What is telemedicine billing: Telemedicine billing is the process of coding, documenting, and submitting claims for healthcare services delivered remotely through video, audio-only, or electronic communication platforms, using payer-specific rules that differ meaningfully from in-person visit billing.
What are telemedicine CPT codes: Telemedicine CPT codes are Current Procedural Terminology codes assigned by the American Medical Association to identify the modality, complexity, and duration of virtual encounters, and they must align with payer coverage policies to generate reimbursement.
What is remote patient monitoring (RPM): Remote patient monitoring is a category of telehealth where connected devices collect and transmit patient health data to providers continuously or periodically, billed under a distinct set of CPT codes separate from synchronous visit codes.
Key Takeaway: As of 2025, the AMA introduced a new telehealth-specific CPT code series in the 98000 range, replacing legacy office visit codes previously reported with telehealth modifiers for many virtual encounters. Practices that have not updated their charge capture workflows to reflect these new codes are actively leaving reimbursement on the table or generating preventable denials.
Key Takeaway: Medicare and Medicaid telehealth coverage follow fundamentally different rules. Medicare operates under national policy with specific originating site, modality, and service type restrictions, while Medicaid reimbursement varies by state and can range from near-parity with Medicare to severely limited coverage. Providers billing across both programs need separate billing logic for each.
Key Takeaway: The biggest source of telehealth claim denials in 2025 is not fraud or upcoding. It is documentation failure, specifically the failure to record the modality used, the patient’s location, the provider’s location, and whether the encounter was synchronous or asynchronous. These four data points drive coverage eligibility for virtually every telehealth payer policy in use today.
Why Telemedicine Billing Is More Complex Than It Looks
Telehealth sounds administratively straightforward. The patient connects remotely, the provider delivers care, and the claim follows the same logic as an in-person visit. That assumption is wrong, and it costs practices real money.
Telehealth billing layers on requirements that do not exist for traditional encounters. The type of technology used matters. Whether the patient was in a qualifying originating site matters. Whether the service was synchronous or asynchronous matters. The patient’s physical location at the time of service matters for both coverage eligibility and state licensure. And as of 2025, which CPT code series applies now depends on whether you are billing Medicare, a commercial payer, or Medicaid, because each may follow a different code set.
For billing teams that transitioned to telehealth quickly during the COVID-19 public health emergency and adopted temporary waiver-based workflows, the landscape has shifted underneath them. Many of the flexibilities that made telehealth billing forgiving during 2020 through 2022 have either expired or are under active payer review. Practices running claim templates built on pandemic-era rules are generating avoidable write-offs.
The providers who bill telehealth cleanly in 2025 treat it as a separate billing discipline with its own documentation checklist, its own code set, and its own payer policy review process. The ones who treat it as a simple variant of office visit billing eventually absorb the denial costs.
The 2025 CPT Code Structure for Telemedicine Visits
The AMA’s 2025 CPT updates restructured telehealth E/M visit reporting with a dedicated code set in the 98000 range. This was a significant shift. Previously, providers largely used the standard office visit E/M codes (99201 through 99215) appended with modifier 95 or GT to signal telehealth delivery. The new codes embed the modality directly into the code itself, removing the modifier dependency and allowing cleaner claim routing.
The new structure breaks into two primary categories: synchronous audio-video visits and synchronous audio-only visits. Each category is further segmented by patient type and visit complexity using medical decision-making tiers.
Synchronous Audio-Video Visit Codes (2025)
These codes apply when the provider and patient are connected in real time via a two-way audio and video platform. Documentation must confirm the video connection was active and functional throughout the encounter.
| Patient Type | MDM Complexity | Typical Duration | CPT Code |
|---|---|---|---|
| New Patient | Straightforward | 15 minutes | 98000 |
| New Patient | Low | 30 minutes | 98001 |
| New Patient | Moderate | 45 minutes | 98002 |
| New Patient | High | 60 minutes | 98003 |
| Established Patient | Straightforward | 15 minutes | 98004 |
| Established Patient | Low | 30 minutes | 98005 |
| Established Patient | Moderate | 45 minutes | 98006 |
| Established Patient | High | 60 minutes | 98007 |
Synchronous Audio-Only Visit Codes (2025)
Audio-only visits apply when video is not available or accessible, and the encounter occurs via telephone in real time. Payer acceptance of audio-only codes varies significantly. Medicare covers audio-only for certain services but applies restrictions on geographic location and patient population. Many commercial payers restrict audio-only even further.
