When Telehealth Cannot Be Billed (and Why)

Telehealth has become a core part of general practice — but it is also one of the most misunderstood and incorrectly billed areas of Medicare. Many compliance issues don’t come from intentional misuse, but from assumptions that if a consult happened, it must be billable.

That isn’t always the case.

Below are the key situations where telehealth cannot be billed under Medicare, and why those restrictions exist.

1. No Established Clinical Relationship (where required)

Telehealth items require an existing clinical relationship between the patient and the GP or practice. If this requirement is not met, the service is not eligible for Medicare billing, even if the consultation was clinically appropriate.

Why this exists: Medicare intends telehealth to support continuity of care — not replace episodic or transactional medicine where no ongoing responsibility is held.

2. Administrative or Non-Clinical Calls

Telehealth items require the delivery of a clinically relevant service. Calls that are purely administrative are not billable, including:

• Obtaining consent only

• Booking or rescheduling appointments

• Explaining fees or processes

• Chasing results without clinical discussion

Why this exists: Medicare only funds professional attendances, not administrative workload — even though that workload is real and time-consuming.

3. When the Same Service Is Already Billed Another Way

Telehealth cannot be billed if the service is already covered by another item for the same patient, same provider, and same timeframe.

This includes:

• Billing telehealth and in-person for the same attendance

• Billing telehealth when the service is bundled into another item

• Billing multiple attendances when the care was continuous

Why this exists: Medicare does not pay twice for the same clinical service.

4. Internal MDT or Case Coordination Without a Patient Attendance

Discussions between clinicians, even when they relate to patient care, are not telehealth attendances unless a specific case conferencing item applies and all criteria are met.

Examples:

• GP discussing a patient with a nurse or allied health provider

• Internal planning meetings

• Reviewing care plans without the patient present

• 
  

Why this exists: Telehealth items are for direct patient care, not background clinical coordination.

5. Telehealth Used Solely to Enable Another Service

If the telehealth call exists only to:

• Confirm consent for another service

• Prepare documentation for later billing

Why this exists: Medicare requires that each billed item independently meets service and documentation criteria.

6. Inadequate Documentation

Even if a telehealth service was clinically appropriate, it cannot be defended if the notes do not clearly demonstrate:

• Mode of consultation (phone or video)

• Time spent (where relevant)

• Clinical assessment and decision-making

• Management or follow-up

Why this exists: In Medicare compliance, if it isn’t documented, it didn’t happen.

The Key Principle to Remember

Telehealth billing is not about whether you helped the patient. It is about whether the service:

✔ Meets item descriptor requirements

✔ Is clinically relevant

✔ Is appropriately documented

✔ Is not excluded by Medicare rules

Many telehealth services are good medicine but non-billable medicine — and that distinction matters.