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By Vilmar Trinta Negrón | Interviewed Lillybeth Rivera García
Telemedicine has emerged as an essential tool for improving access to healthcare, especially in a context where distance and lack of access to traditional health services represent significant barriers. Although in Puerto Rico, telehealth has gained prominence in recent years, becoming an innovative modality for healthcare providers, there is still a need to expand services.
- A new study on the adoption of health information technology, prepared by the Medicaid Office and conducted by Bridgewater Group, revealed that only 37% of doctors on the island are part of organizations that offer telehealth services, and only 3.7% of those who do not provide it have plans to implement it within the next twelve months. Certainly, many private medical practices and hospitals continue to face challenges related to costs and technological infrastructure, limiting the expansion of tools like telehealth.
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Telemedicine and Telehealth in Puerto Rico are legally based on Law No. 168 of August 1, 2018, as amended, known as the “Law for the Use of Telemedicine in Puerto Rico.” Any healthcare professional wishing to offer their services through Telehealth and Telemedicine must obtain certification from the Office of Regulation and Certification of Health Professionals (ORCPS) and the Medical Licensing and Discipline Board (JLDM) of the Department of Health.
According to the Department of Health, telemedicine has demonstrated a significant impact on healthcare by facilitating medical services and promoting the continuous training of healthcare professionals. Some of the benefits mentioned by the agency on its website include: protecting providers and patients, reducing costs, increasing access to medical care, shortening patient wait times, providing data for decision-making, and improving efficiency and outcomes.
- With new trends, billing regulations, and Medicare policies, providers must adapt to a series of challenges and opportunities that could transform the healthcare landscape on the island.
One of the new trends is the expansion of online specialties. Today, telemedicine consultations are not limited to primary care; specialists in various fields such as psychiatry, dermatology, cardiology, and endocrinology also offer services through digital platforms. Likewise, telemedicine is increasingly integrating with wearable devices, such as blood pressure monitors, glucose meters, and electrocardiogram (ECG) devices, allowing doctors to obtain real-time data on a patient’s health status. This facilitates more accurate diagnoses and continuous monitoring of chronic conditions.
Telemedicine platforms are evolving into more interactive solutions, where patients can have consultations that closely resemble in-person interactions. These platforms not only allow video conferences but also the exchange of images, tests, and other relevant documents for care.
On the other hand, Medicare has introduced significant changes in telemedicine service coverage in recent years, and Puerto Rico is no exception.
According to Lillybeth Rivera García, Coding and Premium Management Director at Provider Network Solutions, on November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) published the Final Rule for the 2025 Medicare Physician Fee Schedule (MPFS). The MPFS finalized the telemedicine rules that took effect on January 1, 2025.
“It is important to note that the MPFS applies to Medicare Parts A and B. Differences for Part C, Medicare Advantage, will be highlighted as applicable. CMS acknowledged the decision of the Current Procedural Terminology (CPT®) Editorial Panel to eliminate CPT® codes 99441-99443 for audio-only telephone services in 2025. However, Medicare will not recognize 16 of the 17 new telemedicine CPT® codes (98000-98016) added for 2025. CPT® codes 98000-98015 will have an invalid status,” explained Rivera García.
She added that Medicare will only pay separately for CPT® code 98016, used for brief virtual encounters, instead of HCPCS Level II code G2012, which CMS will eliminate due to redundancy.
During the COVID-19 public health emergency, restrictions were relaxed, allowing beneficiaries to receive telehealth services from home. However, starting April 1, 2025, Medicare will require most telehealth services to be conducted in offices or medical centers located in rural areas, according to information published on medicare.gov. Nonetheless, certain services, such as monthly visits for home dialysis and emergency stroke care, will remain available regardless of patient location. 
The law regulating telemedicine in Puerto Rico establishes that consultations conducted under these modalities may be considered for reimbursement by Medicare, Medicaid, and other insurance plans, provided they meet the definitions and criteria established by the Centers for Medicare & Medicaid Services. 
Additionally, Medicare Advantage plans in Puerto Rico may offer additional telehealth benefits that are not available under Original Medicare.
Rivera García emphasized to doctors that most Medicare Advantage plans have decided to report telemedicine under the following scenarios:
- Audio-only calls: The corresponding evaluation and management codes (CPT® 99202-99205 for initial visits or 99212-99215 for follow-up visits) should be used along with modifier 93, which indicates that it is an audio-only call.
- Audio-video calls: The corresponding evaluation and management codes (CPT® 99202-99205 for initial visits or 99212-99215 for follow-up visits) should be used along with modifier 95, which indicates an audio-video call.
“For Medicare Advantage physicians, these codes are highly important, as individual calls allow for effective documentation of post-hospital discharge visits, as well as follow-up visits after emergency room consultations, positively impacting HEDIS measures. Likewise, audio calls play a key role in directly influencing the risk factor model, contributing to compliance with standards and strategic objectives in healthcare management”, the director pointed out.
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