telemedicine services that require direct patient contact (as indicated in the document’s title – “Telemedicine and Direct Patient Contact”). The policy does not reference other communication technology-based service (CTBS) codes, such as virtual check-ins or electronic visits. It is unclear whether reimbursement is available for these services under separate guidance; however, they are not addressed in this policy, likely because they do not involve direct patient interaction.
Blue Cross Blue Shield of North Dakota (BCBSND)
Blue Cross Blue Shield of North Dakota (BCBSND)’s Telehealth Services Policy defines "telehealth" broadly to include telemedicine, remote patient monitoring, store-and-forward, mobile health, and virtual check-ins. The plan follows CMS and North Dakota state regulations, as well as CPT and HCPCS coding standards. BCBSND provides separate reimbursement in several scenarios: when a patient is located at an originating site such as a clinic or facility; when a provider delivers services from a distant site to an eligible originating site; and when a patient receives telehealth services at home using consumer devices or platforms like mobile health apps, kiosks, or web-based video accessed through an electronic health record (EHR) portal.
Providers may use modifier 95 to indicate audio-visual telehealth services and modifier 93 for audio-only visits. Claims must include the appropriate place of service (POS) code—POS 02 for services provided outside the patient’s home and POS 10 for services provided in the home. Effective January 1, 2025, modifier 95 is no longer required, but POS 02 or 10 must still be reported with the appropriate telehealth evaluation and management (E/M) codes, or the claim will be denied.
Beginning January 1, 2025, BCBSND started recognizing new E/M telehealth codes recently adopted by the American Medical Association (AMA), including codes 98000–98015 which differentiate between audio-visual and audio-only visits. These must also be billed with POS 02 or 10. For Online Digital E-visits (CPT codes 98970–98972, 99421–99423) and Brief Virtual Check-Ins (98016, 98966–98968, G2010, G2012, G2251, G2252), separate payment is permitted only if the service is provided with POS 10, was not initiated from a related E/M service within the prior seven days, and does not result in a related service within the next 24 hours or the soonest available appointment.
BCBSND applies strict bundling rules to these services. If a provider bills multiple Online Digital Visits, Virtual Check-Ins, or E/M services within seven days without appending modifier 25, only the first claim submitted will be reimbursed. Subsequent claims without the modifier will be denied as unbundled. Providers are advised to review BCBSND’s Telehealth Medical Policy for additional guidance and requirements, including a lists of allowable codes and those not allowed with POS 02 or 10. In addition, a separate Remote Patient Monitoring Policy (RPM) outlines the specific criteria and reimbursement conditions for RPM services.
Blue Cross Blue Shield of Illinois (BCBSIL)
Blue Cross Blue Shield of Illinois (BCBSIL) applies its Telehealth Policy to all commercial plans; however, if a conflict arises between this policy and any member’s plan document, the plan document takes precedence. BCBSIL uses the terms telehealth and “telemedicine” interchangeably within its policy. The broader term “virtual health care” is used to describe a range of services delivered through communication technologies.
To qualify for reimbursement, providers must maintain complete and accurate documentation of the virtual encounter, including start and end times, the method of communication used, and compliance with all applicable privacy laws. Providers must also hold the appropriate licensure to treat members in the state where the patient resides. Covered service types include synchronous audio-video E/M services (for new and established patients), synchronous audio-only E/M services (for new and established patients), and brief synchronous communication technology services (e.g., virtual check-ins) for established patients. BCBSIL does not reimburse for asynchronous telecommunications services billed with modifier GQ. Acceptable telehealth modifiers include FQ, FR, G0, GT, 93, and 95, which must be appended to the appropriate CPT or HCPCS code along with the applicable place of service (POS) code, unless a telemedicine-specific procedure code is used. In certain cases, BCBSIL will reimburse the Q3014 facility fee when telehealth services are provided at a primary care office. Providers are expected to use communication technologies that align with the type of service being delivered and must comply with state and federal laws, including HIPAA regulations. The U.S. Department of Health and Human Services’ Office for Civil Rights provides guidance on acceptable HIPAA-compliant technologies.
Effective January 1, 2025, BCBSIL adopted the new telemedicine evaluation and management (E/M) codes developed by the AMA (98000–98015), similar to BCBSND. Unless otherwise stated in the code descriptor, these services are reported based on the level of medical decision-making (MDM) or the total time spent on the date of the encounter. They may not be billed on the same calendar day as another E/M service unless all components and time are aggregated into one reported service. If the minimum time for a telemedicine service is not met, that time may be applied to an in-person E/M visit occurring on the same date in a separate encounter. These telemedicine codes should not be used to report routine communications related to a previous visit unless a new follow-up E/M service is rendered.
If an audio-video connection is lost during a telehealth visit and only audio communication remains, the provider should report the service that accounted for the majority of the encounter duration. For audio-only services, the provider must exceed ten minutes of medical discussion or observation to bill the service.
