How to bill Medicare for telehealth in 2025

CPT added a new set of telemedicine codes this year to report audiovisual and audio-only telehealth services. Payer adoption of the new codes has been inconsistent, however, leading to widespread confusion. Unfortunately, the only way to discern how commercial, Medicare Advantage, and Medicaid plans (including managed care organizations) are handling the changes is to contact your local provider relations representatives and Medicaid agencies. Adding to the complexity, Congress extended Medicare’s pandemic-era telehealth flexibilities, but they are now set to expire March 31 unless Congress acts again.

Accounting for all that, below is a summary of how to bill traditional Medicare for telehealth at this time. (Additional information is available on the AAFP’s telehealth coding webpage.)

Audiovisual services

• Medicare did not adopt CPT’s new audiovisual E/M codes (98000-98007) and will deny claims reported with them. In general, you should report eligible audiovisual telehealth services for traditional Medicare patients the same as last year.

• Medicare does not require a modifier (e.g., 95) for audiovisual telehealth.

• Medicare does require an appropriate place of service (POS) code. Use POS 10 when the patient is at home and POS 02 when the patient is anywhere else.

Audio-only services

• Medicare did not adopt CPT’s new audio-only E/M codes (98008-98015) and will deny claims reported with them.

• CPT deleted the telephone evaluation and management (E/M) codes (CPT 99441-99443).

• Beginning in 2025, Medicare will allow physicians to report any code on the eligible telehealth services list performed via two-way interactive audio-only technology (i.e., telephone) to patients in their home in cases when the physician is technically capable of using audio-video technology, but the patient is not capable or does not consent to use of video. Make sure your documentation reflects both the reason for using audio-only as well as that the physician has audio-video technical capabilities. Append modifier 93 to indicate the service was provided audio-only. For example, in lieu of 99441-99443, report the appropriate office visit E/M (99202-99215) with modifier 93.  

• Federally qualified health centers and rural health clinics should also append the FQ modifier for services provided via audio-only. 

• Use POS 10 to denote that the patient is at home.

Communication Technology-based Services (CTBS)

Medicare replaced HCPCS code G2012 for the virtual check-ins with CPT code 98016 (brief CTBS by a physician or other qualified health care professional, provided to an established patient, 5-10 minutes of medical discussion). The service is still the same – it just has a new code.

— Erin Solis, Manager, Practice & Payment, American Academy of Family Physicians

Posted on Feb. 6, 2025