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How to Code for Telehealth: Audio-video, Audio-only and Virtual-digital Visits

Learn how to accurately get paid for telemedicine services with medical codes for telehealth, audio-only and virtual-digital visits. The right codes for Medicare, Medicaid and private payers can ensure proper payment that helps keep you connected to your patients.

Note: The information provided below is not intended to be advisory. The AAFP recommends that physicians verify each payer's policy and ask patients to verify their coverage ahead of appointments.

Telehealth coding updates for 2025

Beginning October 1, 2025, many of Medicare’s pre-pandemic telehealth policies are in effect. Congressional action is required to make several key Medicare telehealth flexibilities that expired on September 30 permanent. This means:

Medicare beneficiaries may receive telehealth services only if they are at an eligible originating site and within a specific geographic area OR are receiving mental/behavioral health services that meet certain criteria.
Patients may only receive telehealth services in their home or via audio-only if they meet additional criteria.
Federally Qualified Health Centers and Rural Health Clinics can serve as distant site providers.

2025 coding FAQs (updated October 2025)

Eligible originating sites include:

Physician offices

Rural Health Clinics and Federally Qualified Health Centers

Critical Access Hospitals (CAHs)

Skilled Nursing Facilities

Hospitals

Hospital-based or CAH-based renal dialysis centers

Community Mental Health Centers

Renal Dialysis Facilities

Rural Emergency Hospitals

Mobile Stroke Units (for acute stroke)

Patient’s home (limited to mental/behavioral telehealth services)

The originating site must be in one of the following geographic areas:

A rural health professional shortage area (HPSA),

A county that is not in a Metropolitan Statistical Area (MSA), OR

Within a federal telehealth demonstration project.

You can check if an address is an eligible site using the Medicare Telehealth Payment Eligibility Analyzer.

The flexibilities that expired September 30, 2025, apply only to traditional Medicare (Part B) patients. Medicaid, MA and commercial policies will vary by state and payer. You will need to contact your state Medicaid and provider relations representatives to get their policies.

The American Academy of Family Physicians is advocating for Congress to swiftly enact legislation that would make telehealth flexibilities permanent, arguing that they have transformed care delivery, especially for older adults, individuals with mobility limitations and patients in rural or underserved communities. The key provisions include (1) eliminating geographic restrictions so patients can receive care from home, regardless of location, (2) allowing audio-only telehealth for patients without broadband or video-capable devices, (3) permitting FQHCs and RHCs to serve as distant site providers,and (4) waiving in-person visit requirements for behavioral health services.

Telehealth for the treatment of mental/behavioral health conditions is exempt from the geographic requirements if:

The patient is being treated for substance use disorder AND a co-occurring mental/behavioral health condition.

The patient had an in-person visit with the telehealth physician or clinician within six months prior to the initial telehealth visit and every 12 months thereafter.* The in-person visit may be with another physician or clinician in the same subspecialty within the same group practice if the original physician or clinician is unavailable.

CMS has not issued specific guidance to address how the in-person requirements apply to existing patients. Absent additional guidance, practices may want to consider any telehealth visit after September 30, 2025, as the initial visit. This would mean a patient will need to have had an in-person visit on or after March 30, 2025.

*—The physician and patient may agree to waive the annual in-person visit if the risk and burdens of travel outweigh the benefits on an in-person visit and the reason is documented in the patient’s medical record.

Patients may receive mental/behavioral telehealth services at their home if they meet either of the above exceptions or are in a rural HPSA, a county that is not in an MSA, or in a federal telehealth demonstration project.

Audio-only telehealth services are limited to patients who are unable to or do not want to use live video and are located at home. In other words, a patient may only receive audio-only telehealth services if they also meet the eligibility requirements to receive telehealth at home. The telehealth physician or clinician must still have the capability to use live video.

