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An Overview of the 2025 CPT Telemedicine Guidelines

Coding

An Overview of the 2025 CPT Telemedicine Guidelines

Telemedicine has emerged as a routine component of modern healthcare delivery, enabling providers to connect with patients efficiently and effectively. The updated 2025 Current Procedural Terminology (CPT) codes reflect significant strides in formalizing and enhancing telemedicine services. This article explores the nuances of these new codes and guidelines, providing healthcare professionals with the insights needed to navigate the evolving telemedicine landscape.

 

What Are Telemedicine Services?

 

The guidelines first describe what is considered a telemedicine service. They are synchronous, real-time, interactive encounters between healthcare providers and patients using either audio-video or audio-only telecommunication technology. These services are designed to replace in-person visits when deemed medically appropriate. The guidelines also state what they are not; they are not a substitute for routine communication, such as relaying laboratory results. Instead, it serves as a viable alternative for necessary follow-ups, re-assessments, and consultations that align with the standard of in-person care.

 

Key Components of the 2025 Guidelines

 

The 2025 CPT guidelines for telemedicine services outline the requirements for accurate reporting and effective use of these services. Telemedicine encounters are categorized based on either the level of Medical Decision Making (MDM) or the total time spent with the patient on the date of the encounter, just as in-person Evaluation and Management (E/M) services. To be reported, these services must occur on a separate calendar date from any other E/M services. Additionally, telemedicine encounters can be initiated by the patient, their caregiver, or the provider, creating flexibility in how care is accessed.

 

The guidelines emphasize that telemedicine time may be aggregated, or added together, with in-person E/M services on the same day to determine the total service time, provided overlapping time is excluded.

 

Example:

 

Dr. Smith sees an established patient in the office for a scheduled in-person E/M service. During this visit, Dr. Smith spends 15 minutes discussing the patient’s chronic condition, reviewing treatment options, and adjusting the care plan. Later that day, the patient calls Dr. Smith through a telemedicine platform to clarify instructions about a newly prescribed medication and discuss additional symptoms. Dr. Smith spends another 10 minutes on this telemedicine call.

 

In this scenario, the time spent during the in-person visit (15 minutes) and the telemedicine encounter (10 minutes) can be added together for a total of 25 minutes when determining the E/M service level for the day. However, any overlapping time—such as the time spent on administrative tasks like scheduling the telemedicine visit—cannot be included in this calculation. This aggregation ensures that the total time accurately reflects the care provided across both interactions while adhering to the CPT guidelines.

 

Audio-only encounters, covered under codes 98008 through 98015, require a minimum of 10 minutes of synchronous, real-time discussion, excluding asynchronous communication like emails or text messages. These codes ensure that audio-only services remain an effective option when video technology is unavailable or unnecessary. The guidelines also clarify that time spent on administrative tasks, such as scheduling or establishing connections, is not reportable.

 

The guidelines also address connectivity issues and proper reporting. According to the guidelines, if audio-video communication is interrupted and the remainder of the service relies solely on audio, the provider should report the code reflecting the majority of the interaction time. Documentation should indicate which form (audio-only or audio-visual) dominated the encounter to support the code chosen.

 

Example:

 

Dr. Lee conducts a telemedicine visit with an established patient using audio-video communication. The encounter lasts 20 minutes, but during the visit, the video connection is lost after 15 minutes, and the remaining five minutes are completed via audio-only. Since the majority of the visit was conducted using audio-video communication, the visit is reported with code 98005, which reflects a 20-minute synchronous E/M service for an established patient. The documentation should clearly indicate the total time spent (20 minutes) and note that the majority of the visit was performed using audio-video technology, with the final portion conducted via audio-only.

 

New CPT Codes for Telemedicine

 

The new codes (98000–98016) categorize telemedicine encounters into distinct levels based on type, duration, or MDM. Audio-video telemedicine codes (98000–98007) cover E/M services provided through interactive audio-video communication. These codes are broken down into new and established patients, with the level of service determined by MDM or total time spent on the date of the encounter. Prolonged service codes may also be reported with 98003, 98007, 98011, 98015, and 98016.

 

For audio-only telemedicine, codes 98008–98015 are designed for real-time medical discussions that last a minimum of 10 minutes. These services are particularly beneficial when video technology is unavailable, enabling providers to deliver care through verbal communication alone. The codes exclude asynchronous interactions, such as text messages or emails, unless the communication is conducted through devices adapted for patients with hearing impairments.

