What You Need to Know About Telemedicine CPT Codes 98000–98007

Telemedicine Coding Changes in 2025

For the billers, coders, auditors, educators, and savvy clinical folks who are familiar with Evaluation and Management (E&M) coding education tools, the tables below should look remarkably familiar. Not necessarily the codes themselves, but the layout of the History and Exam, Medical Decision Making (MDM), and Time elements of the services. They practically mirror the standard outpatient E&M service grids for codes 99202-99215. 

The tables below reflect just a handful of the 17 new telehealth codes developed by the American Medical Association (AMA) for 2025. Codes 98000-98007 cover real-time audio/video telemedicine visits distinct from other E&M services. Notably, per the AMA Sub Section Guidelines, there is no time interval required between visits to bill. 

Table 1: New Patients 

• Code also prolonged care code 99417 with 98003 for services lasting 75 minutes or more. 

Table 2: Established Patients 

• Code also prolonged care code 99417 with 98007 for services lasting 55 minutes or more. 

Inclusions and Exclusions

The 2025 AMA CPT^® code book clearly outlines inclusions and exclusions associated with this new code set. Included elements are listed as: 

1. Care initiated by patient, family, caregiver, or physician/qualified healthcare professional (QHP). 
2. Synchronous, real-time, telemedicine visit, separate from other E/M services.  
   • If another E/M service has taken place by the same specialty/subspecialty on the same day as a telemedicine visit, we are further directed to add the elements (or time) of each visit together and report as only one E&M service. 
3. Telemedicine reassessments after previous in-person E/M visits (codes 98004-98007). 

Additionally, items not covered within this code set noted in the 2025 AMA CPT^® code book as excludes notes (“not coded here” or “not included here”). These elements are: 

1. Asynchronous digital services (Ex: A MyChart message). 
2. Audio-only telemedicine (Ex: phone call). 
3. Routine communications (Ex: communicating lab results only). 
4. Chronic Care Management services (Ex: codes 99491, 99437). 
5. Principal Care Management services (Ex: codes 99424, 99425). 

Coding Based on Medical Decision Making

It is important to remember each telemedicine code corresponds to a level of medical decision making or time, based on the current CPT^® Medical Decision Making table. Both do not have to be accounted for in order to bill the level of service. Once again, similar to outpatient E/M codes 99202-99215, when based on MDM, the practitioner should consider the number and complexity of problems addressed during the encounter, the amount and complexity of data requiring review/analysis, and the risk of complications and/or morbidity or mortality associated with management of the patient.  

Coding Based on Time

Coding based on time for the new code set 98000-98007 aligns with the current guidelines for outpatient E&M services 99202-99215. Time spent can be counted toward face-to-face or non-face-to-face activities, such as ordering medications, tests, or procedures, documenting clinical information in the Electronic Health Record (EHR), care coordination, etc. In contrast, time spent arranging for the appointment, establishing a connection via a HIPAA-compliant telehealth platform, or performing other services with separate CPT^® codes cannot be counted into the total time spent in patient care for that date of service. 

Medicare

The Centers for Medicare & Medicaid Services (CMS) recognizes only 1 of the 17 telemedicine codes released by the AMA. Therefore, code set 98000-98007 cannot be billed to and reimbursed by CMS for a patient with Medicare as their only health insurer. CMS does, however, recognize telemedicine visits billed with E&M codes 99202-99215, place of service (POS) 02 or 10 and/or modifiers FQ, 95, or 93 on the claim, where appropriate. It is strongly suggested to further research current CMS telemedicine coding guidance at their website, CMS.gov, and any further instruction from the MAC that covers the geographical area your practice is located in. 

Telemedicine Coding and Compliance

In summary, telemedicine continues to evolve, with varying coding requirements and guidelines set forth by the AMA and CMS. Accurate coding based on medical decision making or time is essential for proper billing and reimbursement for this particular code set. While CMS recognizes telemedicine billing with their own specifications, practitioners must stay informed on current regulations and updates from both CMS and regional MACs to ensure compliance and optimize telemedicine practice. As telehealth becomes increasingly integral to healthcare delivery, understanding and implementing these coding guidelines is vital for providing quality patient care and maintaining efficient practice operations. 

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