| Patient Type | MDM Complexity | Typical Duration | CPT Code |
|---|---|---|---|
| New Patient | Straightforward | 15 minutes | 98008 |
| New Patient | Low | 30 minutes | 98009 |
| New Patient | Moderate | 45 minutes | 98010 |
| New Patient | High | 60 minutes | 98011 |
| Established Patient | Straightforward | 15 minutes | 98012 |
| Established Patient | Low | 30 minutes | 98013 |
| Established Patient | Moderate | 45 minutes | 98014 |
| Established Patient | High | 60 minutes | 98015 |
Brief Communication Technology-Based Service Code
This code covers brief virtual patient-initiated communication not associated with a recent E/M service. It applies to short advisory interactions conducted through secure patient portal messaging or other asynchronous digital channels.
| Service Type | CPT Code | Description |
|---|---|---|
| Virtual Consultation | 98016 | 5 to 10 minute discussion unrelated to a recent E/M service, patient-initiated via technology platform. |
Legacy E/M Codes Still Used in 2025
Not all payers have adopted the 98000 series. Many commercial payers and some state Medicaid programs still require legacy office visit E/M codes paired with modifiers. Practices must verify each payer’s preferred code set before setting up their telehealth charge templates. Billing the wrong series to the wrong payer produces preventable denials that are entirely administrative in origin.
| CPT Code | Patient Type | Typical Duration |
|---|---|---|
| 99211 | Established | 5 to 10 minutes |
| 99212 | Established | 10 to 19 minutes |
| 99213 | Established | 20 to 29 minutes |
| 99214 | Established | 30 to 39 minutes |
| 99204 | New Patient | 45 to 59 minutes |
Medicare Telehealth Policy in 2025: What Has Changed and What Has Not
Medicare telehealth policy has been in a prolonged transition since the COVID-19 public health emergency ended. The expanded flexibilities that allowed Medicare patients to receive telehealth from their homes, removed originating site restrictions, and permitted audio-only visits for a broader range of services were temporary. Their extension has required Congressional action, and the timeline has shifted multiple times.
As of 2025, the most recent legislative extensions under the Consolidated Appropriations Act provisions have continued many pandemic-era telehealth flexibilities through a defined period, but providers should not assume permanent availability. CMS publishes updated telehealth-covered services lists annually through the Medicare Physician Fee Schedule final rule, and that list is the definitive source for what Medicare will reimburse virtually in a given year.
Core Medicare Telehealth Requirements
- The patient must be an established or qualifying new Medicare beneficiary
- The provider must be enrolled in Medicare and licensed in the state where the patient is located at the time of service
- The service must appear on the CMS-approved telehealth services list for that calendar year
- The encounter must use an interactive audio and video communication system unless audio-only is specifically approved for that service type
- The patient’s location must be documented in the medical record
- The provider’s location must also be documented for services with location-based billing rules
- Place of service code 02 applies to most telehealth encounters; place of service 10 applies when the patient is located in their home
The place of service distinction between 02 and 10 matters for reimbursement rates. Medicare pays the facility rate for POS 02 and the non-facility rate for POS 10. Using the wrong POS code is one of the most common and financially significant telehealth billing errors in Medicare claims today.
What Medicare Does Not Cover for Telehealth
Medicare does not cover every service via telehealth simply because a provider offers it virtually. Services not on the approved list must be delivered in person or billed under different codes if an equivalent non-telehealth service applies. Billing Medicare for a telehealth service not on the approved list will result in a denial. Resubmitting without correcting the service type will not resolve it.
Mental health services under Medicare have specific telehealth requirements, including an in-person visit within six months of initiating telehealth for mental health and periodic in-person visits during the course of treatment. Practices billing behavioral health under Medicare telehealth need workflows that track and enforce this requirement, or they risk retroactive denials on established claim series.
Medicaid Telehealth Coverage: Navigating the State-by-State Reality
Medicaid telehealth coverage is not a national standard. Each state designs its own telehealth reimbursement rules within the broad framework of federal Medicaid law. This means a practice serving Medicaid patients across state lines, or a billing company supporting clients in multiple states, cannot apply a single telehealth billing template uniformly.
| Policy Dimension | Medicare | Medicaid |
|---|---|---|
| Coverage scope | Nationally uniform, CMS-controlled | State-by-state, wide variation |
| Audio-only allowance | Limited, service-specific | Varies; some states broadly allow, others prohibit |
| Originating site requirements | Extended through legislative action | Varies by state |
| Reimbursement rate relative to in-person | Typically facility rate for POS 02 | Ranges from parity to significant reduction |
| Code set accepted | New 98000 series and legacy codes per service | State-specific; may require modifier or unique code |
| Prior authorization requirements | Limited for most services | Some states require PA for telehealth services |
Practices assuming their Medicaid telehealth claims follow the same logic as their Medicare telehealth claims will generate systematic billing errors. The correct approach is to pull the current telehealth coverage bulletin for each state Medicaid program you bill, map it to your code set and documentation workflow, and update it annually at minimum. State Medicaid programs revise telehealth policies frequently, and interim policy changes between annual updates are common.
