Start With a Real Story
Three years ago, I sat with the CFO of a multi-specialty clinic. Their biggest payer had just recouped over $250,000. The reason? They’d billed audio-only telehealth visits under the wrong CPT codes for months. Worse, they didn’t document why video wasn’t used, didn’t include the required modifier, and didn’t train the new billing staff.
The CFO told me, “We thought telehealth billing would stay easy after COVID. We were dead wrong.”
It’s 2025 now. And here’s the truth: Telehealth is here to stay, but the compliance landscape is more complex than ever. CMS, private payers, and states all have new policies, updated every few months. One slip-up — a missing modifier, an old Place of Service (POS) code, or a missing consent note — and your claims can be denied or clawed back.
That’s why I wrote this: a no-BS guide to what’s changing this year, the latest expert insights, proven tactics that actually work, failures to learn from, and the real steps to protect your revenue.
Why Telehealth Billing Still Trips Practices Up
Stat: A new MGMA report says 60% of practices are seeing more telehealth claim denials than in 2024.
The top reasons?
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Documentation gaps
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Using obsolete CPT codes
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Skipping modifiers like -93 or FQ
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Failing to check each payer’s rules
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Poor staff training and EHR errors
With CMS extending pandemic flexibilities through September 30, 2025, this year is a transition point. Get it right, you thrive. Get it wrong, you risk audits and lost revenue.
Expert Round-Up: What the Sharpest Minds Do Differently
1️⃣ Dr. Anita W., Rural Family Medicine
“Our rural clinics rely on audio-only visits for elderly patients who can’t use video. But we learned fast: no modifier -93, no payment. Our biggest fix? Training providers to note start/stop time, why video was impractical, and patient consent every single time.”
2️⃣ Sarah Chen, Revenue Cycle Manager, Large Urban Network
“If you don’t have a payer grid, you’re flying blind. We update ours quarterly. If Aetna drops a new telehealth policy, we adjust within 48 hours. No more hoping denials fix themselves.”
3️⃣ Carlos Rivera, Compliance Advisor for Startups
“Startups think telehealth is ‘plug and play.’ They forget state laws. I’ve seen platforms get hit with massive recoupments because they didn’t verify whether their providers were licensed in every state they served. Never assume your malpractice policy covers you, either.”
Tactical Tips: Build a Revenue-Ready Telehealth Process
1. Know Your CPT Codes
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99212–99215: Use for audio/video E/M visits.
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99441–99443: Use for audio-only E/M visits — but only if your payer accepts them.
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G2012: Brief virtual check-ins, different from full audio-only E/M.
Pro Tip: Always check your top five payers — some still limit audio-only codes.
2. Use Modifiers Without Mistakes
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Modifier -93: Required for audio-only by Medicare.
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Modifier FQ: Sometimes used instead of -93, depends on payer.
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Modifier 95: Video-based telehealth; some payers require it, others don’t.
3. Get POS Right
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POS 02: Telehealth not in patient’s home.
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POS 10: Telehealth in patient’s home.
Check your payers — some want POS 11 for in-person only, so mixing them up can mean denials.
4. Build and Audit a Payer Grid
Keep a spreadsheet with:
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Allowed CPT codes
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Modifiers required
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Audio-only rules
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Documentation requirements
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Links to each payer’s policy
Review every 90 days. Assign one staffer to manage it.
5. Train Staff Like You Mean It
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Hold onboarding sessions for all billers and front desk staff.
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Review real denied claims and dissect them.
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Include state-specific licensing and malpractice coverage.
6. Document the Modality
Include in every visit:
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Start/stop time
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Patient’s location
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Modality (audio-only or audio/video)
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Why audio-only was needed
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Consent from the patient
7. State Licensure: Check Twice
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Make sure providers are licensed in every state they serve.
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Confirm your malpractice policy covers telehealth across state lines.
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Bookmark and review your state’s telehealth policy quarterly.
Sharing Hard Lessons: Two Costly Real-World Mistakes
Mistake #1: The Behavioral Health Blind Spot
A multi-state mental health group billed all sessions as audio-only, assuming they were fine. They didn’t document why patients couldn’t use video. When audited, they had to repay $350,000. Always prove medical necessity for audio-only.
Mistake #2: The EHR “Auto-Populate” Disaster
One practice’s EHR auto-filled POS 11 (in-office) for all telehealth visits. They were paid for months — then hit with an audit. Result: they refunded every claim. Always verify your EHR settings.
What’s Changing Right Now: 3 Key Updates for 2025
1️⃣ CMS Final Rule Expands Telehealth Flexibility for 2025
CMS’s 2026 Physician Fee Schedule proposed rule extends major telehealth provisions:
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Audio-only allowed for certain non-behavioral services if the patient can’t use video.
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FQHCs and RHCs can keep billing telehealth.
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Virtual direct supervision is now allowed via real-time audio/video.
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The Medicare Telehealth Services List will see a streamlined review process.
2️⃣ MGMA Stat: Top Reasons Telehealth Claims Are Denied
MGMA reports that claim denials rose 60% in 2025, mostly due to:
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Missing or incorrect modifiers.
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Lack of proof that video was impractical.
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Old CPT codes.
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EHR system misconfigurations.
Solution: Add front-end edits, run weekly denials reports, and update payer rules quarterly.
3️⃣ Audio-Only Telehealth Coverage by State
The Center for Connected Health Policy (CCHP) confirms:
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Medicare covers audio-only for behavioral health permanently.
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Non-behavioral audio-only is allowed only if patients can’t use video.
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State Medicaid programs differ — some are broader.
FAQ: Your Top Telehealth Billing Questions
Q1: Are audio-only visits always covered?
No — document why video was impractical. Some payers still deny non-behavioral audio-only.
Q2: Is patient consent required for every visit?
Yes — document it in every note.
Q3: Which POS code do I use?
Use POS 02 or POS 10, depending on where the patient is located.
Q4: Do I need to license providers in every state?
Yes — unless your state has a waiver. Never assume coverage.
Q5: Should I outsource billing?
Only if you understand the basics. Outsourcing doesn’t replace your oversight.
Call to Action: Get Involved — Protect Your Revenue
Get involved. Don’t assume someone else has it covered.
Train your staff. Double-check your claims. Run an audit this quarter. Build your payer grid. Share what you learn with peers. Be the voice in your practice that says, “We’re not guessing anymore — we’re verifying.”
Engage with this conversation. Raise your hand. Let’s fix this industry together.
About the Author
Dr. Daniel Cham is a physician and medical consultant specializing in medical technology, healthcare management, and medical billing. He helps practices navigate the intersection of compliance, revenue, and patient care.
Connect with Dr. Cham on LinkedIn: Daniel Cham, MD
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