Telemedicine is no longer a temporary solution—it has become a permanent part of healthcare delivery. Yet many organizations continue to face a challenging reality: coding guidance, payer policies, and documentation expectations don’t always align. As reimbursement rules evolve and payer scrutiny increases, even experienced coding teams can struggle to determine which telemedicine codes should be reported and when. Understanding these differences is essential to reducing denials, supporting compliance, and ensuring accurate reimbursement.
Beginning with CPT 2025, the American Medical Association introduced a new family of telemedicine Evaluation and Management (E/M) codes (98000–98016) designed specifically for virtual encounters.
The new code family includes:
- 98000–98007: Synchronous audio-video E/M services
- 98008–98015: Synchronous audio-only E/M services
- 98016: Brief synchronous communication technology-based service
Unlike the previous approach of reporting office or outpatient E/M codes with telehealth modifiers, codes 98000–98015 were created specifically for telemedicine encounters. The audio-video and audio-only code families include options for both new and established patients, with code selection based on either medical decision making (MDM) or total time on the date of the encounter.
Code 98016 represents a brief, 5- to 10-minute medical discussion with an established patient that does not originate from a related E/M service provided within the previous seven days and does not result in an E/M service or procedure within the next 24 hours (or the soonest available appointment). This code replaced HCPCS code G2012 within the CPT code set.
An important distinction is that CPT guidance does not always match Medicare payment policy. While the AMA established codes 98000–98015 for telemedicine beginning in 2025, CMS generally did not adopt these codes for Medicare reimbursement. Instead, Medicare typically continues to require the applicable in-person E/M codes reported with the appropriate telehealth modifiers and place-of-service guidance. CMS did, however, adopt CPT code 98016 in place of G2012. Commercial payer policies may vary, making payer-specific verification an important step before billing telemedicine services.
As virtual care continues to expand, organizations should ensure providers, coders, and billing teams understand both the documentation requirements and the payer-specific reporting expectations. Accurate code selection depends on the technology used, patient status, the level of MDM or total time, and the individual payer’s reimbursement policies.
Keeping pace with these changes doesn’t have to be overwhelming. BCA, Inc. partners with healthcare organizations through coding audits, provider and staff education, and consulting services that help identify compliance risks, strengthen documentation practices, and improve coding accuracy. Whether you’re validating your current telemedicine processes or preparing your team for future changes, we’re here to help you build confidence in your coding and compliance program.
Schedule a consultation with one of our experts.