Coding Beyond the Clinic: New 2025 Updates in Telehealth E/M for Dermatology Practice

 

Coding Beyond the Clinic: New 2025 Updates in Telehealth E/M for Dermatology Practice
By Susan Massick, MD, FAAD

On January 1, 2025, the AMA introduced a new set of CPT codes specific to telehealth Evaluation and Management (E/M) services. While some private insurance payers have adopted the new 98000-series telehealth codes, Medicare has declined to recognize them, instead continuing to require the use of traditional E/M codes (99202–99215) with additional telehealth modifiers.

 

Of note, key telehealth flexibilities authorized under the 2023 Consolidated Appropriations Act (CAA)—including the waiver of geographic and originating site restrictions that allow Medicare beneficiaries to receive telehealth care from home—are set to expire on September 30, 2025. Until that time, dermatologists may continue providing telehealth services to Medicare patients at home. However, after this date, Medicare is expected to reinstate the originating site requirements, meaning patients may need to be physically present at a qualifying facility (e.g., a rural clinic, physician’s office, hospital, or skilled nursing facility) for telehealth services to be reimbursed. Because not all commercial payers have adopted the new telehealth codes, be sure to confirm policies with each payer to ensure appropriate and compliant coding.

 

Synchronous Audio-Video and Audio-Only Telehealth Services

The new telehealth E/M codes 98000-98015 are designated by new vs. established patients, audio-visual vs. audio-only, and with service management based on either time spent in medical discussion or in complexity of medical decision making (MDM).

 

At present, the wRVUs between New In-person and New Audio-Video visits are equivalent, with a slight decrease in wRVUs for Audio-only visits. This may be subject to change in the future.

 

Synchronous Audio-Video Evaluation and Management (E/M) Services
New Video			Established Video
Code	MDM	Time	Code	MDM	Time
98000	SF	15	98004	SF	10
98001	Low	30	98005	Low	20
98002	Mod	45	98006	Mod	30
98003	High	60	98007	High	40
Synchronous Audio-ONLY E/M Services
New Audio-ONLY			Established Audio-ONLY
Code	MDM	Time	Code	MDM	Time
98008	SF	15	98012	SF	>10
98009	Low	30	98013	Low	20
98010	Mod	45	98014	Mod	30
98011	High	60	98015	High	40

 

Audio-Video vs. Audio-Only

·        Audio-Video telemedicine requires both synchronous audio and video providing audiovisual communication between the patient and physician. This means a real-time and interactive conversation with video visualization. Audio-Only means via telephone, without video.

o   98000-98007: Synchronous Audio-Video E/M

o   98008-98015: Synchronous Audio-Only E/M

 

·         Medicare is not adopting the new CPT telemedicine codes.

o   For Medicare patients, use traditional in-person E/M codes (e.g., New 99202–99205, Established 99212-99215) with coding guidelines based on time or MDM, modifiers based on type of telehealth platform used, and place of service.

§  modifier 95 for audio-video visits

§  modifier 93 for audio-only visits when video is not available or patient declines video.

·         NB: Medicare does not allow Audio-Only visits for new patients visits, just for established patients.

o   Place of Service Codes

§  POS 10 for home

§  POS 02  elsewhere/not at home

 

·        If you lose the video connection during an Audio-Video visit and complete the visit with Audio-Only, coding/billing is based on the type of service that the majority of the patient interaction was conducted.

o   If you can’t establish a video link for your Audio-Video telehealth, and you have to convert to an Audio-Only visit, you can only bill for an Audio-Only visit.

§  Ex: You perform a New Audio-Video visit with moderate complexity decision-making, but you lose your video connection at the end of the visit and complete by telephone, you can code as 98002 because the majority of the visit had been completed by synchronous video.

§  Ex: An established visit is scheduled as an Audio-Video, but no video link is established, and you complete the visit by Audio-Only, with moderate MDM, you code as 98014 (not 98006).

·        For commercial payers that have adopted the new CPT codes, do not use the in-person codes for new patients 99202-99205 and established patients 99212-99215 with the video modifier 95/93 for telehealth visits.

·         Telephone codes 99441-99443 have been deleted.

·        After September 30, 2025: End of flexible telehealth policies approved under CAA 2023, including the waiver of geographic and originating site restrictions for all Medicare telehealth services. When these CAA provisions expire, Medicare will require telehealth services to be conducted at designated healthcare facilities, such as a doctor’s office—no longer from home. Alternative telemedicine options are virtual check-ins or E-Visits through a secure patient portal. (See below).

