Medicare telehealth coverage for neurology visits, including cognitive assessments, is extended through December 2027. The practices that benefit most have built the staffing model to match, not just the technology.
Key Takeaways
- The Consolidated Appropriations Act of 2026 extended most Medicare telehealth flexibilities through December 31, 2027, giving neurology practices a two-year window to build permanent operational models rather than provisional ones.
- CPT codes 96132-96139 for neurocognitive test administration and interpretation, and 99483 for cognitive care planning, are covered under Medicare telehealth – a significant access tool for cognitive neurology practices serving patients with mobility limitations.
- Telehealth visits for established neurology patients bill at the same E/M codes as in-person visits and are eligible for G2211 when the ongoing care relationship is documented – the coding rules do not change based on delivery modality.
- Staffing the telehealth model correctly means assigning the right visit types to the right clinician level, building the rooming and pre-visit workflow, and monitoring the audio-visual documentation requirements that distinguish telehealth claims from in-person claims on audit.
Neurology was already a strong candidate for telehealth before 2020, and the pandemic-era waivers confirmed it. A large share of neurology follow-up visits – stable epilepsy patients on established medication regimens, Parkinson’s patients between in-person appointments, migraine management follow-ups – can be conducted by video without meaningful clinical compromise. For cognitive neurology practices serving elderly patients with mobility limitations or serving large geographic catchment areas, telehealth is not a convenience feature. It is the access model.
The Consolidated Appropriations Act of 2026, signed into law in late 2025, extended most Medicare telehealth flexibilities through December 31, 2027. That two-year extension is long enough to build a permanent operational model rather than a provisional one. Practices that have been running telehealth on temporary infrastructure – workaround scheduling, informal billing processes, staff handling video setup without a defined protocol – should use the extension window to institutionalize what is working and fix what is not, rather than assume another extension will arrive before the rules contract.
What the extension does not change is the requirement that telehealth visits be documented in ways that distinguish them from in-person visits on a medical record review. The place-of-service code must be correct, the modality must be documented, and for audio-only visits – which remain covered for patients who cannot use video – the inability to use video must be recorded in the note. These are not filing details; they are audit criteria. A practice running 400 telehealth visits per month with inconsistent place-of-service coding or missing modality documentation has a systematic audit exposure that compounds with volume.
Cognitive Assessment Telehealth Coverage
Among the most clinically significant telehealth coverage decisions for neurology is the inclusion of neurocognitive testing codes on the Medicare telehealth list. CPT codes 96132 and 96133 – neurocognitive testing administration, physician or other qualified health care professional, and additional hours – are covered via telehealth, as are 96136 through 96139, which cover the same testing when administered by a technician. CPT 99483, the cognitive care planning code that covers a complex care plan visit for a patient with cognitive impairment, is also on the telehealth-eligible list.
For a cognitive neurology practice, this coverage has real implications. Patients with early-stage dementia and their caregivers can complete cognitive assessment and care planning visits without transportation, which for many families is the binding constraint on whether the appointment happens at all. The clinical information obtained via a structured video visit using standardized tools is comparable to in-person administration for most screening purposes – and the coding for the service does not change based on modality. The documentation must establish the clinical rationale, the specific tests administered, the caregiver or informant who participated, and the clinical interpretation. That documentation framework should be built into the template before the first telehealth cognitive assessment is billed.
G2211 on Telehealth Visits
Add-on code G2211 is not excluded from telehealth visits. If the encounter meets the criteria – an ongoing care relationship with a patient whose condition involves inherent longitudinal complexity – G2211 is billable on a telehealth E/M the same way it would be on an in-person visit. This is a coding point that many neurology billing departments have not incorporated because G2211 was introduced and expanded in an environment where billing staff were already managing new telehealth modifiers and rules simultaneously. An audit of your telehealth claims for G2211 capture alongside an audit of your in-person claims will almost certainly show a wider gap on the telehealth side.
The documentation logic is the same: the note must reflect the ongoing care relationship and the longitudinal complexity of the patient’s condition, not merely that a telehealth visit occurred. A note that is structurally identical to a routine follow-up note with a telehealth modality appended does not support G2211 any better than it does in person. The note template for telehealth visits should be built with the same G2211-supporting language as the in-person template.
The telehealth extension through 2027 is two years to build a real operational model. Practices that treat it as another reprieve rather than a runway will find themselves rebuilding under deadline pressure again in 2028.
The Staffing Model Behind the Telehealth Schedule
Telehealth does not reduce the staffing required to run a visit – it relocates where parts of the work happen. A well-functioning telehealth operation assigns each visit type to the right clinician tier, builds the pre-visit workflow, and defines who handles what before, during, and after the video encounter.
