Important Changes to Telehealth Coding for 2025: What You Need to Know From CMS
Healthcare providers continue to adapt to evolving telehealth regulations, and 2025 significantly changes how these services are coded and billed. While Congress has extended key Medicare telehealth flexibilities through March 31, 2025, CMS has announced important updates to telemedicine reporting requirements that healthcare providers need to understand.
American Relief Act of 2025
Changes to Medicare Telehealth Policies
Congress recently passed the American Relief Act of 2025, extending key Medicare telehealth policies through March 31, 2025. Highlights include:
- Removal of geographic restrictions and expanded originating sites
- Broadened telehealth eligibility for practitioners
- Continued telehealth services for FQHCs and RHCs
- Delayed in-person requirements for mental health services
- Acute Care Hospital at Home program
These changes provide continuance of telemedicine reporting options for 2025, ensuring continued access to remote care while Congress deliberates long-term policy.
CMS Telemedicine Reporting Updates
CMS will not adopt the new CPT telemedicine codes (98000–98015). Instead, telemedicine visits should be reported using in-person E/M codes (e.g., 99202–99215) with:
- Modifier 95 for audio-video visits
- Place of service codes 02 (non-home location) or 10 (telehealth in home)
For audio-only services, CMS expects audio-visual technology unless the patient lacks video capability or declines video use. In such cases, append Modifier 93 for telephone-only visits, and document the exception.
Key points:
- Codes follow E/M guidelines, with service level based on medical decision-making or time spent.
- For audio-only visits, medical discussions must exceed 10 minutes, with duration documented.
- Add-on code +99417 can be used for prolonged service time.
- Code 98016 replaces G2012 for brief virtual check-ins (5–10 minutes).
- Code 98016 applies to patient-initiated virtual check-ins unrelated to recent or upcoming E/M services.
- Real-time, interactive patient-provider encounters are required.
- Codes cannot be used for routine communications (e.g., sharing lab results).
- Services must occur on a separate calendar date from other E/M services unless combined for a single code.
New CPT Telemedicine Codes for Commercial Payers
The new CPT codes include 17 telemedicine options covering audio-visual and audio-only E/M visits, plus virtual check-ins.
| Synchronous audio-video | Synchronous audio-only | |
| New Patient | 98000 – straightforward MDM or 15 minutes | 98008 – straightforward MDM or 15 minutes |
| 98001 – low MDM or 30 minutes | 98009– low MDM or 30 minutes | |
| 98002 – moderate MDM or 45 minutes | 98010– moderate MDM or 45 minutes | |
| 98003 – high MDM or 60 minutes | 98011 – high MDM or 60 minutes | |
| +99417 – for services 75+ minutes | +99417 – for services 75+ minutes | |
| Established Patient | 98004 – straightforward MDM or 15 minutes | 98012 – straightforward MDM or 15 minutes |
| 98005– low MDM or 30 minutes | 98013– low MDM or 30 minutes | |
| 98006 – moderate MDM or 45 minutes | 98014– moderate MDM or 45 minutes | |
| 98007 – high MDM or 60 minutes | 98015 – high MDM or 60 minutes | |
| +99417 – for services 75+ minutes | +99417 – for services 75+ minutes |
The telehealth landscape continues to evolve, and staying compliant with these new requirements is crucial for healthcare providers. Our team remains committed to helping you navigate these changes successfully. For specific questions about implementing these new coding requirements, please contact our specialists today.