Using incorrect or non-adopted codes for telehealth can lead to claim denials, delays, often requiring resubmission or appeals. It can also trigger audit flags or recoup demands as payer increasingly analyze telehealth claims with automated systems. At the same time, correctly coded telehealth services - when aligned with payer policy - can be reimbursed at parity with in-person visits, giving practice financial viability while offering virtual care.

New code set in 2025

The American Medical Association (AMA) added a new set of telemedicine-specific evaluation and management (E/M) codes effective January 1, 2025: codes 98000–98007 for synchronous audio-video visits, and 98008–98015 for audio-only visits.
These new codes are designed to mirror the structure of in-person E/M codes, enabling billing based on medical decision-making (MDM) or total time, much like traditional office visits. 

Not all payers are on the same page

For 2025, the Centers for Medicare & Medicaid Services (CMS) has not adopted the new 98000–98015 codes. That means for traditional Medicare patients, if you submit those codes, your claims will likely be denied. Instead, telehealth for Medicare still must be billed using the standard in-person E/M codes (e.g. 99202–99215) — but with proper telehealth modifiers and place-of-service (POS) codes to reflect that the service was virtual.

Among commercial and private payers, adoption is inconsistent: some accept the new codes, others prefer the older E/M + modifier method. This makes it critical to verify payer-specific policies before submitting.

Best Practices for Clinicians & Billing Teams

1. Verify payer-specific telehealth policies before billing

Always confirm with each payer (commercial insurer, Medicaid/Medicare Advantage plan, or local admin contractor) whether they accept the new 2025 CPT codes or still require older codes + modifiers. Document which modifiers and POS codes the payer requires — and make sure your EHR/superbill pick lists reflect those rules.

2. Ensure correct modifier and place-of-service coding

For telehealth visits (audio-video), use the correct modifier (e.g., “95”) when required by the payer, and the correct POS code. For example, POS 10 when the patient is at home, POS 02 when the patient is not at home. For audio-only visits under some payers, codes may require modifier “93,” or other payer-specific rules — but note that some payers may not accept audio-only at all.

3. Align documentation with level of service (time or MDM-based)

If using new telehealth E/M codes (or even for traditional E/M codes), ensure your clinical documentation supports the level billed — whether your selection is based on medical decision-making or total time spent. 

For time-based billing (especially audio-only), document start/end times, tech used (audio-only vs video), and patient consent for telehealth — many denials stem from missing such details.

4. Maintain payer-specific billing workflows and staff training

Update your EHR/superbills/billing templates to include both the new 2025 codes and fallback codes (older E/M codes) alongside correct modifiers and POS options.

Train billing staff (or external billers) to double-check payer rules before claim submission, because a one-size-fits-all approach no longer works.

5. Treat telehealth claims with the same diligence as in-person claims

Just because service was virtual doesn’t mean billing can be casual. Thorough documentation, accurate coding, and compliance with regulations still apply — in fact, scrutiny may be higher since telehealth coding is evolving rapidly. Periodically audit your own telehealth claim history to identify trends of denials or down-coding and refine workflows accordingly.

Looking Ahead: What to Expect

As of 2025, many payers — especially private insurers — may slowly adopt the new 98000–98015 codes. Over time, broader adoption could simplify billing across modalities and reduce confusion between audio-video vs audio-only distinctions. But after the public-health emergency and temporary waivers, some regulatory flexibilities are being recalibrated (especially for audio-only visits). Practices should plan for ongoing changes.

Continued growth in hybrid care (mix of in-person + virtual visits) means practices need robust internal systems to distinguish and code each visit correctly — especially as audits ramp up.

Conclusion

Telehealth remains a powerful component of modern clinical care — but coding and billing are now more complex than ever. The 2025 introduction of new telemedicine-specific CPT codes offers potential for cleaner, more consistent billing. However, inconsistent payer adoption makes it essential for clinicians and billing teams to stay informed, verify payer policies, update documentation workflows, and train staff thoroughly.

When done right, accurate coding not only maximizes reimbursement — it also lowers the risk of denials, audits, and compliance issues.