2025 CPT® Telemedicine Coding Overhaul: What You Need to Know

The American Medical Association (AMA) is responding to the evolving nature of healthcare delivery by introducing a new set of CPT® codes (98000–98016) for telemedicine services, effective January 1, 2025. These updates aim to streamline the reporting of evaluation and management (E/M) services delivered via telehealth—whether through synchronous audio-video or audio-only communication.

While this expansion modernizes coding for virtual care, providers need to navigate key complexities, particularly regarding Medicare reimbursement, which is limited to just one of these new codes.

Let’s explore what’s new, what’s billable, and how to document services properly to ensure accurate reimbursement and compliance.

Introducing the New Telehealth E/M Codes

Previously, providers relied on standard E/M office visit codes with modifiers or telephone visit codes (99441–99443) to report virtual care. Starting in 2025, CPT® codes 98000–98015 will replace that fragmented system, introducing structured codes based on communication modality and patient status.

Audio-Video E/M Services (98000–98007)

These codes represent E/M services delivered via real-time, interactive audio-video technology and are split by patient type:

New Patients: 98000–98003

Established Patients: 98004–98007

Code selection can be based on either total time spent on the date of service or medical decision making (MDM). For example:

98003 requires 60+ minutes total time.

Prolonged service codes like 99417 can be added in 15-minute increments when exceeding designated time thresholds (e.g., use 99417 with 98003 at 75 minutes).

Important: When using time-based coding, include all provider-performed face-to-face and non-face-to-face activities (e.g., test review, documentation, provider-to-provider communication). Exclude travel, separately reported services, and general teaching.

MDM-based selection must align with the guidelines provided in Table 1: Levels of Medical Decision Making (CPT® 2025), which range from straightforward to high complexity.

Rules for Use: Audio-Video Services

To use the new telehealth E/M codes, services must:

Be medically appropriate substitutes for in-person visits.

Not be used for routine updates (like delivering lab results).

Be conducted on a separate calendar day from any in-person E/M visit.

Tip: If a video connection fails mid-visit and the rest of the encounter is audio-only, report the code based on the communication mode used for the majority of the visit.

Audio-Only Telemedicine Services (98008–98015)

Replacing the deleted 99441–99443 codes, the new audio-only E/M codes cover telephonic care that lasts 10 minutes or more and are also separated by patient status:

New Patients: 98008–98011

Established Patients: 98012–98015

As with audio-video services, code selection may be based on either time or MDM. If the medical discussion is less than 10 minutes, consider using code 98016 (discussed below).

Tip: These codes cannot be used for asynchronous communications or for staff-driven chronic care or principal care management (e.g., 99491, 99424). For online digital services, use codes 99421–99423.

Virtual Check-Ins: New Code 98016

CPT® code 98016 is designated for brief technology-based communications, often called virtual check-ins, initiated by established patients. This service typically helps determine whether a more comprehensive E/M service is needed.

Time requirement: 5–10 minutes

If a full E/M visit occurs on the same day and is time-based, providers may add the virtual check-in time to the total.

Note: CMS does reimburse for 98016, unlike the other new codes (98000–98015), which are currently non-covered under Medicare.

Medicare Limitations and Workarounds

In its 2025 Physician Fee Schedule Final Rule, CMS did not adopt CPT® codes 98000–98015. These have been assigned a status indicator "I", meaning they are not valid for Medicare billing.

Instead, Medicare instructs providers to:

Use standard E/M codes (99202–99215) for audio-video or audio-only visits.

Append modifier 93 to indicate audio-only service, and apply POS 10 when the patient is at home.

Clearly document why video was not feasible (e.g., patient lacked access or declined video).

Medicare reimbursement for audio-only services does not apply when the patient is in a facility or non-home setting (POS 02).

Documentation Essentials for Telemedicine E/M

To ensure accurate reporting and compliance, every telemedicine encounter should be thoroughly documented. Records must include:

Patient status (new or established)

Patient consent

Telehealth platform used

Locations of patient and provider

Names of others present during the visit (if applicable)

Time spent, if coding by time

Activities performed

Tip: When using MDM as the code selection basis, use precise descriptors—such as "acute" or "chronic"—and note any tests, data reviews, or coordination of care.

Final Takeaway

The 2025 updates to CPT® telemedicine codes reflect the growing demand for virtual care. While these changes simplify reporting, complexities around payer acceptance—especially Medicare—require vigilance. Providers must stay informed, use correct modifiers and POS codes, and adhere to precise documentation standards to ensure appropriate reimbursement and avoid denials.

Ready to Master the 2025 CPT® Telemedicine Updates?

Our certified medical coders stay on top of evolving guidelines so you don’t have to. At Bristol Healthcare Services, we help practices:

Accurately apply the latest CPT®, HCPCS, and ICD-10 codes

Stay compliant with Medicare’s ever-changing rules

Reduce denials and maximize reimbursement for telehealth and in-person care alike

Let our experts handle the coding—so you can focus on care.

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