“The art of medicine consists of amusing the patient
while nature cures the disease.” – Voltaire
Introduction: A New Era in Telehealth
In 2025, telehealth has transitioned from a temporary
solution to a permanent fixture in healthcare delivery. This shift necessitates
a comprehensive understanding of telehealth billing and compliance to ensure
accurate reimbursement and adherence to evolving regulations.
Understanding Telehealth Billing Codes
The American Medical Association (AMA) introduced new CPT
codes in 2025 to better capture telehealth services:
- Synchronous
Audio-Video Visits (CPT 98000–98007): These codes are used for
real-time, interactive audio-video consultations. They mirror traditional
Evaluation and Management (E/M) codes (99202–99215) but are tailored for
telehealth scenarios.
- Synchronous
Audio-Only Visits (CPT 98008–98015): Designed for real-time,
interactive audio-only consultations, these codes replace the previous
telephone E/M codes (99441–99443) and are time-based, ranging from 15 to
40 minutes, depending on the complexity of the service .
- Brief
Synchronous Communication (CPT 98016): This code is for a single 5–10
minute medical discussion not related to a previous E/M service within the
last seven days or leading to one in the next 24 hours. It replaces the
CMS virtual check-in code (G2012) .
Billing for Telehealth Services
When billing for telehealth services, consider the
following:
- Modifiers:
Use modifier “95” for audio-video visits and “93” for audio-only visits to
indicate that the service was provided via telehealth .
- Place
of Service (POS) Codes: POS 10 is used when the patient is at home,
and POS 02 is used when the patient is at any other location.
- Medicare
Considerations: While the new AMA CPT codes are not recognized by
Medicare, providers should continue using standard E/M codes with
appropriate modifiers for telehealth services .
Payer-Specific Compliance
Different payers have varying requirements for telehealth
billing:
- Medicare:
As of 2025, Medicare continues to recognize traditional E/M codes for
telehealth services. The new AMA codes are not accepted for reimbursement
.
- Commercial
Payers: Insurers such as Aetna, Cigna, and United Healthcare have
updated their telehealth policies to include the new AMA codes. However,
reimbursement rates and requirements may vary, so it's essential to verify
each payer's policy .
Expert Opinions
- Dr.
Sarah Thompson, MD: "The introduction of CPT 98000–98015 provides
a more accurate representation of telehealth services. However, it's
crucial for providers to stay informed about each payer's policies to
ensure appropriate reimbursement."
- John
Davis, CPC: "Modifiers and POS codes are vital in telehealth
billing. Incorrect usage can lead to claim denials. Providers must be
diligent in their coding practices."
- Emily
Roberts, Healthcare Compliance Officer: "Compliance is not just
about following rules; it's about understanding the nuances of each
payer's requirements and ensuring that documentation supports the services
rendered."
FAQs – Telehealth Billing & Compliance
Q: Are the new AMA CPT codes accepted by Medicare?
A: No, Medicare does not recognize the new AMA CPT codes (98000–98015)
for telehealth services. Providers should continue using standard E/M codes
with appropriate modifiers for telehealth services.
Q: Can I use the same CPT codes for telehealth as I would
for in-person visits?
A: Yes, for audio-video visits, you can use the same CPT codes as
in-person visits. However, you must use the appropriate modifier and POS
code to indicate that the service was provided via telehealth.
Q: Do I need to obtain patient consent for telehealth
services?
A: Yes, obtaining patient consent is essential. Ensure that the
patient understands the nature of telehealth services and agrees to receive
care through this modality.
Q: Are audio-only visits reimbursable?
A: Yes, audio-only visits are reimbursable using specific CPT
codes (98008–98015) if medical necessity is documented and the payer recognizes
these codes.
Q: What modifiers should I use for telehealth billing?
A: Use modifier 95 for synchronous audio-video visits and modifier
93 for synchronous audio-only visits. Always check payer-specific
guidelines.
Q: What place-of-service (POS) codes apply to telehealth?
A: POS 10 is used when the patient is at home, and POS 02
applies when the patient is at another location. Accurate POS coding is
critical for compliance and reimbursement.
Q: Do telehealth visits require the same documentation as
in-person visits?
A: Yes, all telehealth visits require thorough documentation of
history, exam (if applicable), medical decision-making, and patient
communication to support billing.
Q: Are telehealth compliance rules the same for
commercial insurers and Medicare?
A: Not exactly. While the general compliance standards are the
same, each payer may have unique rules for coding, documentation, and
reimbursement, so verifying each policy is essential.
Q: Can telehealth be used across all specialties?
A: Yes, telehealth is widely used across specialties, including primary
care, behavioral health, chronic disease management, post-op follow-ups, and
urgent care.
Q: Will telehealth automatically increase my practice
revenue?
A: Not necessarily. Accurate coding, proper documentation, and payer
verification are required to avoid claim denials and ensure reimbursement.
