As of Jan. 1, rheumatology practices face significant changes regarding coding and reimbursement for telemedicine services. These include new and deleted codes in the American Medical Association (AMA) Current Procedural Terminology (CPT), updated Medicare policies and the looming expiration of temporary pandemic-related flexibilities.
The AMA has stated that the new CPT codes were created to reflect emerging healthcare needs, including services for mental health, remote patient monitoring and audio-only telemedicine visits for new and established patients. Understanding the nuances of telemedicine coding for 2025 is important to ensure compliance with CPT guidelines and prompt payment.
New & Deleted Telemedicine Codes for CY 2025
The 2025 CPT manual includes 17 new codes for audio-visual and audio-only telemedicine visits for new patients (98008–98011) and established patients (98012–98015). The newly created codes appear to expand upon the significant changes to medical decision making (MDM) and total time introduced in the revised evaluation and management (E/M) services; the time thresholds are important elements for determining which codes to report.
However, the Centers for Medicare & Medicaid Services (CMS) declined to recognize 16 of these new codes for audio-visual and audio-only telehealth, citing statutory limitations that require them to continue using the existing E/M codes for these services.
Keep in mind that commercial, self-funded and Medicare Advantage (MA) policies regarding telehealth vary, so providers and their staff should verify the most recent policies with individual plans. Similarly, because Medicaid policies are established at the state level, providers should check the local Medicaid agency and/or Medicaid Managed Care Organizations for their policies.
The key updates include:
- Beginning Jan. 1, CPT codes 99441–99443 are no longer available.
- Modifiers 93 and 95, indicating the service was provided via audio-only or audio-visual technologies, are no longer required (except for Medicare claims). The new code descriptors identify how the service was performed to streamline the coding process, eliminating the need for modifiers.
CPT codes 98000–98007 are for synchronous audio-video telemedicine visits and require a medically appropriate history and/or examination:
For new patients:
- 98000: requires straightforward medical decision-making or 15-29 minutes
- 98001: requires low medical decision-making or 30-44 minutes
- 98002: requires moderate medical decision-making or 45-59 minutes
- 98003: requires high medical decision-making or 60-74 minutes
- 75+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
For established patients:
- 98004: requires straightforward medical decision-making or 10-19 minutes
- 98005: requires low medical decision-making or 20-29 minutes
- 98006: requires moderate medical decision-making or 30-39 minutes
- 98007: requires high medical decision-making or 40-54 minutes
- 55+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
CPT codes 98008–98015 are for synchronous audio-only telemedicine visits that require >10 minutes of medical discussion:
For new patients:
- 98008: requires straightforward medical decision-making or 15-29 minutes
- 98009: requires low medical decision-making or 30-44 minutes
- 98010: requires moderate medical decision-making or 45-59 minutes
- 98011: requires high medical decision-making or 60-74 minutes
- 75+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
For established patients:
- 98012: Requires straightforward medical decision-making or 10-19 minutes
- 98013: Requires low medical decision-making or 20-29 minutes
- 98014: Requires moderate medical decision-making or 30-39 minutes
- 98015: Requires high medical decision-making or 40-54 minutes
- 55+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
For services provided by asynchronous communication, do not use codes 98000–98015. Instead, providers should report CPT code 98016: brief communication technology-based services with established patients (e.g., virtual check-in) and 5-10 minutes of medical discussion instead of MDM or time. CPT code 98016 is for established patients, at the request of the patient/caregiver, to determine if a more intensive E/M service is required. Note: CPT code 98016 cannot be reported if the problem originates from a related E/M service within the previous seven days or if the service leads to an urgent visit within 24 hours or the next available appointment.
Changes in Policies
Congress was able to extend certain telehealth flexibilities through March 31, 2025. These include:
- Removing geographic requirements and expanding originating sites for telehealth services;
- Expanding practitioners eligible to furnish telehealth services;
- Extending telehealth services for Federally Qualified Health Centers and Rural Health Clinics;
- Delaying in-person requirements under Medicare for mental health services furnished through telehealth and telecommunications technology;
- Allowing for the furnishing of audio-only telehealth services; and
- Extending use of telehealth to conduct face-to-face encounters prior to recertification.
Medicare Telemedicine Policies for CY 2025
Although the extension was passed, Medicare’s telemedicine policies continue to evolve with continuous updates, which the ACR is monitoring. Because the agency has chosen not to recognize the new telemedicine codes 98000–98015, these are not eligible for reimbursement. Instead, providers must continue to use standard E/M codes (99202–99215) along with the appropriate modifier (e.g., 95 for audio-visual, or 93 for audio-only) and place of service for most telemedicine services. Subsequently, Medicare has decided to recognize the new brief virtual check-in CPT code 98016, which will replace HCPCS Level II code G2012, set to be deleted.
The remaining 16 new telemedicine CPT codes will appear on the Medicare Physician Fee Schedule with a status indicator of I, which means they will not be covered codes for Medicare beneficiaries. This does not mean the codes are inactive or invalid; Medicare has indicated that it has G codes that represent the services for CPT codes 98000–98015, making it unnecessary to cover both sets of codes.
Additionally, Medicare will allow use of audio-only communication technology for any telehealth service provided to a patient in their home if the physician can use an audio-video telecommunications system but the patient is unable or does not consent to use of video. The CMS has also stated the following elements will be necessary when billing for audio-only services:
- Documentation must reflect that the physician has audio-video available, but the patient preferred audio-only or was unable to use audio-video; and
- The provider must append CPT modifier 93 to services provided via audio-only.
- Federally qualified health centers and rural health centers should use modifier FQ, 93 or both where appropriate because they are identical in meaning.
When providing telemedicine services, providers should use the CPT or HCPCS code that best describes the service provided to avoid denials and payment adjustments. Contact the ACR practice management team for any questions or additional information at [email protected].
ACR Lunch & Learn Series
The ACR practice management team offers a free, tailored, one-hour lunch-and-learn series on coding and compliance to ensure billing accuracy for rheumatology services. This workshop will give hands-on training to help rheumatology practices maximize reimbursements and minimize claim denials or rejections. It will also provide key insights on navigating documentation and coding challenges.
The webinar is the latest in a series of resources developed to assist members, practices, and their staff with coding updates. To schedule a lunch-and-learn training session, contact Melesia Tillman at [email protected]. For additional questions on billing and coding for telemedicine and other E/M services contact the ACR practice management department at [email protected].
