The Struggles of Telehealth Billing
Let’s start with a story.
A friend of mine—a family medicine physician—had been practicing telehealth during the pandemic and was riding high. Things were going great, claims were getting approved, and patients were happy. Then came the audit. The result? A $50,000 clawback for improperly billed telehealth visits. How did it happen?
The short answer: telehealth billing isn’t static—it’s constantly evolving. What worked a year ago may not fly today. As telemedicine becomes a fixture in our healthcare system, navigating billing compliance and coding becomes more complicated. Telehealth regulations vary by payer, and changes in CPT codes, modifiers, and documentation standards can result in denials or worse—clawbacks.
In this post, I’ll break down the latest telehealth billing practices, mistakes to avoid, and how to stay ahead of compliance hurdles, especially regarding Medicare and Medicaid reimbursement policies.
🔥 Why Telehealth Billing Is So Tricky Right Now
The reality is simple: telehealth billing can feel like a moving target. Here’s why:
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Pandemic rules have shifted. What was allowed during the COVID-19 public health emergency isn’t necessarily allowed now. Telemedicine services are no longer treated the same as in-person visits, so it's essential to know the current reimbursement rates.
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Payers are still figuring out the right way to pay for telehealth services.
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Coding errors or outdated procedures can result in claim denials or payment delays.
The bottom line? Staying on top of telehealth compliance means constantly adapting to new rules.
🚨 5 Telehealth Billing Tips That Will Save You Time and Money
✅ 1. Know Your Modifiers—and Use Them Right
Modifiers are your best friends, but only if you use them correctly.
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Modifier 95 = Real-time audio and video telehealth.
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Modifier 93 = Audio-only telehealth.
Pro tip: Not all EHRs automatically include the right modifier. Double-check each claim to make sure you're on the ball with telehealth billing codes and telehealth claims.
✅ 2. Document Everything—Especially Location and Mode of Communication
It’s tempting to skip over details, but documentation is critical for telehealth claims. Pay attention to:
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Patient location (Are they in a rural area? In a state where you’re licensed?)
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Mode of communication (Was it audio-only, or did you use video?)
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Visit duration (Payers care about this!)
Failing to properly document these can trigger an audit and result in claim denials.
✅ 3. State Licensing Still Matters
During COVID-19, the state licensing rules for telehealth were relaxed. But guess what? Those temporary flexibilities are gone. If you're treating a patient in another state, you must verify that you’re licensed in that state. No exceptions.
Always check your telehealth regulations and licensing requirements before seeing a patient in another state.
✅ 4. Don’t Mix Telehealth and In-Person Billing Codes
It might be tempting to treat telehealth the same as in-person visits, but they’re not the same when it comes to CPT coding.
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Different codes apply for telehealth visits, and sometimes, reimbursement rates vary.
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Certain services, like chronic care management and behavioral health visits, may have telehealth-specific billing requirements.
Make sure you're using the right codes for virtual visits and double-check that you're following payer-specific rules for telemedicine billing.
✅ 5. Audit Your Telehealth Claims Regularly
I can’t stress this enough: audit your telehealth claims regularly. Set aside time each month to review:
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Modifiers: Are they accurate?
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Patient details: Is their location and visit duration documented properly?
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CPT codes: Do they match the service provided?
The last thing you want is a telehealth audit surprise. Stay ahead by reviewing claims before they’re submitted.
🚨 A Hard-Learned Lesson in Telehealth Billing
I’ve been there myself—getting hit with a denial for telehealth claims I thought were perfectly fine. I used the wrong CPT code and assumed audio-only visits could be billed the same as video visits. Wrong. The denial cost me thousands, and I learned the hard way that telehealth billing needs to be precise.
Don’t make the same mistake. Stay proactive by auditing your billing practices, keeping your team informed, and making sure your documentation is in order.
🗣 Real Docs Share Their Telehealth Billing Struggles
"Telehealth was a game changer during the pandemic, but now we’re getting clawbacks because we didn’t update our billing codes fast enough. It’s a mess." – Dr. Linda, Family Medicine, Florida
"I thought Medicare would reimburse for all of our telehealth visits, but after reviewing the new regulations, we were left with a bunch of denied claims." – Dr. Mark, Cardiologist, Arizona
🚀 Final Thoughts: Mastering Telehealth Billing Compliance
Let’s face it: telehealth is here to stay, but if you don’t keep up with telehealth billing codes, CPT modifiers, and state regulations, you risk losing revenue.
The key to success is staying educated, staying compliant, and auditing your claims regularly. Use these tips to improve your billing practices and ensure you're not leaving money on the table.
❓ Frequently Asked Questions (FAQ)
Q1: What’s the difference between telehealth and telemedicine when it comes to billing?
A: While telemedicine is a subset of telehealth, they’re often used interchangeably in billing. But it’s important to verify whether you're billing for audio-only or video-based services, as coding and modifiers may vary.
Q2: Do I need to use a modifier for every virtual visit?
A: Yes! Use Modifier 95 for video telehealth and Modifier 93 for audio-only visits. Without the correct modifier, your claim could be denied.
Q3: Is patient consent still required for telehealth visits after the pandemic?
A: Yes. Patient consent is still required for telehealth services to comply with Medicare and Medicaid regulations. Always document consent, whether it’s audio-only or video.
Q4: Can I bill telehealth services the same way as in-person visits?
A: No. Telehealth visits require different CPT codes and may have different reimbursement rates depending on the payer. Always check payer-specific rules for telemedicine billing.
Q5: How do I keep up with all these telehealth billing changes?
A: Stay up-to-date with the latest updates from the Centers for Medicare and Medicaid Services (CMS), the American Medical Association (AMA), and your payer policies. Regular audits are also key.
🧠 References
Here are the working links for the latest telehealth billing and coding updates:
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CMS 2025 Telehealth Billing and Coding Updates: The Centers for Medicare and Medicaid Services (CMS) has released updates on telehealth billing, including new service codes and changes to audio-only telehealth communication. You can read the CMS guidance here.
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OIG Report on Telehealth Billing Compliance Risks Post-Pandemic: The Office of Inspector General (OIG) has provided a toolkit for analyzing telehealth claims to assess compliance risks. You can access the OIG report here.
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AMA’s Telemedicine CPT Code Updates for 2025: The American Medical Association (AMA) has introduced new CPT codes for telemedicine services, including behavioral health and chronic care management billing. You can view the AMA’s CPT updates here.
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