 

Code 98016: Virtual Check-In for Established Patients

 

Code 98016 is designated for brief communication technology-based services, such as virtual check-ins, provided to established patients. This service must be patient-initiated and is specifically intended to determine whether a more extensive E/M visit, such as an in-person office visit, is necessary. Unlike other telemedicine services, video technology is not required, making it particularly useful for quick consultations conducted via telephone. The service duration is limited to 5–10 minutes of medical discussion, excluding services lasting less than five minutes. Importantly, this code cannot be reported if the check-in is related to an E/M service provided in the past seven days or leads to another E/M service or procedure within the next 24 hours (or the soonest available appointment). When a virtual check-in leads to a same-day E/M service where time is used to determine the E/M level, the time spent on the virtual check-in can be added to the total E/M time, provided all other conditions are met.

 

Example:


A patient with a history of hypertension contacts their physician, Dr. Jones, via telephone to report symptoms of dizziness and ask whether an office visit is needed. Dr. Jones spends seven minutes discussing the patient’s symptoms, asking about their blood pressure readings, and advising them to adjust their posture when taking medications. Dr. Jones determines that the patient needs a same-day office visit for further evaluation. Later that afternoon, during the in-office visit, Dr. Jones spends an additional 20 minutes assessing the patient, reviewing medications, and adjusting the treatment plan. Since the virtual check-in (seven minutes) and the in-office visit (20 minutes) occurred on the same day and time is being used to determine the E/M level, the two times can be combined for a total of 27 minutes. This allows for appropriate reporting and reflects the comprehensive care provided.

 

The Future of Telemedicine

 

As telemedicine continues to evolve, the 2025 CPT updates represent a step toward integrating these services more deeply into routine care. By establishing clear guidelines, the American Medical Association (AMA) aims to ensure that telemedicine remains a viable, efficient, and equitable healthcare option.

 

The 2025 CPT codes for telemedicine services underscore the growing importance of virtual care in today’s healthcare environment. For providers, understanding these updates is essential for compliance and optimal reimbursement. By leveraging these guidelines, practices can enhance care delivery, improve patient outcomes, and embrace the opportunities telemedicine offers.

 

Note: This article does not address payor-specific guidelines on the codes’ usage. Please check with your commercial payors to review their guidelines. CMS will not recognize 16 of the 17 new codes discussed in this article. CPT codes 98000-98015 will have a Status of “I” for invalid in the Medicare Physician Fee Schedule for 2025. Medicare will reimburse for the virtual check-in code 98016.

 

Source: Betty A. Hovey

 

Betty A. Hovey, BSHAM, CCS-P, CDIP, CPC, COC, CPMA, CPCD, CPB, CPC-I, is a nationally recognized healthcare consultant and speaker. She is an expert auditor and loves to help practices stay compliant and profitable. Betty states, "Physicians work hard for their practices and they should be paid properly for what they do."

 

Betty brings over thirty years of healthcare experience. She has worked for practices both large and small with the same intensity and attention. She has spent years on the "front lines" for practices handling medical billing, coding, claims, and denials. She has also managed practices and directed healthcare system departments. Her areas of expertise include Evaluation and Management, Primary Care, Dermatology, Plastic Surgery, Cardiology, Cardiothoracic Surgery, General Surgery, GI, E/M and procedural auditing, and ICD-10-CM.

 

chcs.consulting/

 

 

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Radiology Practices Struggle to Avoid Penalties in the Medicare Quality Payment Program:For many radiology practices, the idea of a positive payment adjustment for participation in the Medicare Quality Payment Program (QPP) has been lost.  Several factors have combined over the past few years to change the goal for radiology practices - it is now "penalty avoidance" rather than a reward for reporting quality metrics.  As outlined in Healthcare Administrative Partners' recent review of the Medicare 2024 Physician Fee Schedule Proposed Rule, the QPP requirements for successful participation are going to become even stricter.
The 2024 ICD-10-CM Updates Include New Codes for Reporting Metabolic Disorders and Insulin Resistance

Coding

The 2024 ICD-10-CM Updates Include New Codes for Reporting Metabolic Disorders and Insulin Resistance:The ICD-10-CM annual updates scheduled for implementation on October 1, 2023, include 395 new codes, 25 deleted codes, and a total of 13 revised codes. Among the newly added codes are codes that better define metabolic disorders, such as metabolic syndrome, also known as insulin resistance syndrome, dysmetabolic syndrome, hypertriglyceridemic waist, obesity syndrome, and Syndrome X. 
Understanding Gastroesophageal Reflux Disease and ICD-10-CM Coding