Documentation Requirements That Drive Telehealth Claims
Telehealth documentation failure is the leading cause of post-payment audits and takebacks in this service category. The clinical documentation standard for the visit complexity is the same as in-person, but telehealth adds a layer of encounter-specific elements that must appear in the record to substantiate the claim.
Required Documentation Elements for Every Telehealth Encounter
- Date and start time of the encounter
- Modality used: audio-video, audio-only, or asynchronous electronic communication
- Patient’s physical location at the time of service, including city and state
- Provider’s physical location at the time of service
- Patient consent to telehealth services, noted at least on initial encounter
- Whether the visit was a new or established patient encounter
- Medical decision-making documentation sufficient to support the level billed
- For mental health under Medicare: documentation confirming in-person visit timeline compliance
Missing even one of these elements does not necessarily mean the claim will deny on submission. Many payers process the claim initially and audit records retrospectively. When auditors find gaps in documentation, they issue recoupment demands. A single audit covering six months of telehealth encounters with incomplete documentation can generate a six-figure takebacks demand for a mid-sized practice.
Who Owns Telehealth Documentation in the Practice Workflow
Documentation ownership is where telehealth processes break down at the operational level. The front office collects demographic and consent data. The provider generates the clinical note. The billing team translates the note into a claim. When the documentation gap sits at the boundary between these roles, no single person catches it.
Practices that manage telehealth documentation well assign explicit responsibility for each required data element. The front office confirms and records patient location before the visit starts. The provider confirms their own location in the note header. The billing team reviews the completed note against a telehealth documentation checklist before claim submission. None of these steps require new technology. They require defined process ownership and consistent execution.
Common Telemedicine Billing Mistakes That Cause Denials and Audits
The following mistakes are operational in nature, not theoretical. Each one reflects a recurring pattern seen in practice-level telehealth billing reviews.
Using the Wrong Place of Service Code
Billing all telehealth encounters under POS 02 when some should use POS 10, or vice versa, is one of the most common Medicare telehealth billing errors. The distinction determines the applicable fee schedule rate. Using the facility rate (POS 02) when the patient is at home should be POS 10 means the practice is systematically underpaid. Using POS 10 when the patient is at a healthcare facility means the practice may be receiving the non-facility rate premium incorrectly, which creates audit exposure.
Not Verifying Payer-Specific Code Requirements Before Building Charge Templates
Building charge templates based on Medicare 98000 series logic and applying them uniformly across all payers generates denials from commercial carriers that still require legacy E/M codes with modifier 95. Each payer in your contract portfolio needs its own telehealth code mapping, and that mapping needs to be reviewed at least annually when payers update their telehealth policies.
Billing Audio-Only Visits Without Verifying Coverage
Audio-only telehealth coverage is inconsistent across payers, service types, and patient populations. Billing audio-only visits without first confirming that the specific payer covers the specific service via audio-only results in avoidable denials. Some payers deny at submission. Others process initially and then deny or audit retrospectively, which is harder to dispute.
Failing to Document Patient Location for Every Encounter
Patient location is not a nice-to-have data point in telehealth documentation. It is required for coverage determination, state licensure compliance, and payer audits. Providers who skip documenting patient location because it feels redundant are creating audit vulnerabilities on every encounter where it is missing.
Applying Pandemic-Era Billing Templates Without Updating Them
Billing teams that built their telehealth workflows in 2020 or 2021 under COVID-19 waiver conditions are frequently operating on expired logic. Originating site waivers, audio-only expansions, and modifier rules from the public health emergency have been modified or rescinded. Running claim templates that assume those rules still apply generates systematic errors.
Missing the In-Person Mental Health Visit Requirement Under Medicare
For behavioral health providers billing Medicare telehealth, the requirement for an in-person visit within six months of the first telehealth mental health service is a claim-level compliance obligation. Practices without a tracking system for this requirement will eventually bill a telehealth mental health visit that violates the rule and face either a denial or a recoupment demand on audit.
Telehealth Types That Require Different Billing Approaches
Not all telehealth services are coded the same way. Understanding the billing distinctions across delivery types prevents systematic miscoding.
