2025 Brings New Telemedicine Codes
- By Gabriel Aponte Moberg
- In Billing
- June 2, 2025
- 4 Comments
But only one is reimbursable under Medicare.
For calendar year 2025, the American Medical Association (AMA) introduced a new set of telemedicine codes (CPT® 98000-98016) for reporting patient evaluation and management (E/M) services conducted with the use of audio-video or audio-only telecommunication. Previously, your only option for reporting audio-video services was to use the office/outpatient E/M codes with the appropriate modifier and place of service (POS) code and telephone codes 99441-99443 for audio-only services. With the addition of these new codes, the way in which you report telemedicine E/M services to some payers beginning in 2025 may have changed. Let’s make sure you know when and how to use these new codes.
Audio-Video E/M Services
CPT® codes 98000-98007 are for reporting E/M services via synchronous (real-time), interactive audio-video telecommunication technology. These codes are divided into two categories:
- E/M services for new patients (98000-98003)
- E/M services for established patients (98004-98007)
The selection of these new telemedicine E/M codes is based on either total time spent on the date of service or medical decision making (MDM). Each code specifies the required total time, such as code 98003, which requires 60 minutes or more.
When coding based on time, all face-to-face and non-face-to-face interactions personally conducted by the provider on the date of service should be considered. Activities such as reviewing tests, documenting in the electronic health record, ordering tests, and communicating with other healthcare professionals are included, whereas separately reported services, travel, and general teaching are not counted.
For prolonged services, code 99417 may be used in 15-minute increments when the total time exceeds the maximum required for the primary service. Code 99417 should only be reported with 98003 when total time reaches 75 minutes or more, and with 98007 when total time reaches 55 minutes or more.
When selecting a code based on MDM, refer to Table 1: Levels of Medical Decision Making (MDM) in CPT® 2025 Professional. The new telemedicine codes specify the required level of MDM, which ranges from straightforward complexity to high complexity.
The AMA has established additional guidelines regarding the appropriate use of these new codes. Telemedicine services:
- Must be medically appropriate as a substitute for an in-person visit.
- Cannot be used for routine follow-up communications, such as relaying laboratory results, but may be used for follow-up visits when reassessment for treatment response or complications is necessary.
- Must be performed on a separate calendar date from another E/M service. If a telemedicine service occurs on the same day as an in-person E/M service, do not report the two encounters separately. Instead, combine the MDM elements of both encounters and report the in-person E/M code.
Tip: If an audio-video connection is lost during the encounter and only audio remains available, AMA advises reporting the service based on the mode of communication used for the majority of the visit.
Audio-Only Visits
New synchronous audio-only visit codes, 98008-98015, replace deleted telephone codes 99441-99443.
These codes are divided into two categories:
- E/M services for new patients (98008-98011)
- E/M services for established patients (98012-98015)
These codes require more than 10 minutes of medical discussion, and the code level can be based on time or MDM. For medical discussion less than 10 minutes, look to 98016 (discussed below).
Tip: Per CPT® guidelines, do not use telemedicine codes for clinical staff oversight such as that for chronic care management (99437, 99491) and principal care management (99424, 99425). For asynchronous (not live or in real time) services, look to the online digital E/M codes 99421-99423 (an exception for hearing impaired patients applies).
Documentation Best Practices
To ensure proper reimbursement and compliance of the new telemedicine codes, providers should document key details. Documentation in the medical record must clearly indicate:
- Whether the patient is new or established;
- Whether patient consent was obtained;
- The telemedicine platform used;
- The locations of both the patient and provider, as well as any other individuals present during the visit;
- If time is the basis for coding, the total time spent; and
- The specific activities performed.
Tip: When using MDM, providers should include key terms such as “acute” or “chronic” when describing diagnoses, as well as any tests ordered, external note reviews, or other decision-making criteria referenced in Table 1: Levels of Medical Decision Making (MDM) in CPT® 2025 Professional.
Brief Audio-Video Services
So, when should you use new CPT® code 98016? Use 98016 for reporting a brief communication technology-based service, such as a virtual check-in, that is initiated by an established patient. This service is generally for the purposes of determining if a more extensive E/M service is needed. “Brief” is defined as 5 to 10 minutes; anything less is not billable. However, if the check-in leads to an E/M service on the same day, and time is used for E/M level selection, you may add the time spent on the virtual check-in to the time spent on the E/M service.
Tip: Do not count time setting up the appointment or arranging the connection.
Unlike the new telemedicine codes (98000-98015), Medicare does allow reimbursement for CPT® code 98016. For dates of service on or after Jan. 1, 2025, use this new code instead of deleted HCPCS Level II code G2012.
Note: The Centers for Medicare & Medicaid Services (CMS) did not recognize 98000-98015 for billing purposes in the 2025 Physician Fee Schedule final rule. Consequently, these codes have been assigned an “I” status indicator, meaning they are not valid for Medicare purposes. Medicare expects providers to be technically capable of rendering audio-video, interactive, real-time services. However, if the patient is not capable of, or does not consent to, using video technology, providers must report the service with modifier 93 in conjunction with office and outpatient E/M codes (99202–99215) for audio-only (e.g., telephone) encounters. This exception applies to patients located in their home, which requires POS 10 on the bill. These audio-only E/M services are not covered for patients in a facility or non-patient-home setting (POS 02). Documentation in the medical record must support why the service could not be rendered using video technology.
Resources:
2025 AMA CPT® Professional
Billing and coding Medicare Telehealth Fee-for-Service claims
Federal Register / Vol. 89, No. 236 / Monday, December 9, 2024 / Rules and Regulations, page 82
AMA Errata and Technical Corrections – CPT2025 Date: March 14, 2025
Audio-Only Telehealth Post-PHE — Medicare, Medicaid, and Private Payers
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Hi I work in a FQHC we use the office visit code for telehealth. The providers need to know if we can ad 93 or 95 to the E/M 99201-99215 our POS is 11
use can use 93 or FQ. https://www.aapc.com/blog/93379-many-medicare-telehealth-coverage-extensions-have-come-to-an-end/
I have Aetna denying claims with Mod 93 for audio only w. 99214. They state we should be using 98008-98015 for audio only; they are moving away from using mod 93. Is this accurate? These new guidelines also apply to commercial?
For Medicare, modifier 93 is only required for FQHCs and RHCs.
Audio-only E/M services are reported with 98008-98016 — except for Medicare, which only accepts 98016. None of the codes are on the CMS telehealth code list since audio-only isn’t considered telehealth.