Telehealth Coding in 2025: Navigating the Complexities of Audio-Only Visits

Why Telehealth Coding Still Deserves Your Attention

Telehealth remains a core component of modern healthcare delivery, offering patients improved access and convenience, especially in rural and underserved communities. While video-based virtual visits have become commonplace, audio-only telehealth—initially introduced as a temporary measure during the COVID-19 public health emergency—has carved out a lasting role in today’s hybrid care models.

In 2025, healthcare organizations must pay close attention to how audio-only services are documented and coded. From nuanced place of service reporting to payor-specific variations in coverage, the risks are high—and so are the consequences of getting it wrong.

The Current State of Audio-Only Telehealth Coverage

Audio-only telehealth visits were made temporarily reimbursable during the pandemic to ensure continuity of care for patients without access to video technology. Over time, these flexibilities have been extended—and in some cases made permanent—by CMS through legislative action such as the Consolidated Appropriations Act.

Today, Medicare continues to reimburse audio-only services under certain conditions. These include behavioral health services, chronic care management, primary care visits, and follow-up care with established patients. However, coverage is not universal. Commercial insurers and state Medicaid programs may apply different criteria, billing codes, and documentation requirements—introducing layers of complexity for coders and billing teams.

Audio-Only Telehealth Coding: Risks and Common Pitfalls

As audio-only services become more mainstream, healthcare providers must avoid several critical errors that threaten reimbursement and compliance. Some of the key areas of risk include:

Incorrect Use of Modifiers

• Modifier 93, introduced in 2022, signals that a service was delivered via synchronous audio-only telecommunication.
• Failing to append Modifier 93, or using it on an ineligible code, is a common source of denials.

Inaccurate Place of Service (POS)

• POS 02: Telehealth provided outside the patient’s home
• POS 10: Telehealth delivered while the patient is at home
• Misreporting patient location can mislead payors and result in non-payment.

Time-Based Billing Errors

• For E/M services delivered without video, providers must document total encounter time and that >50% of the visit was spent in counseling or care coordination.
• Missing time logs or unclear documentation can disqualify the visit for reimbursement.

Payor Policy Discrepancies

• Medicare, Medicaid, and commercial payors vary in how they recognize audio-only visits.
• Coding professionals must routinely reference payor-specific telehealth policies and crosswalk them accurately.

Must-Have Documentation Elements for Audio-Only Visits

Thorough, precise documentation is non-negotiable. Providers and coders should ensure each audio-only encounter record includes:

• Patient’s location at time of service
• Provider’s location
• Clear statement that audio-only technology was used
• Clinical justification for using phone instead of video
• Chief complaint, history, assessment, and treatment plan
• Total time spent, documented in minutes
• Verbal patient consent to conduct the visit via phone
• Provider attestation confirming that no video was used

These elements not only support reimbursement but also serve as a defense against audits and potential take-backs.

Best Practices for HIM and Coding Leaders

To remain compliant and minimize audit exposure, healthcare organizations must build strong internal frameworks for telehealth billing and documentation. Here’s what you can do now:

1. Enhance EHR Functionality

Create telehealth-specific documentation templates, including time logs and drop-down menus for modality (audio vs. video).

2. Educate Providers Continuously

Offer refresher training and job aids to clinicians on documentation standards, coding guidelines, and modifier use.

3. Track Policy Changes Proactively

Assign team members to monitor payor portals, CMS updates, and state Medicaid bulletins for evolving coverage rules.

4. Audit Retrospectively

Conduct periodic reviews of billed audio-only visits to identify documentation gaps or modifier misuse.

5. Develop Internal Checklists

Build front-end and back-end compliance workflows that ensure patient location, consent, and audio-only attestation are captured.

Looking Ahead: Audio-Only Is Here to Stay—But with Rules

Audio-only telehealth visits aren’t a passing trend—they’re a permanent fixture in patient-centered care, particularly in behavioral health and chronic care management. But their long-term success depends on how well providers and coders adapt to the complexities of this evolving model.

As telehealth policies continue to shift, organizations that invest in coding accuracy, documentation excellence, and payor policy awareness will be best positioned to capture appropriate reimbursement and maintain compliance.

Need Help Navigating Telehealth Coding?

At Bristol Healthcare Services, our team of certified coding professionals specializes in telehealth billing, documentation audits, and compliance reviews. Whether you’re struggling with Modifier 93 usage or trying to keep up with multiple payor policies, we’re here to ensure your telehealth program remains sustainable and profitable.

Contact us today to streamline your telehealth revenue cycle. Or click the link to learn more about our revenue cycle management and medical billing services.