Synchronous Telehealth
Live, real-time video or audio visits between patient and provider. This is the most common telehealth modality and the category covered by the 98000 series codes. The key documentation requirement is confirming that the technology connection was active and interactive throughout the visit.
Asynchronous Telehealth (Store-and-Forward)
Medical information is captured and transmitted electronically for later review by a provider who is not simultaneously present. This modality is covered under specific circumstances, particularly in dermatology and ophthalmology, and uses a different code set from synchronous visits. Medicare covers store-and-forward telehealth only in federal telemedicine demonstration programs and specific geographic settings as of current policy.
Remote Patient Monitoring
RPM uses connected devices to collect patient data continuously or periodically outside a clinical encounter. Billing codes for RPM (99453, 99454, 99457, 99458) are separate from visit codes and cover device setup, data collection and transmission, and provider monitoring time. RPM billing requires documentation of active monitoring engagement, patient consent, and device data review. Billing RPM codes without active provider engagement in reviewing and acting on transmitted data is a compliance risk.
Chronic Care Management and Principal Care Management via Telehealth
CCM and PCM services include care coordination that can be delivered telephonically or via electronic platforms. These are time-based codes with specific monthly thresholds and require patient consent, a comprehensive care plan, and documented clinical staff time. Telehealth delivery of CCM does not change the underlying code requirements, but it does affect how time is tracked and documented.
Telehealth and the Revenue Cycle: Impact Beyond the Claim
Telehealth billing performance affects more than individual claim outcomes. At the revenue cycle level, telehealth introduces structural challenges that ripple through patient access, eligibility verification, prior authorization, and accounts receivable management.
Eligibility and Benefits Verification for Telehealth
Standard eligibility verification confirms coverage for services. Telehealth eligibility verification must go one step further and confirm that the payer covers the specific service type via the specific modality for that patient’s plan. A patient who has active medical coverage does not automatically have telehealth coverage. Many commercial plans have telehealth benefit structures that differ by plan tier, network status, or service category. Verifying this upfront prevents remittance surprises and reduces retroactive denial volume.
Prior Authorization for Telehealth Services
Some payers require prior authorization for telehealth visits for specific service categories. Mental health services, specialty consultations, and high-complexity visits are the most commonly restricted. Practices that skip prior authorization for telehealth encounters on the assumption that virtual visits are low-acuity and always pre-approved will encounter denials that are difficult to appeal retroactively.
Accounts Receivable Follow-Up on Telehealth Denials
Telehealth denials require denial-specific follow-up logic. A denial for “service not covered via telehealth” requires a different resolution path than a denial for “documentation insufficient” or “invalid place of service.” AR teams that apply generic follow-up workflows to telehealth denials without triaging by denial reason code will extend days in AR and reduce recovery rates. Telehealth denial categories need their own work queues with staff who understand the specific resolution actions for each reason code.
What the Future of Telemedicine Means for Billing Operations
The long-term trajectory of telehealth reimbursement is toward permanence and expansion, but the short-term path is characterized by regulatory flux, payer policy divergence, and technology-driven billing complexity. Practices that build flexible, policy-aware telehealth billing operations now will absorb regulatory changes better than those operating on static templates.
Technology Convergence and Its Billing Implications
AI-assisted diagnostics delivered through telehealth platforms, wearable health devices generating RPM data streams, and integrated EHR-telehealth workflows are creating new billing scenarios that do not always fit cleanly into existing code sets. Practices adopting these technologies need to verify that the services being delivered have billable codes and covered service status with their payer mix before making technology investments.
Hybrid Care Models and Documentation Complexity
The emerging standard for many specialties is a hybrid model where patients alternate between in-person and telehealth visits. This introduces documentation complexity around visit type continuity, care plan maintenance, and the in-person visit requirements that apply to certain telehealth-delivered services under Medicare. Practices need clear protocols for documenting hybrid care episodes in a way that supports the billing for each encounter type without creating cross-contamination in the record.
Payer Contract Negotiation for Telehealth Rates
Many commercial payer contracts written before 2020 do not address telehealth reimbursement explicitly or include telehealth rates significantly below in-person rates. As telehealth becomes a permanent component of care delivery, renegotiating contract language to include explicit telehealth rate schedules, covered service lists, and modality requirements is a revenue cycle priority for practice administrators and managed care directors.
Frequently Asked Questions About Telemedicine Billing in 2025
Do I need to use the new 98000 CPT codes or can I still use 99213 and similar codes for telehealth?