The National Consortium of Telehealth Resource Centers has put together a guide to help practices navigate the expiration of the telehealth flexibilities. At a high level they, recommend:

Assessing how many of your patients currently receive telehealth outside of an approved originating site.
Evaluate your financial risk and determine whether you can continue offering telehealth to patients without payment.
Provide clear communications to your patients, physicians and clinicians, and staff.
If the waivers expire and are reinstated at a later date, Medicare may allow you to retroactively submit claims for services provided during the gap. While Medicare has done this in the past, there are no requirements for them to provide retroactive payment. If you plan to bill Medicare patients for non-covered telehealth services, consider obtaining an Advance Beneficiary Notice (ABN). You will not be able to bill Medicare if you bill the patient.
Explore alternative locations and eligible originating sites that may be more accessible to your patients.
Check if a site meets the telehealth payment requirements by entering the street address into the Medicare Telehealth Eligibility Analyzer.

You can find detailed guidance and additional tips on the National Consortium of Telehealth Resource Centers webpage.

Physicians participating in Medicare Shared Savings Program ACOs under two-sided risk and that have selected prospective assignment are not subject to the originating and geographic site restrictions. Participants in these ACOs may continue providing telehealth services to prospectively assigned Medicare beneficiaries, regardless of the beneficiary's location. This includes ACOs in the ENHNACED track and BASIC track levels C, D, or E.

ACOs participating in a one-sided model or participating under the preliminary prospective assignment with retroactive reconciliation method are subject to the usual Medicare fee-for-service telehealth rules.

Additional information is available in the MSSP Telehealth Fact Sheet.

Coding for audio-video visits

Medicare

Beneficiaries must be in an eligible originating site and located within a specific geographic area OR receiving telehealth services for the diagnosis or treatment of a mental/behavioral health condition or substance use disorder.

Medicare did not adopt the new audio-video CPT codes (98000-98007). Instead use the appropriate office visit evaluation and management CPT code as outlined below:

CPT Codes	99202-99205 99211-99215
Place of Service (POS)	Use the POS that aligns with the patient's location. POS 02: Telehealth Provided Other than in a Patient's Home POS 10: Telehealth Provided in a Patient's Home (a location other than a hospital or other facility where the patient receives care in a private residence)*

As of January 1, 2024, Medicare pays for telehealth services provided in the patient’s home (POS 10) at the non-facility rate. Telehealth services provided at an originating site (POS 02) are paid at the facility rate. You can look up the non-facility and facility rates using the Medicare Physician Fee Schedule Lookup Tool.
Telehealth provided in the patient’s home is restricted to mental/behavioral health services.

To be eligible to receive mental/behavioral health telehealth services in the home, the beneficiary’s home must either meet the geographic site requirement (i.e., be in a rural HPSA, outside of a MSA or in a federal health demonstration project) or meet one of the following criteria:
- Are being treated for substance use disorder AND a co-occurring mental/behavioral health condition, or
- had an in-person visit with the telehealth physician or clinician within six months prior to the initial telehealth visit and every 12 months thereafter. The in-person visit may be with another physician or clinician in the same subspecialty within the same group practice if the original physician or clinician is unavailable.

Medicare does not require a modifier for audio-video telehealth services.

Private Payers

Commercial, self-funded, and Medicare Advantage polices regarding telehealth vary, including their adoption of the new audio-video CPT codes (98000-98007). Check with your local provider relations representative for their most recent policies.

Medicaid

Similarly, Medicaid policies are established at the state-level, including their adoption of the new audio-video CPT codes (98000-98007). Check with your local Medicaid agency and/or Medicaid Managed Care Organizations (MCOs) for their policies.

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Coding for audio-only visits

Medicare

Effective October 1, 2025, Medicare audio-only telehealth is limited to mental/behavioral health and substance use disorder services provided to patients in their home. See above for the requirements for patients to receive telehealth services in their home.
Medicare will allow use of audio-only communication technology for any telehealth service provided to a patient in their home if the physician is capable of using an audio-video telecommunications system, but the patient is unable or does not consent to use of video. A list of Medicare’s Telehealth Services is available here. Use the CPT or HCPCS code that best describes the service provided (e.g., 99202-99215).
Beginning January 1, 2025, CPT Codes: 99441-99443 are no longer available. Medicare did not adopt the new audio-only CPT codes (98008-98015).
Append CPT modifier 93 to services provided via audio-only.
- Federally qualified health centers and rural health centers should use modifier FQ, 93, or both where appropriate and true, since they are identical in meaning.
Documentation must reflect that the physician has audio-video available, but the patient preferred audio-only or was unable to use audio-video.

