2025 Telehealth Updates: Key Changes in Evaluation & Management (E/M) Codes and Medicare Policies

Telehealth has been a transformative force in healthcare, expanding access to medical services across the country. However, as we move into 2025, the landscape of telehealth is undergoing significant changes. With the expiration of COVID-19 public health emergency waivers and new policy decisions from the Centers for Medicare & Medicaid Services (CMS), providers must stay informed to ensure compliance and proper reimbursement.

End of Public Health Emergency Waivers and Medicare Policy Shifts

The temporary waivers that expanded Medicare Part B telehealth services during the COVID-19 public health emergency ended in May 2023. Congress granted an extension through the Consolidated Appropriations Act, 2023, but this extension ends on December 31, 2024.

Healthcare providers and industry stakeholders have been eagerly awaiting CMS's stance on the future of telehealth, which was clarified in the 2025 Physician Fee Schedule (PFS) final rule, released on November 1, 2024. Unless Congress acts, these changes will take effect January 1, 2025.

Key Telehealth Policy Changes in the 2025 PFS Final Rule

1. Deletion of Telephone E/M Codes

CMS acknowledges the CPT® Editorial Panel’s decision to delete the audio-only telephone E/M codes 99441-99443 for 2025. These codes, which covered telephone-based medical discussions, will no longer be available.

2. Medicare’s Non-Recognition of Most 2025 Telehealth CPT® Codes

Despite the introduction of new synchronous audio-video and audio-only telehealth codes (98000-98016), Medicare will not recognize 16 of the 17 new CPT® codes. Specifically:

• CPT® codes 98000-98015 will have an "I" (Invalid) status for Medicare reimbursement.
• Only CPT® code 98016 will be reimbursed separately as a brief virtual check-in, replacing HCPCS Level II code G2012, which is being eliminated due to redundancy.

3. Continuation of Direct Supervision via Telehealth

CMS will continue to allow direct supervision through real-time audio-visual telecommunications (not audio-only) for qualifying services. This is a significant decision for providers offering telehealth services requiring real-time physician supervision.

4. Permanent Telehealth Coverage for Certain Behavioral and Mental Health Services

Beginning January 1, 2025, certain behavioral and mental health services will be permanently available under Medicare's telehealth coverage. Providers should refer to CMS’s List of Telehealth Services (to be updated) to determine which services remain covered.

5. Place of Service (POS) Code Designations

Medicare will continue using two telehealth-specific POS codes:

• POS 02 – Patient not in their home when telehealth services are provided.
• POS 10 – Patient in their home when telehealth services are provided (continues to be paid at the non-facility rate).

6. Provider Address Requirements for Telehealth

Physicians providing telehealth services from their home can continue listing their practice address on Medicare claims instead of their home address. This reduces administrative burden and enhances privacy.

7. Reinstatement of Pre-Pandemic Geographic and Location Restrictions

One of the most significant policy rollbacks is the reinstatement of pre-pandemic telehealth geographic and location restrictions:

• Medicare will only cover telehealth services if the patient is located in a:
  
  • Health Professional Shortage Area (HPSA)
  • Rural census track
  • County outside a metropolitan statistical area

This means that unless a Medicare patient meets these geographic criteria, telehealth services will not be covered.

8. Teaching Physician Virtual Presence Allowed Until Dec. 31, 2025

Teaching physicians can continue participating virtually in medical education only for Medicare-covered telehealth services until December 31, 2025.

New E/M Codes for Telehealth in 2025

1. Synchronous Audio-Video E/M Visits

For synchronous real-time audio-video encounters, providers will use the following new codes, based on medical decision-making (MDM) and total time spent.

New Patient Audio-Video E/M Codes

• 98000 – Straightforward MDM / 15 minutes
• 98001 – Low MDM / 30 minutes
• 98002 – Moderate MDM / 45 minutes
• 98003 – High MDM / 60 minutes

Established Patient Audio-Video E/M Codes

• 98004 – Straightforward MDM / 10 minutes
• 98005 – Low MDM / 20 minutes
• 98006 – Moderate MDM / 30 minutes
• 98007 – High MDM / 40 minutes

2. Synchronous Audio-Only E/M Visits

For telephone-based audio-only visits, providers will use these new E/M codes:

New Patient Audio-Only E/M Codes

• 98008 – Straightforward MDM / 15 minutes
• 98009 – Low MDM / 30 minutes
• 98010 – Moderate MDM / 45 minutes
• 98011 – High MDM / 60 minutes

Established Patient Audio-Only E/M Codes

• 98012 – Straightforward MDM / 10 minutes
• 98013 – Low MDM / 20 minutes
• 98014 – Moderate MDM / 30 minutes
• 98015 – High MDM / 40 minutes

However, since Medicare will not recognize 16 of these 17 codes (except 98016), private payers' adoption of these codes will be a key factor in their utility.

Congress Could Still Change the Future of Telehealth

While CMS has set these policies in stone for 2025, Congress still has until the end of 2024 to amend the geographic location restrictions for Medicare telehealth services. If no legislative action is taken, more than 85% of Medicare telehealth visits could become ineligible for payment starting January 1, 2025.

The Telehealth Modernization Act of 2024, which aims to remove geographic restrictions and permanently expand telehealth access, remains stalled in Congress as of September 18, 2024. Unless lawmakers act soon, providers and patients could face major disruptions in telehealth accessibility.

What Can You Do?

Healthcare professionals and telehealth advocates are urged to contact their local representatives to push for legislative action. If Congress does not act, Medicare telehealth services could be significantly reduced in 2025, limiting access for millions of patients.

Final Thoughts: Navigating the 2025 Telehealth Landscape

The 2025 updates bring both opportunities and challenges for healthcare providers utilizing telehealth. While some behavioral and mental health services will be permanently covered, Medicare’s decision not to recognize most new telehealth E/M codes and the return of geographic restrictions pose serious concerns.

To ensure a smooth transition, providers should:

✔ Stay updated on telehealth policies
✔ Monitor CMS’s final List of Telehealth Services
✔ Advocate for legislative changes to expand access