It depends on your payer mix. Medicare and some commercial payers have adopted the new 98000 series for telehealth, while others still require legacy E/M codes paired with modifier 95 or GT. You must verify each payer’s current telehealth billing requirements before updating your charge templates. Using the wrong series for a given payer produces preventable denials.
What is the difference between place of service 02 and place of service 10 for telehealth?
POS 02 indicates the patient is at a telehealth site other than their home, and Medicare pays the facility rate for those encounters. POS 10 indicates the patient is at home, and Medicare pays the non-facility rate. Using the correct POS code matters both for claim processing accuracy and for receiving the correct reimbursement rate. Systematic use of the wrong POS code results in either underpayment or audit exposure.
Can I bill Medicare for audio-only telehealth visits?
Medicare covers audio-only telehealth for a defined subset of services, including certain mental health visits and some primary care services, under conditions that have been extended through legislative action. Coverage is not blanket for all services delivered by phone. You must confirm that the specific service type you are billing is on the CMS-approved audio-only telehealth list for the current year before submitting audio-only claims to Medicare.
What documentation is required to support a telehealth claim?
At minimum, your documentation must include the date and time of service, the modality used, the patient’s physical location during the encounter, the provider’s location, patient consent for telehealth, whether the patient is new or established, and sufficient medical decision-making documentation to support the level billed. Missing any of these elements creates audit exposure even if the claim processes initially.
Does Medicaid cover telehealth the same way Medicare does?
No. Medicaid telehealth coverage is state-administered and varies substantially across states. Some states have enacted broad telehealth parity laws that require commercial and Medicaid coverage of telehealth at rates equivalent to in-person services. Others impose significant restrictions on covered services, approved modalities, and reimbursement rates. You must consult the current telehealth policy for each state Medicaid program you bill independently rather than applying Medicare logic.
What is the in-person visit requirement for Medicare mental health telehealth?
Medicare requires that patients receiving mental health services via telehealth have an in-person visit with the treating provider within six months before or after the first telehealth mental health service. Ongoing telehealth mental health treatment under Medicare also requires periodic in-person visits, though CMS has published specific guidance on the frequency requirements. Practices that do not track compliance with this rule face retroactive denials on entire series of mental health telehealth claims.
Are remote patient monitoring CPT codes billed the same way as telehealth visit codes?
No. RPM uses a separate code set (99453, 99454, 99457, 99458) that covers device setup, data transmission infrastructure, and provider monitoring time on a monthly basis. These codes are distinct from synchronous visit codes and have their own documentation and coverage requirements. Mixing RPM and visit billing logic produces claim errors and can create compliance issues if provider engagement with transmitted data is not adequately documented.
What happens if I use a telehealth modifier on a claim where the payer expects the 98000 series?
The claim will likely deny for invalid procedure code or modifier combination. The resolution requires resubmission with the correct code, which is possible within timely filing limits but adds administrative burden and delays cash flow. Running the wrong code structure systematically for a payer means every telehealth claim for that payer is at risk, and the cumulative denial volume can be significant over a quarter.
Telemedicine Billing: Next Steps Checklist
- Audit your current telehealth charge templates against each payer’s 2025 telehealth billing requirements
- Confirm which payers in your mix have adopted the 98000 CPT series and which still require legacy E/M codes with modifiers
- Verify correct place of service code usage (POS 02 vs. POS 10) across your Medicare telehealth claims
- Build a payer-specific telehealth coverage matrix covering service types, modalities, and code sets
- Establish a documentation checklist that front office, clinical, and billing staff each use at their stage of the encounter workflow
- Create a telehealth-specific denial work queue with denial reason code-specific resolution actions
- Confirm that your Medicaid telehealth claims use current state-specific policy requirements, not Medicare assumptions
- Implement a tracking mechanism for Medicare mental health in-person visit compliance if you bill behavioral health telehealth
- Review your commercial payer contracts for explicit telehealth rate language and identify gaps for renegotiation
- Schedule an annual review of your telehealth billing policies aligned with the CMS physician fee schedule final rule cycle
Get Expert Support for Your Telehealth Revenue Cycle
Telehealth billing errors compound quickly. A single misconfigured charge template or documentation gap repeated across hundreds of encounters creates denial volumes and audit exposure that are difficult to recover from without dedicated support. Getting the billing structure right from the start, or auditing and correcting it now, protects both your cash flow and your compliance posture.
If your practice is managing telehealth billing in-house and encountering systematic denials, or if you are expanding your telehealth program and need to build the billing infrastructure correctly, our revenue cycle specialists can help you build a compliant, payer-specific telehealth billing workflow that holds up under audit and maximizes reimbursement recovery. Contact our team to discuss your telehealth billing needs.