Myth Busters – Telehealth Edition
- Myth:
"Telehealth services are reimbursed at a lower rate than in-person
visits."
Fact: Reimbursement rates vary by payer. Some commercial insurers offer payment parity, reimbursing telehealth services at the same rate as in-person visits. - Myth:
"I can use any CPT code for telehealth services."
Fact: Use the appropriate CPT code for the service provided. Telehealth requires specific codes and modifiers to indicate audio/video or audio-only delivery. - Myth:
"Telehealth services are not subject to the same compliance
requirements as in-person visits."
Fact: Telehealth services must adhere to the same documentation, billing, and coding standards as in-person care. - Myth:
"Audio-only visits are not reimbursable."
Fact: Audio-only visits have specific CPT codes (98008–98015) and are reimbursable if documentation supports medical necessity. - Myth:
"I don’t need patient consent for telehealth visits."
Fact: Patient consent is mandatory. Providers must document that patients understand the telehealth modality, limitations, and privacy considerations. - Myth:
"Telehealth compliance only matters for Medicare."
Fact: All payers, including commercial insurers and Medicaid, have specific compliance rules. Staying informed prevents claim denials and audits. - Myth:
"Telehealth is only for primary care or minor issues."
Fact: Telehealth is used across specialties, including behavioral health, chronic disease management, post-op follow-ups, and urgent care consultations. - Myth:
"Using telehealth automatically increases revenue."
Fact: Without accurate coding, proper documentation, and payer verification, telehealth can lead to claim denials or compliance issues.
Step-by-Step Instructions for
Telehealth Billing and Compliance
Step 1: Confirm Telehealth
Eligibility
- Verify that the patient’s insurance plan
covers telehealth services.
- Check if the patient qualifies for audio-video or
audio-only visits.
- Confirm any state-specific telehealth regulations.
Step 2: Obtain Patient Consent
- Inform the patient about the nature, benefits, and
limitations of telehealth.
- Explain privacy considerations, including
HIPAA compliance.
- Document verbal or written consent in the patient’s electronic
health record (EHR).
Step 3: Determine the
Appropriate CPT Code
- For audio-video visits, use CPT 98000–98007 or
standard E/M codes (99202–99215) with modifier 95.
- For audio-only visits, use CPT 98008–98015
with modifier 93.
- For brief check-ins, use CPT 98016 if criteria
are met.
Step 4: Assign the Correct
Place of Service (POS) Code
- POS 10: Patient at home.
- POS 02: Patient at any other location outside
the provider’s office.
Step 5: Document the Encounter
Properly
- Record history, exam (if applicable), medical
decision-making, and patient communication.
- Note duration of service for time-based CPT
codes.
- Ensure documentation supports billing and
compliance requirements.
Step 6: Verify Payer-Specific
Rules
- Check the payer’s telehealth policy for
coverage, coding, and reimbursement rules.
- Adjust coding and documentation according to each
payer’s requirements.
Step 7: Submit the Claim
- Include correct CPT code, modifier, and POS code
on the claim.
- Attach any required supporting documentation
if the payer requests it.
- Double-check patient demographics and insurance
information to avoid denials.
Step 8: Track and Audit Claims
- Monitor reimbursement and claim status.
- Address denials or rejections promptly with corrected
claims and documentation.
- Perform regular audits to ensure ongoing
compliance.
Step 9: Educate Your Staff
- Train all clinical and billing staff on telehealth
coding, compliance, and documentation standards.
- Update protocols as regulations and payer policies
change.
Step 10: Continuously Review
and Improve
- Keep up-to-date with AMA CPT updates, CMS
guidance, and payer policies.
- Collect feedback from patients and staff to
improve the telehealth experience.
- Implement quality improvement initiatives to
optimize efficiency and compliance.
Final Thoughts
Telehealth has become an integral part of healthcare
delivery. Understanding the nuances of telehealth billing and compliance is
essential for providers to ensure accurate reimbursement and adherence to
regulations. Stay informed, stay compliant, and continue to provide quality
care to your patients.
Call to Action
Stay ahead in the evolving landscape of telehealth by
engaging with industry updates, participating in webinars, and collaborating
with peers. Your proactive approach ensures that you remain compliant and
continue to deliver exceptional care.
References
- AMA Telehealth Policy, Coding & Payment
- Telehealth Billing in 2025
- Telehealth
Evaluation and Management (E/M) Services for 2025
Hashtags
#Telehealth #MedicalBilling #Compliance #CPTCodes
#HealthcareReimbursement #Telemedicine #MedicalCoding #HealthcareCompliance
#Telehealth2025 #MedicalPractice
About the Author
Dr. Daniel Cham is a physician and medical consultant
specializing in medical technology, healthcare management, and medical billing.
He focuses on delivering practical insights to help professionals navigate
complex challenges at the intersection of healthcare and medical practice.
Connect with Dr. Cham on LinkedIn to learn more: linkedin.com/in/daniel-cham-md-669036285
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