For established follow-up patients with stable chronic conditions – the natural fit for APP-managed telehealth – the model requires a clear attribution policy: which patients are seen by the APP independently, which require a co-signature under general supervision, and which need a warm hand-off to the physician during the visit because clinical complexity exceeds the APP’s scope. Documenting that policy and training to it consistently is what keeps the billing defensible. Incident-to billing on telehealth visits requires the same supervision standard as in-person incident-to – the supervising physician must be available and accessible during the visit – and that requirement must be built into the scheduling structure, not managed informally.
The pre-visit workflow matters more in telehealth because the patient is not physically in your office where a medical assistant can catch a problem before the physician enters. A standardized pre-visit protocol – medication review, symptom checklist, technology check, and collection of the structured information the physician needs for the E/M level determination – should run before every telehealth encounter. Practices that skip it have physicians spending the first five minutes of each visit on information a medical assistant could have collected beforehand.
Payer Mix and Telehealth Reimbursement in Practice
Medicare’s telehealth rates are straightforward: in 2025 and 2026, telehealth visits are paid at the same rates as in-person visits under the physician fee schedule. Commercial payer parity is a different matter. Many commercial plans have telehealth coverage that varies by plan design and state, and some have reverted to pre-pandemic rate structures or added prior authorization requirements for telehealth visits that did not exist during the flexibilities period. A neurology practice running a high telehealth volume should audit its commercial payer telehealth policies annually – specifically, the rate paid, the place-of-service code requirements, and whether audio-only is covered at all for each plan – because the coverage assumptions from 2022 may not match the 2026 policy.
Build a payer-by-payer telehealth reimbursement matrix and update it at contract renewal. Include the rate paid for key telehealth E/M codes, audio-only coverage, cognitive assessment code coverage, and G2211 acceptance via telehealth. The practices that discover a payer has not been paying telehealth at parity for eighteen months find out on a billing audit, not from a remittance. The practices that built the monitoring process find out in February when the payer changes the policy and they catch it on the quarterly review.
From the Field
A two-neurologist cognitive neurology practice in the Mountain West built its telehealth program during the pandemic flexibilities and never formalized it. Sixty percent of visits had moved to video, but the scheduling system still classified all visits as “office visit” because nobody had updated the visit type configuration, the place-of-service codes on claims were inconsistently applied, and G2211 was not captured on any telehealth claim. A billing audit flagged a systematic place-of-service error affecting the prior 14 months of telehealth visits, and two commercial payers had been applying in-person rates to telehealth claims that had the wrong code – in one direction overpayment, in the other underpayment. Our fractional CFO engagement rebuilt the visit type configuration in the scheduling system, corrected the place-of-service coding going forward, conducted a payer-by-payer telehealth rate audit for the trailing period, and filed a voluntary corrective submission with the one payer where the in-office code had triggered overpayment. On the underpayment payers, the billing coordinator submitted corrected claims within the timely-filing window and recovered a meaningful amount. G2211 was added to the telehealth template. The practice now runs a quarterly telehealth billing review as a standing item on the billing coordinator’s calendar.
Consulting Versus Fractional Execution
A telehealth billing consultant can audit your place-of-service coding, identify the payer matrix gaps, and write the corrected billing policy. If your billing coordinator can rebuild the visit type configuration, implement the quarterly review, and manage the commercial payer policy monitoring, consulting is the right scope, and it will be more economical than a fractional engagement. We will say so when that is the answer.
The pattern we see most often in telehealth engagements is that the billing problem was identified months or years ago, a memo was written, and nothing changed because the billing coordinator had no guidance on how to reconfigure the scheduling system, no one ran the payer matrix audit, and the quarterly review was never assigned to anyone. That is an execution problem, not an information problem. A fractional executive does the analysis and then sits with your billing coordinator to rebuild the configuration, runs the first quarterly review alongside them, and confirms the process is running before stepping back. Ask any firm presenting as fractional whether they will be inside your scheduling system with your staff or delivering a policy document and leaving implementation to you. The label is unregulated. The work it describes is not.
Sources
- CMS, Consolidated Appropriations Act 2026 – Telehealth Extension Through December 2027 — https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule
- CMS, HCPCS G2211 Frequently Asked Questions — https://www.cms.gov/files/document/hcpcs-g2211-faq.pdf
- CMS, Calendar Year 2026 Medicare Physician Fee Schedule Final Rule — https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule
- MGMA, 2025 Provider Compensation and Productivity Data Report — https://www.mgma.com/2025-provider-compensation
More in the Neurology Series
- The Economics of an E/M-Heavy Neurology Practice After the Office Visit Changes — how E/M coding changes and the G2211 add-on code reshape neurology office visit revenue.
- Neurology Infusion Suite Economics and the Buy-and-Bill Risk Equation — how to evaluate infusion suite economics before you sign a drug purchasing agreement.
- In-Office Neurodiagnostics: EEG, EMG, and the Business Case for Doing Them Right — how to run an in-office neurodiagnostic program that survives a payer audit.
- Neurology Access and Referral Management: What Long Wait Times Are Actually Costing You — the operational and financial cost of long neurology wait times and how to move the number.