 

Medical Decision Making (MDM)

·         MDM here is equivalent to E/M guidelines for in-person visits with the same four levels of decision-making: Straightforward (SF), Low Complexity, Moderate Complexity, and High Complexity. Follow current guidelines for MDM.

 

Time for Services

·        Evaluation and management services can be based on time. New Audio-Video and Audio-Only visits start at a minimum of 15 minutes vs. 10 minutes for Established Audio-Video, with increased coding levels at 15-minute increments for New and 10-minute increments for Established patients.

o   For Audio-Only established E/M services, medical discussions must last at least 10 minutes.

·        Time spent connecting to any type of virtual visit is not included— time is calculated based on the actual time spent in medical discussion. Your nursing staff should contact your patient prior to the designated telehealth appt to confirm that your patient is logged in to the secure telehealth platform and ready to talk, so you don’t waste time waiting for your patient to join. Any wait time cannot be counted toward the E/M service.

·        You must document specific duration of time spent in medical discussion, not by range of time. (ex: for a 98001 visit: New Audio-Video 98001 visit with 32 minutes of medical discussion).

·        Any encounter < 5 minutes cannot be charged and should be coded as “No Charge.”

·       These codes are not for routine correspondence with patients related to a previous encounter, such as reviewing test results or for clinical staff communication with patients.

 

Brief Synchronous Telehealth E/M, ie Virtual Check-In

·       Code 98016 is used for patient-initiated “check-ins” unrelated to a prior or upcoming visit. It applies only to your established patients. Virtual check-ins are synchronous (interactive), real-time telehealth discussions between you and your patient lasting 5-10 minutes that determine whether a more extensive evaluation is warranted.

 

E-Visit E/M Services

E-Visits are for patient-initiated medical questions and inquiries with physician and APP communication performed and recommendations provided through a secure online patient portal. To bill for an E-Visit, there must be both evaluation and management services provided to the patient.

 

E-Visit Online for Physicians/APPs
Code	Time	Patient Type
99421	>5-10 minutes	Est Only
99422	11-20 minutes	Est Only
99423	>21 minutes	Est Only

 

·        E-Visits can be done in lieu of an in-person office visit— new clinical decisions can include prescribing a new medication, adjusting a medication dosage, or ordering a test.

·        7-day period rule applies here: Do not bill an E-Visit within 7 days of a prior E/M visit for the same issue, whether in-person, synchronous video or audio, or E-visit.

·        Do not bill E-visits for

o   E-visits less than 5 minutes. Anything < 5 minutes is no charge. Minimum for 99421 is > 5 minutes.

o   Clinical staff or physician communication for reviewing test results, appointment scheduling, referral placement, and routine medication refill requests.

o   Patient questions regarding a surgical procedure within the designated global period (postoperative period dependent on type and extent of surgical procedure).

 

Conclusion

New telehealth codes for participating commercial payers for E/M services based on either medical decision making or time in medical discussion:

Audio-Visual Synchronous Visits

·         CPT codes

o   New patients 98000-98003

o   Established patients 98004-98007

Audio-Only (no video) Synchronous Visits

·         CPT Codes

o   New patients 98008-98011

o   Established patients 98012-98015

 

Medicare Audio-Visual (synchronous video) visits

·         New and Established Visits are covered

o   CPT Codes 99202-99205 for new patients, 99212-99215 (established patients)

o   Modifier 95 for real-time, two-way audio/visual communication

o   Designated Place of Service (POS 10 at home, POS 02 elsewhere)

Medicare Audio-Only

·         Established patients only

o   CPT codes 99212-99215

o   Modifier 93 (audio/telephone only); document pt declined video or did not have access to video

·         DO NOT BILL Audio-Only NEW PATIENTS visits.

 

CPT coding is constantly changing, and it is your responsibility to stay informed and to incorporate updates. Please note that these are general tips. Contact your practice compliance officer or billing specialist for specific questions pertaining to your clinic. 

 

Additional Information:

AMA: “How the AMA meets need for new telehealth CPT codes,” Feb 4, 2025: www.ama-assn.org/practice-management/cpt/how-ama-meets-need-new-telehealth-cpt-codes.

CMS: “Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule Fact Sheet,” Nov 1, 2024: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-final-rule.

CodingClarified.com: “Telemedicine/Telehealth 2025,” October 4, 2024: https://codingclarified.com/telehealth/.

Telehealth.HHS.Gov: “Telehealth policy updates.” https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates