The telehealth landscape has undergone rapid transformation in recent years, driven by technological advancements and the global shift toward virtual care. As we move into 2025, telehealth billing continues to evolve, bringing significant changes that healthcare providers must navigate to stay compliant and maximize reimbursement. From new coding requirements to updated place of service guidelines, understanding these updates is critical for success.
This comprehensive guide will walk you through the key changes in telehealth billing for 2025, offering actionable insights to help you adapt and thrive in this dynamic environment.
Major Changes Taking Effect in 2025
1. Audio-Only Services Transition
One of the most notable changes in 2025 is the elimination of traditional audio-only telephone services codes (99441-99443) by the Centers for Medicare & Medicaid Services (CMS). This marks a significant shift in how audio-only services are billed. Providers must now ensure they are using the appropriate codes for audio-only encounters, as these services will no longer fall under the previous coding structure.
2. New Telehealth Code Status
CMS has introduced seventeen new telehealth CPT® codes (98000-98016) for 2025. However, only one of these codes (98016) will be recognized by Medicare. The remaining codes (98000-98015) will be invalid for Medicare billing, though they may still be accepted by other payers. Providers must carefully verify payer-specific requirements to avoid claim denials.
3. Behavioral Health Services Expansion
In a positive development for mental health providers, Medicare has permanently added select behavioral and mental health services to its telehealth coverage, effective January 1, 2025. This expansion reflects the growing recognition of telehealth’s role in improving access to behavioral health care.
Understanding Place of Service (POS) Codes
Accurate POS coding remains a cornerstone of telehealth billing. Here’s what you need to know:
- POS 02: Use this code when providing telehealth services to patients outside their homes.
- POS 10: Apply this code for services delivered to patients in their homes. Note that this code continues to receive non-facility payment rates.
Proper use of POS codes ensures accurate reimbursement and compliance with payer requirements.
Geographic Requirements Return
The temporary pandemic-era flexibilities that allowed telehealth services to be provided to patients regardless of location are ending. In 2025, telehealth coverage will once again be limited to patients in:
- Health professional shortage areas
- Rural census tracts
- Counties outside metropolitan statistical areas
Providers must verify patient eligibility and location before delivering telehealth services to avoid claim denials.
Coding Guidelines for Different Visit Types
New Patient Visits (Audio-Video)
- 98000: 15+ minutes, straightforward medical decision-making (MDM)
- 98001: 30+ minutes, low complexity MDM
- 98002: 45+ minutes, moderate complexity MDM
- 98003: 60+ minutes, high complexity MDM
Established Patient Visits (Audio-Video)
- 98004: 10+ minutes, straightforward MDM
- 98005: 20+ minutes, low complexity MDM
- 98006: 30+ minutes, moderate complexity MDM
- 98007: 40+ minutes, high complexity MDM
Brief Virtual Check-Ins
- 98016: 5-10 minutes of medical discussion (replaces G2012)
These new codes reflect the varying levels of complexity and time spent during telehealth visits, ensuring accurate billing for the services provided.
Documentation Requirements
Thorough documentation is essential for successful telehealth billing. Ensure your records include:
- Medical necessity justification
- Time spent or MDM level details
- Communication method used (audio-video vs. audio-only)
- Patient location during service
Proper documentation not only supports reimbursement but also protects providers in the event of an audit.
Teaching Physician Guidelines
Teaching physicians will maintain the flexibility to provide virtual supervision through December 31, 2025. This applies across all teaching settings for Medicare telehealth services. However, proper documentation remains essential to ensure compliance.
Best Practices for Success in 2025
To navigate the evolving telehealth billing landscape, healthcare providers should adopt the following best practices:
- Verify Patient Eligibility and Location: Confirm that patients meet geographic and eligibility requirements before providing services.
- Document Thoroughly: Record time spent, MDM levels, and communication methods in detail.
- Use Appropriate POS Codes: Ensure accurate coding based on patient location.
- Stay Updated on Payer Requirements: Regularly review updates from CMS and other payers to stay compliant.
- Monitor Claim Rejections: Track denied claims to identify and address potential coding issues.
Looking Ahead
As telehealth becomes an integral part of healthcare delivery, staying current with billing requirements is more important than ever. Providers should:
- Regularly review CMS updates and guidance
- Maintain open communication with payers to clarify requirements
- Invest in staff training to ensure familiarity with new codes and guidelines
- Monitor industry trends to anticipate future changes
Conclusion
The evolution of telehealth billing in 2025 reflects the growing role of virtual care in modern healthcare. By understanding and implementing these new guidelines, healthcare providers can ensure compliance, optimize reimbursement, and continue delivering high-quality care to their patients.
Staying informed, adapting to changes, and maintaining meticulous documentation will be key to success in this dynamic environment. As telehealth continues to shape the future of healthcare, providers who embrace these updates will be well-positioned to thrive.
References:
List of Telehealth Services | CMS. (n.d.). Www.cms.gov. https://www.cms.gov/medicare/coverage/telehealth/list-services
Telehealth policy updates | Telehealth.HHS.gov. (2023, November 9). Telehealth.hhs.gov. https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates
Fletcher, T. (2024, November 8). Telehealth 2025: The Final Rule. AAPC Knowledge Center. https://www.aapc.com/blog/91584-telehealth-2025-the-final-rule/?srsltid=AfmBOooteGDsn53rd5aX2759t2IlmWfMCcoDGAHq5BRIfK0fPkMcQbKM