Telehealth 2025: The Final Rule
- By Terry Fletcher
- In Billing
- November 8, 2024
- 27 Comments
Medicare reinstates certain pre-pandemic telehealth policies.
COVID-19 public health emergency waivers that applied to Medicare Part B policies for telehealth services ended May of 2023, and an extension of those waivers, granted in the Consolidated Appropriations Act, 2023, ends Dec. 31, 2024. With that date rapidly approaching, the healthcare industry has been anxiously waiting for word from the Centers for Medicare & Medicaid Services (CMS) on the future of telehealth. That time has come.
CMS issued the calendar year 2025 Physician Fee Schedule (PFS) final rule on Nov. 1, 2024, answering the many questions circling in stakeholders’ heads. Absent Congressional action, this is the final word for telehealth services effective Jan. 1, 2025.
Telehealth in 2025
At this juncture, I’ll start with the highlights of telehealth policy changes in the 2025 PFS final rule:
- CMS acknowledges the CPT® Editorial Panel’s decision to delete audio-only telephone services CPT® codes 99441-99443 for 2025. However, Medicare will not recognize 16 of the 17 telehealth CPT® codes (98000-98016) added for 2025; CPT® codes 98000-98015 will have an I Invalid status. Medicare will only pay separately for brief virtual check-in encounter CPT® code 98016 in lieu of HCPCS Level II code G2012, which CMS is deleting due to redundancy.
- Direct supervision through real-time audio and visual interactive telecommunications (not audio-only) will continue to be allowed on qualifying services.
- Certain behavioral and mental health services will be permanently offered under telehealth for Medicare patients beginning Jan. 1, 2025. A link to CMS’s List of Telehealth Services is in the Resources section, which you should reference (once the list is updated).
- Place of service (POS) codes will continue to have two telehealth designations:
- 02 Patient not in their home when telehealth services are rendered; or
- 10 Patient in their home when telehealth services are rendered. POS 10 will continue to be paid at the non-facility rate.
- CMS will continue to allow physicians to list their practice address, rather than their home address, when performing Medicare services via telehealth from their home.
- Pre-pandemic geographic and location restrictions for telehealth (before March 1, 2020) are being reinstated. This means that unless a Medicare patient lives or is located in a health professional shortage area, a rural census track, or a county outside of the metropolitan statistical area at the time of service they will not be covered for telehealth services.
- Teaching physicians may continue to have a virtual presence in all teaching settings, but only for Medicare telehealth services and just through Dec. 31, 2025.
Authoritative references are provided in the Resources section to allow you to source the information yourself.
Congress Could Change Everything
We still have until the end of 2024 for Congress to fix the geographical location issue for telehealth. But time is of the essence, or more than 85 percent of Medicare patients’ telehealth encounters occurring after Jan. 1, 2025, could be invalid for payment.
The Telehealth Modernization Act 2024 is still sitting in Committee as of Sept. 18, 2024. Until Congress moves on this, medical practices and Medicare patients are in limbo as to where telehealth services will be covered in 2025. I urge you to contact your local representative to draw attention to this matter.
Resources
https://www.congress.gov/bill/117th-congress/house-bill/2617/text
https://aspr.hhs.gov/legal/PHE/Pages/covid19-11Jan23.aspx
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Could you share your knowledge on TCM visits via Telehealth in 2025? Thank you!
Look for an article in AAPC the Magazine — coming soon!
Can Medicare Participating Providers accept cash payment for a telehealth office visit if the patient desires the service and consents to payment? Or do the MPP rules forbid this?
Should I assume that, for non Medicaid and Medicare clients who have insurance through their employer, Telehealth will no longer be covered unless Congress extends the federal Telehealth mandate for 2025? In other words, most insurance companies will decide NOT to continue it despite it being popular for members?
If audio only services are made permanent for mental health related visits, but the 99441-99443 code set is being deleted and CMS is not adopting 16 of the 17 new codes (98000-98015) than what CPT codes should be utilized for audio only mental health related E&M visits after 1/1/25 when billing for Medicare B client visits?
Can you tell me if modifiers are required for 2025 telehealth services?
The type of modality used (live video or audio-only) is indicated by affixing a modifier on the CPT code when filling out the
CMS 1500:
• GQ (not used unless you are in an Alaska or Hawaii telehealth demonstration project): asynchronous telehealth
service.
