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 (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.
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.
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Synchronous audio-video |
Synchronous audio-only |
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New Patient |
98000 – straightforward MDM or 15 minutes |
98008 – straightforward MDM or 15 minutes |
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98001 – low MDM or 30 minutes |
98009– low MDM or 30 minutes |
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98002 – moderate MDM or 45 minutes |
98010– moderate MDM or 45 minutes |
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98003 – high MDM or 60 minutes |
98011 – high MDM or 60 minutes |
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+99417 – for services 75+ minutes |
+99417 – for services 75+ minutes |
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Established Patient |
98004 – straightforward MDM or 15 minutes |
98012 – straightforward MDM or 15 minutes |
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98005– low MDM or 30 minutes |
98013– low MDM or 30 minutes |
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98006 – moderate MDM or 45 minutes |
98014– moderate MDM or 45 minutes |
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98007 – high MDM or 60 minutes |
98015 – high MDM or 60 minutes |
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+99417 – for services 75+ minutes |
+99417 – for services 75+ minutes |
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.
Shea Lunt, RHIA, CPC, CPMA, PMP
Director of Coding Quality & Compliance
Shea is a Director of Coding Quality & Compliance for The Haugen Consulting Group with 15 years of healthcare industry experience. Shea has experience working on the professional fee side of coding, auditing, education, and compliance serving coders and physicians. Shea has also served as a project lead for ICD-10-CM education initiatives and implementation of computer-assisted coding (CAC) projects. She earned a bachelor’s degree in health information management and a master’s degree in health services administration from the University of Kansas Medical Center in Kansas City, Kansas. Shea is a Registered Health Information Administrator (RHIA), Certified Professional Coder (CPC), Certified Professional Medical Auditor (CPMA), and a Project Management Professional (PMP).
Hello
Can you confirm if these codes are good for INPT?
98000-98007
98001-980015
Hi Velasco, These are for outpatient. For inpatient, continue to use the appropriate inpatient code (e.g., 99231-99233) with modifier 95 or 93.
Hi. Since we don’t know what the in-person requirement will look like starting April 1, 2025 – is it possible to continue to see clients for mental health related appointments via audio-only? I don’t want to drop care but also see a handful of clients via telehealth. Thoughts?
Hi Lindsay – CMS has posted the following FAQ; please see question #6: https://www.cms.gov/files/document/telehealth-faq-calendar-year-2025.pdf
Do we need to add a modifier to the codes 98000-98017? And will the POS still be 2 or 10?
Hi Jacki,
This will likely be payer specific, so you should always check payer policy. Generally speaking, yes, you would use POS 02 or 10 and no, a modifier would not be required.
is it true that starting 4/1/25 patients will be required to be in office or back to the 02 location and not in a patient’s home?
Hi Michelle, The current telehealth flexibility extensions remain in effect until March 31, 2025. Any further extensions or permanent policy changes would require approval by Congress.
On all audio only visits telehealth services including Behavior health services does requirement documentation still need to be met in regard to why the visit was conducted audio only still? I know BH services are permanently being extended but providers are inquiring does this documentation need to be required in their audio only note.
Hi Bianca, Behavioral/mental telehealth services in Medicare can permanently be delivered using audio-only communication platforms; there is no need to document why the visit was conducted via audio-only communication.
To bill Medicare telephone visit it is required to have documentation that medical discussions must exceed 10 minutes, with duration documented since they want regular office visit codes?
Hi Danielle, No, this requirement is only for the new telemedicine audio-only visit codes (98008-98015).
I think Danielle meant for audio only visits for Medicare patients since we are submitting office visit codes with modifier 93, do audio only visits need to exceed 10 minutes in order to code/bill?
Hi Bianca, Office visit codes do not have this requirement.
What reference did you use to find that Medicare will accept e/m codes for telehealth?
Hi Hunter,
It can be found in the 2025 CMS Final Rule, starting on page 80. https://www.federalregister.gov/documents/2024/12/09/2024-25382/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other. In addition, this information was presented at the AMA’s 2025 CPT & RBRVS Symposium.
Warm regards,
The Haugen Learning Team