Private Payers

Commercial, self-funded and Medicare Advantage polices regarding telehealth vary, including their coverage of audio-only and whether they adopted the new audio-only CPT codes (98008-98015). Check with your local provider relations representative for their most recent policies.

Medicaid

Similarly, Medicaid policies are established at the state level, including their coverage of audio-only and whether they adopted the new audio-only CPT codes (98008-98015). Check with your local Medicaid agency and/or Medicaid Managed Care Organizations (MCOs) for their policies.

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Coding for virtual-digital visits

Medicare

eVisits and virtual check-ins are considered communication technology-based services (CTBS). They are not subject to the originating and geographic site restrictions and are not impacted by the expiration of the telehealth waivers. Practices may continue to provide CTBS to all patients regardless of where the patient is located.

e-Visit

99421	Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 5-10 minutes
99422	Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 11-20 minutes
99423	Online digital E/M service, for an established patient, for up to seven days, cumulative during the seven days, 21 or more minutes

Virtual check-in

G2010	Remote evaluation of recorded video or images submitted by an established patient (e.g., store and forward), including interpretation and follow-up with the patient within 24 business hours, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment
98016	Brief communication technology-based service (CTBS), e.g. virtual check-in, by a physician or other QHP who can report E/M services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.
G2252	Brief CTBS, e.g., virtual check-in, by a physician or other QHP who can report evaluation and management services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 11-20 minutes of medical discussion.

Medicare replaced G2012 with CPT code 98016.

Private Payers

Commercial, self-funded and Medicare Advantage polices regarding telehealth vary. Check with your local provider relations representative for their most recent policies.

Medicaid

Similarly, Medicaid policies are established at the state level. Check with your local Medicaid agency and/or Medicaid Managed Care Organizations (MCOs) for their policies.

Virtual/Digital Scenario Notes

Patient consent is required and may be obtained either before or at the time of service.
Virtual check-ins and e-visits must be initiated by a patient. Physicians and other providers may need to educate beneficiaries on the availability of the service prior to patient initiation.
There are no POS or modifier requirements for virtual check-ins or e-visits. Use the POS used for typical services.

Virtual Check-in (HCPCS Code 98016, G2252)

These are brief conversations with a physician or other clinician to determine if an in-person visit is necessary.
The communication cannot be related to a medical visit within the previous seven days and cannot lead to medical visit within the next 24 hours (or soonest appointment available).
Physician or other clinician may respond to patient by telephone, audio/video, secure text messaging, email or patient portal.
HCPCS code G2010 can be used when a captured video or image (store and forward) is sent to the physician. The physician must follow up with the patient within 24 business hours. The consultation must not originate from an evaluation and management (E/M) service provided within the previous seven days or lead to an E/M service within the next 24 hours (or soonest available appointment).

E-Visits (online digital evaluation and management services)

These are non-face-to-face, patient-initiated communications with the physician through an online patient portal. The communications can occur over a seven-day period, and the exchange must be stored permanently.
They are a time-based service. Physicians use the cumulative time for up to seven days to determine the level of service.
- Cumulative time includes review of the initial inquiry, review of patient records pertinent to the assessment of the patient’s problem, personal interaction with clinical staff focused on the patient’s problem, development of management plans (including generation of prescriptions or ordering of tests), and subsequent communication with the patient. Communication can occur through online, telephone, email or other digitally supported communication

Physicians and other clinicians who may independently bill Medicare for E/M services can use the following codes:

99421: Online digital evaluation and management service, for a patient, for up to 7 days, cumulative time during the 7 days; 5-10 minutes
99422: Online digital evaluation and management service, for a patient, for up to 7 days, cumulative time during the 7 days; 11-20 minutes
99423: Online digital evaluation and management service, for a patient, for up to 7 days, cumulative time during the 7 days; 21 or more minutes

E-visits should not be billed on the same day the physician reports an office visit E/M service (CPT codes 99202-99205 and 99211-99215) for the same patient. Additionally, e-visits should not be billed when using the following codes for the same communication:

99091
99339-99340
99374-99380
99487 and 99489
99495-99466

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