• GT: Critical Access Hospital distant site providers billing under CAH Optional Method II.
• FQ: A Medicare telehealth service was furnished using real-time audio-only communication technology
• 93: Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only
telecommunications system.
• 95: Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications
system.
Other modifiers that may be used when billing for telehealth:
•G0 (zero): Used to identify telehealth services furnished for purposes of diagnosis, evaluation, or treatment of
symptoms of an acute stroke.
•GY: Notice of Liability Not Issued, Not Required Under Payer Policy. Used to report that an Advanced Beneficiary
Notice (ABN) was not issued because item or service is statutorily excluded or does not meet definition of any
Medicare benefit. (Note: only to be used when the patient is not at an eligible originating site.)
• FR: Supervising practitioner present through two-way, audio and video communication.
No, I would not assume that. Payers will likely cover telehealth services as they did before the pandemic, but you will need to check policies and state laws carefully.
Use the applicable codes on the Medicare telehealth services code list. https://www.cms.gov/medicare/coverage/telehealth/list-services
Does this apply to FFS Medicare or ALL insurance plans (commercial, etc)?
Hope you can assist me to understand this more clearly. I am in a small pediatric/well womans clinic and have seen some updates in regards how to bill audio only telemed 99212-5 with mod 95 vs 99441-3 vs now 98012-5. As I am new in my billing position any assistance would be greatly appreciated to help me understand this better. Thank you!
What code we should code for audio-only below 10min for New patient? As 98016 is for established patient. Also can we bill 96127 with these new audio-only telem CPTs?
You will have to check each payer’s policy. I read that UHC is adopting Medicare’s policy.
UHC is not allowing the use of modifier 93 on 992XX codes. They only allow modifier 93 on codes in appendix T. It’s also unclear if Medicare is allowing audio-only for anything other than ESRD and behavioral health. Or can we assume that the flexible use of modifier 93 is good to go until March?
For synchronous audio-only visit for evaluation and management of a new patient, see 98008, 98009, 98010, 98011. A CPT 2025 note says, “Do not report 98016 in conjunction with 98000-98015.” There are no NCCI edits for 98016.
Yes, private payers don’t always mirror Medicare policy. I suggest referencing this MLN article from CMS. It’s a little out of date, but all the Consolidated Appropriations Act provisions that were set to end Dec. 31, 2024, outlined in the article, are extended through March 14, 2025, with the passage of The American Relief Act, 2025.
https://www.cms.gov/files/document/mln901705-telehealth-services.pdf
Does Medicare pay more for Video Telehealth and less for Audio only telehealth
can we use an EM code -ie-99213,99214 with 98008-98016? for audio only?
I have spent hours looking for payer policies such as Aetna, BCBS, Cigna, etc and I can’t find anything policies. Can anyone tell me how/where to locate them?
Terri, You’ll get a better response if you post your question in our forums, but here are a few links:
https://www.aetna.com/health-care-professionals/newsletters-news/provider-newsletters-archive.html
https://www.uhcprovider.com/en/resource-library/provider-portal-resources.html
https://www.cigna.com/health-care-providers/coverage-and-claims/policies/
Shyam, please see our latest article Telehealth: Medicare Policy for CY 2025.
CPT guidelines state “When the patient-initiated check-in leads to an E/M service on the same calendar date, and when time is used to select the level of that E/M service, the time from 98016 may be added to the time of the E/M service for total time on the date of the encounter.”
This guidance should help you: https://telehealth.hhs.gov/providers/billing-and-reimbursement/billing-and-coding-medicare-fee-for-service-claims
This article may help you https://www.webpt.com/blog/times-a-medicare-patient-cant-pay-cash
I have been tried in many insurance with the New Televst Code for the new patient as well as Established patients, but Aetna, Molina, Emblem, etc all are denied the new Televst code, so can you please guide me, shall I continue with the old one or can wait for the new update like Place of sevice or Modifier.
Any assistance would be greatly appreciated to help me understand this better
Thank you!
Please post your question in our forums. Include the specific code you are having trouble with; what remittance codes you are getting on denials, etc. The more info the better.
The COVID-19 telehealth waivers for Medicare Part B are ending soon, on December 31, 2025. Healthcare providers and patients are eagerly waiting for CMS to announce the future rules and guidance for continuing telehealth services.