Coding

Understanding Gastroesophageal Reflux Disease and ICD-10-CM Coding:GERD stands for Gastroesophageal Reflux Disease, a chronic condition where stomach acid flows back into the esophagus, causing a range of symptoms, such as heartburn, regurgitation, chest pain, difficulty swallowing, and a chronic cough.
ICD-10 & Other Coding Revisions to National Coverage Determinations: October 2023 Update

Coding

ICD-10 & Other Coding Revisions to National Coverage Determinations: October 2023 Update:CR 13166 is a maintenance update of ICD-10 conversions and other coding updates specific to NCDs.
E/M Scoring Questions

Coding

E/M Scoring Questions:Evaluation and Management visits are often the "bread and butter" of an organization. Thus, correctly scoring encounters is essential to ensuring proper reimbursement. The element of "Risk" is only one of the three elements of Medical Decision Making (MDM) but understanding what is meant by all the definitions within each element is critical. 
Medical Necessity and Data Under the E/M Documentation Guidelines

Coding

Medical Necessity and Data Under the E/M Documentation Guidelines:Whenever I audit charts under the 2021 E/M Documentation Guidelines, which now apply in all places of service, I like to start by reviewing the first and third columns. The first column is Number and Complexity of the Presenting Problem, and the third column is Risk of Complications and/or Morbidity or Mortality of Patient Management.
Coding Critical Care Services in 2023

Coding

Coding Critical Care Services in 2023:Critical care services refer to the delivery of medical care to the critically ill or injured patient by a qualified physician or other qualified healthcare professional (QHP). Current Procedural Terminology (CPT) defines a critical illness or injury as one that "acutely impairs one or more vital organ systems such that there is a high probability of imminent or life-threatening deterioration in the patient's condition." 
PSQIA, PSWP, and HIPAA Compliance

Coding

PSQIA, PSWP, and HIPAA Compliance:This article addresses patient confidentiality and security related to patient safety evaluation systems, investigations, root cause analyses, and compliance to rules and regulations.  It is a basic introduction to help understand the importance of appropriately managing this type of privileged information.
ICD-10 Codes to Report Cataracts

Coding

ICD-10 Codes to Report Cataracts:Cataracts, a leading cause of vision loss in the United States, occur when the normally clear lens of the eye becomes clouded. This clouding obstructs or alters the passage of light into the eye, resulting in impaired vision. Ophthalmic surgeons perform safe and effective surgery to treat cataracts. Professional medical billing and coding companies can assist physicians with coding and claims submission tasks.
Understanding Skin Biopsy CPT Codes: A Comprehensive Guide

Coding

Understanding Skin Biopsy CPT Codes: A Comprehensive Guide:Skin biopsy plays a crucial role in the diagnosis and management of various dermatological conditions. To accurately report and bill for these procedures, healthcare providers rely on Current Procedural Terminology (CPT) codes. CPT codes are standardized numerical codes used to describe medical procedures and services. In this article, we will delve into the world of skin biopsy CPT codes. Understanding these codes can help family physicians code and bill skin biopsy procedures correctly, ensuring optimal reimbursement and proper documentation.
The Transition to ICD-11: A Major Step Forward for Global Health

Coding

The Transition to ICD-11: A Major Step Forward for Global Health:During the late 1800s, a physician from France named Jacques Bertillon was developing a method to create a consistent way of categorizing diseases. His goal was to simplify the process of monitoring and comparing mortality rates across various nations. In 1893, he released the inaugural version of the International Statistical Classification of Diseases, which is currently recognized as the International Classification of Diseases - ICD.
Overcoding: Putting a Strategic Stop to a Silent Revenue Killer

Coding

Overcoding: Putting a Strategic Stop to a Silent Revenue Killer:Overcoding is in the crosshairs as the Centers for Medicare and Medicaid Services (CMS) continues its quest to ferret out fraud and abuse and recoup improper reimbursements-a focus that returns $8 for every $1 spent on audits. There are no signs that they are letting up any time in the future, as the federal government has increased funding for audits and fraud investigations. 
Identifying the Admitting, Principal, Primary, and Secondary Diagnoses

