Telehealth 2025

What is the difference between Telemedicine and Telehealth?

Telemedicine is the practice of medicine using technology to deliver care at a distance. It occurs using telecommunications between a patient (at an originating site) and a physician or other practitioner licensed to practice medicine (at a distant hub or site).

Telehealth is the use of telecommunications and information technology to provide access to health assessment, diagnosis, intervention, consultation, supervision, and information across distances. It seeks to improve a patient’s health by permitting two-way, real-time interactive communication between the patient and the physician or practitioner at a distant site.

As of 2025, medical coding guidelines for telehealth are expected to continue evolving alongside regulatory changes and technological advancements. Here are some general guidelines and trends you might anticipate based on current practices:

1. CPT Codes: Familiarize yourself with the latest Current Procedural Terminology (CPT) codes specifically designated for telehealth services. Codes for virtual visits, remote patient monitoring, and other telehealth-related services may be updated.
2. Modifiers: Use the appropriate modifiers, such as 95 for telehealth services provided via real-time audio and video technology. Ensure you stay updated on any new modifiers introduced.
3. Documentation Requirements: Thorough documentation is essential. Providers must document the modality of the visit (e.g., audio, video), patient consent, and the specific services rendered during the telehealth encounter.
4. Patient Location: Be aware of the rules regarding the patient’s location during the telehealth visit. Some payers require the patient to be in specific locations (e.g., at home, in a healthcare facility) to qualify for reimbursement.
5. Coverage Variations: Different insurers may have varying coverage for telehealth services. Ensure you are familiar with the specific policies of Medicare, Medicaid, and private payers.
6. New Codes for Remote Monitoring: As remote patient monitoring continues to grow, look for updates in coding guidelines that may introduce new codes for remote services, including chronic care management and patient engagement tools.
7. Interstate Licensure: Be aware of the implications of interstate licensure for telehealth services, especially if coding involves care provided across state lines. This may impact reimbursement eligibility.
8. Compliance with HIPAA: Ensure that all telehealth practices comply with HIPAA regulations for patient privacy and data security. This is crucial for maintaining trust and ensuring proper coding.
9. Continuing Education: Stay updated through webinars, coding workshops, and guidelines from organizations like the American Academy of Professional Coders (AAPC) and the American Health Information Management Association (AHIMA).
10. Feedback Loop: Engage in regular reviews of coding practices and feedback from claims submissions to adapt to ongoing changes and improve accuracy.

In the Evaluation and Management (E/M) section, there are 17 new telemedicine codes (98000-98016), effective Jan. 1, 2025

CPT 2025 will include new codes for audio-only telemedicine visits for new patients (98008-98011) and established patients (98012-98015). These expanded codes will replace the existing telephone-only codes 99441-99443, which CPT 2025 will delete.

New telemedicine code debuting in 2025, 98016 (Brief communication technology-based service (eg, virtual check-in) by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related evaluation and management service provided within the previous 7 days nor leading to an evaluation and management service or procedure within the next 24 hours or soonest available appointment, 5-10 minutes of medical discussion). It will replace the existing HCPCS code G2012.

CPT New patients:

• 98000 – Synchronous audio-video visit for the evaluation and management of a new patient, which requires a medically appropriate history and/or examination and straightforward medical decision-making. When using total time on the date of the encounter for code selection, 15 minutes must be met or exceeded

• 98001 – …which requires a medically appropriate history and/or examination and low medical decision-making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded

• 98002 – …which requires a medically appropriate history and/or examination and moderate medical decision-making. When using total time on the date of the encounter for code selection, 45 minutes must be met or exceeded

• 98003 – which requires a medically appropriate history and/or examination and high medical decision-making. When using total time on the date of the encounter for code selection, 60 minutes must be met or exceeded

 CPT Established patients:

• 98004 – Synchronous audio-video visit for the evaluation and management of an established patient, which requires a medically appropriate history and/or examination and straightforward medical decision-making. When using total time on the date of the encounter for code selection, 10 minutes must be met or exceeded.

• 98005 – … which requires a medically appropriate history and/or examination and low medical decision-making. When using total time on the date of the encounter for code selection, 20 minutes must be met or exceeded

• 98006 – …which requires a medically appropriate history and/or examination and moderate medical decision-making. When using total time on the date of the encounter for code selection, 30 minutes must be met or exceeded

• 98007 – … which requires a medically appropriate history and/or examination and high medical decision-making. When using total time on the date of the encounter for code selection, 40 minutes must be met or exceeded.

Before the PHE, the following frequency limitations were in place:

• Limit of one telehealth visit every three days for subsequent inpatient visits;
• Limit of one telehealth visit every 14 days for subsequent nursing facility visits; and
• Limit on critical care consultations to one telehealth visit per day.

CMS proposed to continue to delay through December 31, 2025, before reinstating limitations on the number of times certain services in high-acuity settings may be performed via telehealth. During this time, CMS will continue to evaluate whether the removal of these frequency limitations should be made permanent.

The extension of CMS’s current suspension of frequency limitations applies to the following codes:

• Subsequent inpatient visit CPT codes 99231, 99232, 99233;
• Subsequent nursing facility visit CPT codes 99307, 99308, 99309, 99310; and
• Critical Care Consultation Services HCPCS codes G0508, G0509.

Telehealth Services under the PFS

For CY 2025, CMS proposed to add several services to the Medicare Telehealth Services List on a provisional basis, including demonstration prior to initiation of home International Normalized Ratio (INR) monitoring and caregiver training services. They were proposing to continue the suspension of frequency limitations for subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations for CY 2025. https://www.cms.gov/medicare/coverage/telehealth/list-services

CMS proposed that beginning January 1, 2025, an interactive telecommunications system may include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology.

CMS proposed that, through CY 2025, we will continue to permit the distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home.

CMS proposed, for a certain subset of services that are required to be furnished under the direct supervision of a physician or other supervising practitioner, to permanently adopt a definition of direct supervision that allows the physician or supervising practitioner to provide such supervision through real-time audio and visual interactive telecommunications. CMS specifically proposed that the physician or supervising practitioner may provide such virtual direct supervision for services furnished incident to a physician’s service when they are provided by auxiliary personnel employed by the physician and working under his or her direct supervision and for which the underlying HCPCS code has been assigned a PC/TC indicator of office or other outpatient visit for the evaluation and management of an established patient who may not require the presence of a physician or other qualified health care professional. For all other services furnished under the direct supervision of the supervising physician or other practitioner, we are proposing to continue to define “immediate availability” to include real-time audio and visual interactive telecommunications technology only through December 31, 2025.

CMS proposed to continue our current policy to allow teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in all teaching settings, but only in clinical instances when the service is furnished virtually (for example, a three-way telehealth visit, with the patient, resident, and teaching physician all parties in separate locations) through December 31, 2025. This virtual presence will continue to meet the requirement that the teaching physician be present for the key portion of the service. We are also requesting information to help us consider whether and how best to expand the array of services included under the primary care exception in future rulemaking.

CMS transformed the working definition of “direct supervision” over the course of the public health emergency. The definition was updated in regard to supervision for the following:

• Diagnostic tests
• Physician’s services
• And certain hospital outpatient services

Always consult official sources or coding specialists for the most accurate and updated information as guidelines can change frequently.

https://ecqi.healthit.gov/sites/default/files/2025-EC-Telehealth-Guidance.pdf

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