The pre-Christmas continuous resolution passed by Congress to keep the government running for another three months failed to address the 2.83% Medicare pay cut for physicians or prior authorization reform in Medicare Advantage, but it did extend some flexibilities granted for telehealth services during the COVID-19 public health emergency.
The extensions of the telehealth flexibilities and the Acute Hospital Care at Home program, however, will only last through March.
The temporary telehealth flexibilities granted by Congress allowed the Centers for Medicare & Medicaid Services (CMS) to waive geographic limits and other restrictions on where services could be delivered and by whom were set to expire Dec. 31.
The agency, however, does have the authority to maintain or even expand some of these services.
During a presentation at the 2025 AMA CPT and RBRVS Annual Symposium, Lindsey Baldwin and Emily Yoder, the director and deputy director of the CMS Division of Practitioner Services shared details on some of the actions CMS was empowered to take to support and maintain telehealth services into 2025.
Yoder noted that the 2025 Medicare physician pay schedule’s “final rule does reflect CMS’ goal to preserve some important but limited flexibilities in our authority and expand the scope of an access to telehealth services where appropriate.”
CMS actions in the Medicare physician pay schedule include:
- Expanding the Medicare telehealth services list to include caregiver-training services on a provisional basis and HIV prep counseling.
- Continuing to suspend frequency limitations for subsequent inpatient visits, subsequent nursing facility visits and critical care consultations for 2025.
- Establishing an official definition of an “interactive telecommunication system” to permanently include two-way, real-time audio-only communication technology for any Medicare telehealth service furnished to a beneficiary in their home if the distance site physician or nonphysician practitioner is technically capable of using an interactive telecommunication system but the patient is not capable of or does not consent to the use of video technology.
- Continuing to allow physicians who deliver telehealth services from their home to Medicare beneficiaries to list the address of their enrolled practice locations instead of their home address.
- Continuing to delay an in-person visit requirement for mental telehealth services to beneficiaries in their homes until Jan. 1, 2026.
Standardizing rapid responses
The COVID-19 public health emergency sparked the need for wider use of telehealth. Physicians, health systems and payers responded quickly and positively.
But the rapid response resulted in solutions that varied from payer to payer with varying codes and modifiers being used for different services and sites of service, according to Peter Hollmann, MD, during a separate Symposium presentation.
Dr. Hollmann said there were AMA Current Procedural Terminology (CPT®) codes in existence prior to the pandemic, but were not widely used.
Like the existing federal regulations on telehealth, they were also characterized by the limits on their use.
In August 2022, a work group was formed that included members of the RVS Update Committee (RUC) and the CPT Editorial Panel to create more consistency.
Dr. Hollmann, who has chaired both panels in the past, described the workgroup’s output, which included deleting CPT telephone-only calls 99441—99443, and creating a set of telehealth codes taking advantage of current technological options.
Delivering E/M via telehealth
The new codes report services delivered via audio-visual and audio-only technology and for new and established patients.
There was another significant distinction to make.
“We felt these are E/M services, and they should look a lot like the evaluation of management services in the doctor’s office,” Dr. Hollmann said. “So we decided that they should be coded either by medical decision-making or total time on the date of the encounter.”
Different sets of codes were needed because of the uncertainty that still surrounded telehealth, he added.
“We created both audio-video codes and audio-only codes ... because it may be that some payers would recognize audio-video only but not audio,” Dr. Hollmann explained. “We really didn't know.”
The new and established patient codes recognize the different resources these types of patients require.
“Bottom line was that these are E/M services,” he said. “They're very much like office and outpatient visits—except they do require a communication-based technology.”
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Audio-only, telephone not the same
“The telephone codes in the audio-only codes are not synonymous—that's important to note,” Dr. Hollmann added.
Audio-only codes can be used for new or established patients. The telephone codes were only for established patients.
Telephone visits could only be initiated by patients. Audio-only visits can also be initiated by physicians or other nonphysician providers.
The time of a telephone visit had a cap. Audio-only visits do not, and extended service codes are available for longer visits.
The CPT telehealth codes are to describe synchronous, real-time, interactive encounters between physician and patient, and the audio-only visits are also required to include “medical discussion.”
“They're not to be used for routine communications related to previous encounters,” Dr. Hollmann explained. “Just calling up the patient and saying, ‘Your labs look great. Keep up the good work,’ that's not what these services are for. They really have to be distinct, medically necessary services.”
New codes for 2025 include:
- Synchronous audio-video: 98000—98007.
- Synchronous audio-only: 98008—98015.
- Brief synchronous communication technology service (a single five- to 10-minute medical discussion not related to a previous E/M service with the last seven days or leading to one in the next 24 hours): 98016.
The 98016 service replaces the CMS “virtual check-in” visit, which used the CMS Healthcare Common Procedure Coding System code G2012.
Dr. Hollmann noted the benefits of the new code structure for telehealth-driven discussions where complex medical decision-making took place.
“As a geriatrician, I've had family conferences discussing very serious illnesses with a patient there and it's been best to do audio-video because that way I could bring in family members from across the country,” he said. “We've had lengthy discussions, and they have been high medical decision-making and may have gone well beyond 60 minutes.”
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