Coding

Identifying the Admitting, Principal, Primary, and Secondary Diagnoses:Knowing how to differentiate the admitting, principal, primary, and secondary diagnoses for reporting and sequencing purposes can be intimidating and confusing. The following are some commonly asked questions related to reporting diagnoses in the facility setting. 
Combination Codes Provide Greater Detail for Complicated Conditions

Coding

Combination Codes Provide Greater Detail for Complicated Conditions:When ICD-10-CM was initially implemented, it was like watching the Discovery Channel, where new codes and guidelines seemed to appear, along with new guidelines for how to report them.
Identifying the Components of a High-Risk Evaluation and Management Service

Coding

Identifying the Components of a High-Risk Evaluation and Management Service:Since 2021, when the Office and Other Outpatient Evaluation and Management (E/M) services coding guidelines changed to require only scoring by time or medical decision making (MDM), coders, providers, and facilities have worked hard to implement changes that would facilitate correct coding through clear documentation and well-formatted templates. 
Defining Modifier 25

Coding

Defining Modifier 25:Yes! Considering the recent uproar caused by one payer's plan to implement a policy requiring prepayment review of documentation for all visits billed with 99212-99215, modifier 25, and a minor procedure, it is clear there is still a need to discuss this often-misused modifier.
Are You Properly Reporting Radiology Services?

Coding

Are You Properly Reporting Radiology Services?:It's probably not surprising that the most commonly billed imaging services are radiologic examinations of the humerus, spine, fingers, and abdomen (codes 72070, 73060, 73140, and 74019).
If a Procedure Was Not Documented, Was It Performed?

Coding

If a Procedure Was Not Documented, Was It Performed?:Most of us, if not all of us, have heard the statement, "If it isn't documented, then it wasn't performed." While I know this is often the perspective of payers, I cringe when I hear this, thinking about all the providers that I work with and the fact that it may not be a true statement that the procedure was not done.
How Can Radiology Networking Improve Your Practice?

Coding

How Can Radiology Networking Improve Your Practice?:A large metropolitan-area radiology group covers several departments within a hospital system.  They have on-site staff daily at each location to handle all modalities, including sub-specialists to be sure pediatric, neuro, and body imaging are handled with the right expertise.  
May Is Clean Air Month: Spread the Word About Air Pollution and Health

Coding

May Is Clean Air Month: Spread the Word About Air Pollution and Health:Summary: Clean Air Month in May is a nationwide campaign to encourage people to preserve the environment and make the world a more sustainable, healthy planet.
Let's Talk Prolonged Services! Did you report all of your time?

Coding

Let's Talk Prolonged Services! Did you report all of your time?:Prolonged preventive services are provided in outpatient settings and can be provided via telehealth. Annual wellness visits and the Welcome to Medicare visit include a thorough review of the patient's health and medical history. The physician performs an exam that consists of a blood pressure check, height and weight assessment, and a vision screen. Depending on the medical history information provided by the patient and the results of the physical examination, the physician orders or performs additional tests as medically necessary. 
New ICD-10-PCS procedure codes - Effective April 1, 2023

Coding

New ICD-10-PCS procedure codes - Effective April 1, 2023:To download all of the new files, go to this CMS website:  https://www.cms.gov/medicare/icd-10/2023-icd-10-pcs or see below.
2023 release of ICD-10-CM - Effective April 1, 2023

Coding

2023 release of ICD-10-CM - Effective April 1, 2023:The FY2023 ICD-10-CM codes are to be used from April 1, 2023 through September 30, 2023.  
Keys to Correct Embolization Coding: CPT® Codes 37241-37244

Coding

Keys to Correct Embolization Coding: CPT® Codes 37241-37244:It is no secret that interventional radiology is one of the most difficult specialties for coders and auditors to master.  In particular, coding correctly for embolization procedures can be tricky due to the multiple coding considerations involved. This article provides tips that will have you coding and auditing some of the most common embolization procedures like a pro! 
What's Going on With the COVID Vaccines Now?

