
Medical Billing & Coding Alert
The 2025 CPT update introduces new telemedicine codes to address evolving healthcare needs, including mental health services, remote patient monitoring, and audio-only telehealth visits. Seventeen new CPT codes (98008–98015) have been created for audio-visual and audio-only consultations for both new and established patients, reflecting changes in medical decision-making and time-based reporting.
However, CMS has opted not to recognize 16 of these codes, maintaining the use of existing E/M codes for telehealth services. As telemedicine policies vary across commercial insurers, Medicare Advantage, and Medicaid, providers must stay updated with individual payer guidelines to ensure compliance and accurate reimbursement.
Key Updates to Telemedicine Codes for 2025
Effective January 1, 2025, significant changes to telemedicine coding will impact provider billing and reimbursement. CPT codes 99441–99443 for audio-only telehealth services have been discontinued and replaced with new codes reflecting updated reporting standards. Additionally, modifiers 93 and 95—previously required to indicate whether services were delivered via audio-only or audio-visual technology—are no longer necessary except for Medicare claims. The revised code descriptors now specify the method of service delivery, streamlining the coding process and reducing the administrative burden for healthcare providers.
Extended Telehealth Flexibilities Through March 2025
To ensure continued access to virtual care, Congress has extended key telehealth provisions through March 31, 2025. These extensions allow patients and providers to benefit from expanded telehealth services across different healthcare settings.
One of the most significant updates is the removal of geographic restrictions, allowing patients to receive telehealth services regardless of their location. Additionally, the expansion of originating sites means more facilities can offer virtual care. The policy also broadens provider eligibility, enabling a wider range of healthcare professionals to deliver telehealth services and increasing accessibility for patients.
Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can continue providing telehealth services, ensuring that individuals in rural and underserved areas maintain access to essential care. Furthermore, Medicare’s in-person visit requirement for mental health services delivered via telehealth has been postponed, allowing patients to receive virtual mental health support without the burden of an initial physical appointment.
Audio-only telehealth services will also remain an option, catering to patients who may not have access to video-enabled devices. Lastly, telehealth can still be used for face-to-face encounters required for recertification, providing greater flexibility for both providers and patients.
These extensions reflect the growing reliance on telemedicine and may influence future decisions on making certain telehealth policies permanent beyond 2025.
New Audio-Visual Telemedicine Codes
Effective January 1, 2025, healthcare providers will have new audio-video telemedicine codes for both new and established patients. These codes define evaluation and management (E/M) visits based on the complexity of medical decision-making (MDM) and the time spent on the encounter.
Audio-Video Telemedicine for New Patients
- 98000 – Straightforward MDM, 15+ minutes - Synchronous audio-video visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision-making. When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded.
- 98001 – Low MDM, 30+ minutes - Synchronous audio-video visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and low medical decision-making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.
- 98002 – Moderate MDM, 45+ minutes - Synchronous audio-video visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and moderate medical decision-making. When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded.
- 98003 – High MDM, 60+ minutes - Synchronous audio-video visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and high medical decision-making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded.
Notes:
- (For services 75 minutes or longer, use prolonged services code 99417)
Audio-Video Telemedicine for Established Patients
- 98004 – Straightforward MDM, 10+ minutes - Synchronous audio-video visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and straightforward medical decision-making. When using total time on the date of the encounter for code selection, 10 minutes must be met or exceeded.
- 98005 – Low MDM, 20+ minutes - Synchronous audio-video visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and low medical decision-making. When using total time on the date of the encounter for code selection, 20 minutes must be met or exceeded.
- 98006 – Moderate MDM, 30+ minutes - Synchronous audio-video visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and moderate medical decision-making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded.
- 98007 – High MDM, 40+ minutes - Synchronous audio-video visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and high medical decision-making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.
Notes:
- (For services 55 minutes or longer, use prolonged services code 99417)
New Audio-Only Telemedicine Codes
With the discontinuation of 99441–99443, the CPT 2025 update introduces new audio-only E/M codes for telehealth visits:
Audio-Only Telemedicine for New Patients:
- 98008 – Straightforward MDM, 15+ minutes -
- 98009 – Low MDM, 30+ minutes
- 98010 – Moderate MDM, 45+ minutes
- 98011 – High MDM, 60+ minutes
Audio-Only Telemedicine for Established Patients:
- 98012 – Straightforward MDM, 10+ minutes
- 98013 – Low MDM, 20+ minutes
- 98014 – Moderate MDM, 30+ minutes
- 98015 – High MDM, 40+ minutes
These new audio-only codes replace the outdated telephone visit codes (99441–99443), ensuring greater specificity and alignment with modern telehealth services.
New Virtual Check-In Code (98016)
A new brief virtual check-in code, 98016, has been introduced to replace the existing HCPCS code G2012. This code applies when a physician or qualified healthcare provider delivers a 5–10 minute virtual check-in that is not related to a prior E/M service within the last 7 days and does not lead to a scheduled visit within the next 24 hours.
CMS and Medicare Reimbursement Challenges
While these new CPT codes mark a significant advancement in telemedicine billing, CMS has declined to recognize 16 of these codes for Medicare reimbursement—at least for now. The 2025 Proposed Medicare Physician Fee Schedule states that CMS sees no current need to cover these new E/M telemedicine codes. However, the final 2025 Medicare Physician Fee Schedule is set to be released later this year, and policy changes are still possible.
Providers should monitor payer policies closely, as commercial insurers, Medicare Advantage, and Medicaid programs may adopt different telehealth reimbursement rules.
Key Takeaways for Providers
- New CPT codes (98000–98016) for telemedicine replace outdated billing practices.
- Audio-visual and audio-only telehealth visits have separate, well-defined codes.
- 99441–99443 are discontinued, and modifiers 93 and 95 are no longer required (except for Medicare).
- Medicare has not yet approved most of the new telemedicine codes for reimbursement.
- Providers should verify payer-specific telehealth policies to ensure compliance and accurate billing.
- With these updates, 2025 marks a significant shift in telemedicine billing, aiming to simplify coding and improve provider reimbursement—though challenges with CMS and Medicare remain.
BillingFreedom Is Leading the Way in Telemedicine Billing & Coding
BillingFreedom is the go-to medical billing service for seamless telemedicine coding and reimbursement. Our team stays ahead of CPT updates, ensuring precise coding for audio-video and audio-only telehealth visits, including the latest E/M and RTM codes. We navigate complex Medicare, FQHC, and RHC policies, optimizing claims for maximum reimbursement. With a commitment to accuracy, compliance, and efficiency, we minimize denials and streamline the billing process. Whether it's remote patient monitoring or advanced telehealth documentation, BillingFreedom empowers healthcare providers with expert solutions.
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