Common Threads and Key Differences
Across all four payers reviewed—UnitedHealthcare (UHC), Aetna, Blue Cross Blue Shield of North Dakota (BCBSND), and Blue Cross Blue Shield of Illinois (BCBSIL)—several common elements emerge in their telehealth policies. All cover core services such as evaluation and management (E/M), behavioral health, and routine or urgent primary care visits. Remote patient monitoring (RPM), virtual check-ins, and e-visits are also widely recognized (with a few exceptions), though the depth of coverage and billing requirements vary. Each payer requires that telehealth services be delivered via HIPAA-compliant platforms, with proper documentation. Providers are expected to report place of service (POS) codes 02 (telehealth provided outside the home) and 10 (telehealth provided in the home), and all four insurers allow audio-only services when billed with the appropriate modifier—typically Modifier 93 or FQ—though coverage is sometimes limited to specific CPT/HCPCS codes. Importantly, all four payers either include a list of eligible telehealth codes within their policies or reference a separate document that outlines the codes they consider reimbursable via telehealth.
Despite these shared foundations, significant differences arise in how asynchronous services, audio-only visits, and originating site facility fees are treated. Asynchronous telehealth presents a clear point of divergence. UHC allows reimbursement for asynchronous services when billed using Communication Technology-Based Services (CTBS) codes. Aetna specifies the use of Modifier GQ for store-and-forward telehealth, although none of the eligible codes in its telehealth policy are explicitly paired with GQ. BCBSND permits the use of Modifier 93, which it defines as applicable to either audio-only or asynchronous services. BCBSIL recognizes asynchronous care through specific e-visit and virtual check-in codes but does not reimburse for Modifier GQ submissions.
The originating site facility fee (Q3014) is another area where policies diverge. UHC reimburses this fee when the patient is located at a CMS-designated originating site but does not allow it when POS 10 is used (indicating the patient is at home). Aetna does not reimburse the originating site fee at all. In contrast, BCBSND explicitly lists Q3014 as reimbursable, and BCBSIL allows the fee when the patient is physically present at a primary care provider’s office. Other distinctions include how payers manage modifier use and coding compliance. UHC is notably flexible, accepting common modifiers such as 95, GT, GQ, and G0 for informational purposes but requiring only Modifier 93 for reimbursement of audio-only services. Aetna and BCBSIL both require specific modifiers for reimbursement and include detailed rules for documentation and coding. On the other hand, at the beginning of 2025 BCBSND transitioned away from the Modifier 95 requirement.
A notable development is the adoption of the newly created AMA telehealth E/M codes (98000–98015) by at least two of the four private payers reviewed: BCBSND, and BCBSIL. Meanwhile, as noted by UHC’s policy, Medicare has opted not to incorporate these codes into its 2025 reimbursement structure (with the exception of 98016 for a virtual check-in). This discrepancy in adoption of the new codes by private payers has additionally appeared across Medicaid programs, showcasing that coding policies similarly differ across both public and private payers. Additionally, because the 98000–98015 codes do not have direct in-person equivalents, they may fall outside the scope of state-level private payer parity laws, which often apply only to services that would otherwise be covered in-person. For instance, we have seen some Medicaid programs attach lower rates to these codes, while others have preserved parity with their adoption.
This observation also highlights a broader policy gap: while coverage and reimbursement parity are often a central consideration in telehealth policy, none of the reviewed commercial payer documents explicitly mention parity requirements, with the exception of Aetna, which makes a specific note that its eligible code list does not apply to fully insured commercial plans, which are governed by individual state telehealth coverage mandates. Additionally, the preface to the document notes that coverage may be mandated by applicable legal requirements of a State, the Federal government or CMS. In practice, this means Aetna may reimburse for a service in one state but not in another, depending on whether a state law requires parity in coverage or reimbursement. For example, Oregon mandates that private payers cover any telehealth service that would be covered in person—provided it can be delivered safely and effectively—at the same reimbursement rate as in-person care. This requirement would apply to these plans when operating in Oregon even if the specific service code is not included on the payer’s official list of eligible telehealth codes. Therefore, while parity requirements are not mentioned explicitly in these private payer documents, this observation signals that even more variation is possible in application of private payer policies.
Coverage exclusions also help distinguish these plans. Aetna explicitly excludes concierge or boutique medicine, care plan oversight (except in special cases), and missed appointment charges—categories that the other payers do not directly address. BCBSIL, meanwhile, employs a more enforcement-driven policy structure, including strict documentation protocols, claims editing logic, and adherence to 2025 AMA E/M coding updates.
In sum, while private payers share a foundation of telehealth coverage and general billing requirements, their approaches differ in key areas like asynchronous service reimbursement, audio-only allowances, eligible codes, and originating site fees. These differences highlight the importance for providers, billing staff, and other stakeholders to carefully review each payer’s telehealth policies and avoid assuming consistency across commercial plans (or any payer, for that matter).
Find the original resource at : https://www.cchpca.org/resources/telehealth-coverage-policies-across-select-private-payers/
Telehealth Coverage Across Select Private Payers:
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