Telehealth E-Visit Codes 99421–99423: What's Reimbursable in 2026

1. What CPT codes 99421, 99422, and 99423 actually are

These three codes cover what CMS officially calls "online digital evaluation and management services" — commonly called e-visits. They are not the same as a live video or phone telehealth appointment. The 99421–99423 series indicates that the provider delivers E/M services via a digital platform, and unlike a synchronous audio-video or audio-only visit, the service is asynchronous: the provider receives a message via the portal from an established patient and responds based on their availability.

The official CMS definitions for each code level are straightforward and time-based. According to CMS: 99421 covers online digital evaluation and management for an established patient, cumulative time during 7 days, of 5–10 minutes; 99422 covers the same service for 11–20 minutes; and 99423 covers 21 or more minutes of cumulative time during those 7 days.

A critical point for patients reviewing bills: e-visits run on a seven-day clock, and the codes count cumulative provider time across that entire window — not just a single message. That means a provider is supposed to add up all the time spent reading your messages, reviewing your records, drafting responses, and doing related clinical work over the full week before selecting which code to bill.

Also important: digital evaluation and management services are not classified as telehealth services, so providers should not apply POS 02 or modifier 95 to these codes. If you see those telehealth place-of-service codes or modifiers attached to a 99421–99423 claim, that is a red flag for a billing error that may cause a denial — or result in your being billed incorrectly for a higher cost-share amount. For a deeper look at how misapplied billing codes inflate what you owe, see our post on what upcoding is and how hospitals inflate your bill.

2. Who can bill these codes — and who cannot

Not every clinician who responds to your patient portal message is entitled to bill 99421–99423. In all types of locations and geographic areas, established Medicare patients may have non-face-to-face patient-initiated communications with their doctors using online patient portals. These services can only be reported when the billing practice has an established relationship with the patient, the patient must generate the initial inquiry, communications can occur over a 7-day period, and the services may be billed using CPT codes 99421–99423.

According to the Federal Register, "99421–99423 are for practitioners who can independently bill E/M services," while CPT codes 98970–98972 are for practitioners who cannot independently bill E/M services. In practical terms, a physician, nurse practitioner, or physician assistant may bill 99421–99423, but a nurse or medical assistant responding to your portal message on their own cannot.

There is also a hard rule against billing these codes for new patients. CMS states that these e-visit services apply specifically to established Medicare patients. If you have never seen this provider before and a 99421–99423 code appears on your bill, that is a billing error worth disputing. Similarly, a provider cannot bill an e-visit if the exchange rolls into a billable in-person or live telehealth visit within seven days, and the patient must initiate the exchange.

3. The 2026 regulatory landscape: what's extended, what's permanent

Two major regulatory events in late 2025 and early 2026 govern telehealth billing today. First, on October 31, 2025, CMS issued the Calendar Year 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F), effective January 1, 2026, which introduces a series of payment and program updates, including revisions to telehealth policies that affect physicians, health systems, and digital health companies delivering virtual care.

Second, on February 3, 2026, the Consolidated Appropriations Act, 2026 (H.R. 7148) was signed into law, extending most Medicare telehealth flexibilities through December 31, 2027. According to the AMA, the legislation renewed the telehealth coverage that many older adults have relied on since the start of the COVID-19 pandemic.

Under the current framework, Medicare patients can receive telehealth services for non-behavioral/mental health care in their home through December 31, 2027, and there are no geographic restrictions for the originating site for Medicare non-behavioral/mental telehealth services through that date. One notable permanent change from the CY 2026 PFS Final Rule: CMS permanently removed the application of telehealth frequency limits on subsequent inpatient and nursing facility visits and critical care.

CMS also finalized a policy to move all "provisional" telehealth services — including developmental, psychological, and neuropsychological testing services — to the permanent Medicare Telehealth Services List. This matters for patients because services no longer listed as "provisional" are more secure from year-to-year coverage changes.

4. The Medicare/commercial payer split — and why it matters on your bill

The most significant billing complexity in 2026 is the divergence between Medicare and commercial payer code acceptance. The AMA introduced a dedicated telehealth E/M code series (98000–98016) in 2025, but CMS determined these codes are duplicative of existing E/M codes with modifiers and declined to reimburse most of them under Medicare. That means if a provider bills the new 98000-series codes to Medicare, the claim will be denied.

For Medicare fee-for-service claims, practices should continue billing standard office E/M codes (99202–99215) with the appropriate place-of-service code and modifier. CMS has assigned the 98000–98015 codes a status indicator of "I" — not valid for Medicare purposes — meaning they will trigger denials if submitted to Medicare. Many commercial payers and some state Medicaid programs do accept the 98000–98015 series, creating a dual-track billing system.

For e-visits specifically, codes 99421–99423 remain active and valid under both Medicare and most commercial payers in 2026. E-visits (99421–99423) cover patient-portal messages over a seven-day window. These codes stayed active, and confusion arises because some assume the new 98000 series replaced them — it didn't.

For live video telehealth visits (not e-visits), place-of-service codes do matter. The distinction between POS 02 (Telehealth Provided Other Than in Patient's Home) and POS 10 (Telehealth Provided in Patient's Home) directly affects reimbursement rates. CMS pays the nonfacility rate for POS 10 claims, which is typically higher than the facility rate applied to POS 02 claims. A wrong POS code doesn't just affect what the provider gets paid — it can affect your cost-sharing if your plan applies different cost-share tiers to facility vs. nonfacility services. Check your Explanation of Benefits carefully. For help reading an EOB, see our guide on Medicare Summary Notices vs. commercial EOBs.

5. Common billing errors to look for on your telehealth bill

E-visit codes generate a specific set of errors that patients can actually spot on an itemized bill. The table below summarizes the most common patterns and how to identify each one.

If you spot any of these patterns, your first step is to request an itemized bill if you don't already have one. Every line item should show the CPT code, the date of service, and the name of the rendering provider. You can cross-reference whether an e-visit and a live visit appear on the same date — that's a clear rule violation. For a broader guide on how adjustments and credits can mask errors, see what "adjustments" on a hospital bill really mean.

6. How cost-sharing applies, and what you can dispute

E-visits are not free for Medicare patients. The Medicare coinsurance and deductible generally apply to these services. That means you'll typically owe 20% of the Medicare-approved amount for 99421–99423 after your Part B deductible, just as you would for an in-person office visit.

For commercial insurance, coverage rules vary widely by plan. Payers may cover e-visits the same as in-person visits, apply a different cost-share tier, or in some cases not cover them at all — particularly if the provider used the wrong code or wrong modifier. Billing teams should verify coverage with each contracted payer before submitting claims using these codes. The reimbursement rates assigned by CMS to these codes are notably lower than those for their in-person office visit counterparts, so even where they are accepted, rate comparison is warranted. If your EOB shows you were charged a facility-level cost-share for an e-visit, that is worth questioning — e-visits have no place-of-service designation and should not be processed like a hospital outpatient service.

If you believe you were billed for an e-visit that doesn't meet the rules above — wrong patient status, same-day as an office visit, provider-initiated contact — you have the right to dispute the charge. Start by requesting the itemized bill and the visit notes for the 7-day period in question. Your insurer's member services line can tell you how a claim was adjudicated, and your state insurance commissioner's office can help if a commercial plan is unresponsive. If you're dealing with an out-of-network dispute involving a No Surprises Act-eligible service, our post on the Federal IDR process walks through your options.

About VerifyDoc: We help patients identify errors and overcharges on medical bills. We publish guides on hospital billing, the No Surprises Act, and disputing medical charges, updated as federal and state rules change.