Telehealth Billing in 2025

Telehealth has significantly impacted healthcare delivery, especially after its rapid expansion during the COVID-19 pandemic. One of its primary advantages is increased access to care for patients who may face barriers such as distance, lack of transportation, or time constraints. Virtual visits enable patients in rural areas or those with mobility challenges to consult with healthcare providers from the comfort of their homes.

Since the pandemic, telehealth has evolved, improving access to care, enhancing patient outcomes, and increasing efficiency for healthcare providers. As telehealth becomes more mainstream, it is essential to stay informed about changes in policy and billing practices, particularly updates from the Centers for Medicare & Medicaid Services (CMS) and new American Medical Association (AMA) billing codes.

CMS COVID-Era Flexibility: Extended Through September 30, 2025

During the COVID-19 pandemic, CMS introduced temporary regulatory changes to expand access to telehealth services, which were crucial for ensuring vulnerable populations received care. Since the pandemic, Congress has continued to extend these flexibilities to ensure Medicare patients maintain access to virtual care. Most recently, on March 15, 2025, Congress extended these flexibilities for Medicare until September 30, 2025. This extension allows telehealth services across state lines and eliminates the requirement for patients to visit healthcare facilities for telehealth consultations, enabling care from home.

Here are five key telehealth related elements that are part of the flexibilities:

1. The bill removes geographic and originating site restrictions, allowing patients to receive telehealth services from various locations, including their homes, regardless of where they live.
2. It expands the range of healthcare practitioners authorized to provide telehealth services.
3. Federally qualified health centers and rural health clinics will remain eligible to furnish telehealth services.
4. The legislation delays the implementation of in-person visit requirements for mental health services delivered via telehealth.
5. The bill maintains the authorization of audio-only telehealth services and extends the use of telehealth for hospice care recertification

New AMA Telemedicine Billing Codes

In 2025, the AMA introduced new telehealth billing codes to accommodate the growing role of virtual care. These codes streamline the billing process and ensure healthcare providers are fairly compensated for telehealth services. There was a total of 17 new telemedicine codes (98000 -98016) for synchronous audio-video and audio-only visits, covering both new and established patients, as well as brief communication technology-based services. The new codes can be chosen based on either time or medical decision-making (MDM).

• 98000 – 98003: Synchronous audio-video visits, new patients
• 98004 – 98007: Synchronous audio-video visits, established patients
• 98008 – 98011: Synchronous audio-only visits, new patients
• 98012 – 98015: Synchronous audio-only visits, established patients
• 98016: Patient-initiated virtual check-in (replacing G2012 for established patients)

CMS has not adopted the AMA’s telemedicine codes (98000 – 98015), except for 98016, which replaces G2012 for patient-initiated virtual check-ins. Medicare expects audio-video technology to be used unless the patient lacks video capability or declines to use it. To bill Medicare telehealth services in 2025, continue using the standard in-person Evaluation and Management (E&M) CPT codes (99202 – 99215), append modifier “95” for audio-video visits, or modifier “93” for audio-only visits, and use POS 10 when the patient is at home or POS 02 when the patient is anywhere else.

Commercial Payers and Telehealth Policies in 2025

Commercial payers are adjusting their policies to reflect the growing role of telehealth, and some are incorporating the new AMA-created billing codes. Insurers such as Aetna, Cigna, and United Healthcare have updated their existing telehealth policies. There is also an emphasis on payment parity, ensuring that telehealth services are paid at the same rate as in-person services.

However, providers should be aware of specific payer requirements and restrictions. It is important to review payer-specific policies to ensure proper reimbursement and avoid denials.

How Healthcare Providers Can Bill Telehealth in 2025

Healthcare providers must stay informed about billing for telehealth services as they continue to evolve. Here are some key recommendations:

1. Familiarize Yourself with New AMA Codes: Ensure the correct use of updated AMA billing codes to prevent errors and ensure timely reimbursement. Verify that private payers are accepting the new codes before billing.
2. Understand CMS Flexibility for Medicare: Stay up to date with CMS updates regarding telehealth coverage, especially for Medicare patients. Make sure the correct billing codes and modifiers are used.
3. Document Thoroughly: Ensure proper documentation of the visit modality (audio or video), patient condition, and duration or medical necessity for correct billing.
4. Stay Up to Date on State Regulations: Review state-specific policies for Medicaid and private payers to avoid reimbursement issues. Make sure you’re aware of state-specific licensure requirements before providing telehealth services.
5. Educate Your Staff: Regular training for your team ensures everyone understands the new codes and billing requirements, minimizing errors.

Conclusion

Telehealth in 2025 is entering a new phase, with extended CMS flexibility, updated AMA telemedicine billing codes, and evolving commercial payer policies. Providers now have more tools to offer high-quality remote care. Staying informed about billing guidelines and payer policies will help ensure compliance and proper reimbursement.

- The NORM Payer Committee

References:

Medicare: Medicare Part B Telehealth coverage

Medicare: Telehealth FAQ Calendar Year 2025

Cigna: Reimbursement Policy R31: Virtual Care

United Healthcare: 2025R0046A:Telehealth/Virtual Health Policy, Professional

Aetna:  Telemedicine and Direct Patient Contact Payment Policy

HHS: Telehealth policy updates