Coding

What's Going on With the COVID Vaccines Now?:Keeping up with the changes to the COVID vaccines has certainly been a rollercoaster ride, and we now have two new twists to this exciting ride. Twist one comes from the FDA who recently pulled the emergency use authorization (EUA) for the monovalent Moderna and Pfizer-BioNTech mRNA vaccines, and instead authorized the bivalent boosters for all doses starting at age 6 months. Twist two is found in the changes taking place as part of the official end to the COVID Public Health Emergency (PHE), beginning May 11, 2023. Buckle up, and let's look at how this changes things.
Men's Health Awareness Month: Catch Prostate Cancer Early with Routine Screening

Coding

Men's Health Awareness Month: Catch Prostate Cancer Early with Routine Screening:Summary: Men's Health Awareness Month is the ideal time to spread information about preventable health problems and encourage early detection and treatment of diseases such as prostate cancer.
What Is the Impact of the 2023 Medicare Fee Schedule on Your Radiology Practice?

Coding

What Is the Impact of the 2023 Medicare Fee Schedule on Your Radiology Practice?:The Medicare Physician Fee Schedule (MPFS) was lowered for 2023 due to a cut of 2.08% in the Conversion Factor (CF) used to determine payment rates.  We reported  that the CF could have been reduced as much as 4.47% had Congress not intervened at the last minute to adjust it, along with waiving the 4% PAYGO reduction that was supposed to occur in 2023. 
Second Quarter 2023 Updates Are Different This Year

Coding

Second Quarter 2023 Updates Are Different This Year:The second quarter of 2023 is not business as usual, so it is important to pay attention to ensure that organizational processes and training take place to avoid mistakes. Not only have ICD-10-CM coding updates been added to the usual code set updates (e.g., CPT, HCPCS, ICD-10-PCS), but the end of the COVID-19 Public Health Emergency will bring about changes that will also take place during the quarter (but not on April 1, 2023).
Dermatology CPT® Codes and Tips for 2023

Coding

Dermatology CPT® Codes and Tips for 2023:Your dermatology practice performs medical and surgical services for your clients; as such, your medical billing strategy needs an understanding of both medical and surgical dermatology CPT codes.
How to Bill Mental Health Telehealth

Coding

How to Bill Mental Health Telehealth:Billing for mental health telehealth services can be challenging due to various factors. Mental health providers must navigate different payer coverage and reimbursement policies, choose the correct CPT codes and modifiers, document telehealth services properly, comply with regulations related to telehealth, and educate patients about insurance coverage.
2023 Emergency Care Physician Changes

Coding

2023 Emergency Care Physician Changes:Welcome to 2023 - so far, an interesting year.  This year, CPT made many changes to Evaluation and Management (E/M) services, including emergency care physician changes.  Emergency care CPT codes are simply a different form of E/M CPT codes.
Facility Outpatient E/M Coding

Coding

Facility Outpatient E/M Coding:Reporting outpatient E/M services in a facility setting is a little different than other outpatient services. It is important to follow payer guidance. Novitas has provided some guidance on which codes to report based on the type of service provided. They have an FAQ page that covers both emergency department (99281-99285, G0380-G0384) and clinic visits, which states the following:
Cervical Dysplasia: Risk Factors, Diagnosis, and Treatment

Coding

Cervical Dysplasia: Risk Factors, Diagnosis, and Treatment:Summary: Mild cervical dysplasia usually resolves on its own but should be monitored as it can progress to moderate or severe dysplasia, which, if not treated, could become cancerous.
Overcoming Code Denials in Healthcare

Coding

Overcoming Code Denials in Healthcare:Denial rates are rising because of numerous factors, including the increasing complexity of coding guidelines, increased workloads and staff shortage, adoption of AI and automation in payor claim reviews, increasingly sophisticated remittance processes, and more. However, taking a more granular review of your claims may help avoid significant revenue hurdles or other more serious headaches, like audits.  
Gastroenterology CPT Codes and Tips for 2023

Coding

Gastroenterology CPT Codes and Tips for 2023:Since gastroenterology practices can perform both medical and surgical services, your gastroenterology medical billing strategy has to take this into account. Billing for this specialty can be challenging, but the friendly experts at NCG want to make it simple for you to boost your healthcare revenue cycle.
Dawning of a New Era: The Sun Rises on New E/M Standards in 2023 and Beyond

Coding

Dawning of a New Era: The Sun Rises on New E/M Standards in 2023 and Beyond:Well, the time is finally here! 2023 has ushered in a new standard for how we look at evaluation and management (E/M) services. Physicians, providers, coders, auditors, educators, and compliance professionals alike are finally able to utilize much more than the "bean-counting" methods set forth by the Centers for Medicare and Medicaid Services' (CMS) 1995 and 1997 ("95" and "97") E/M guidelines.

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