December-January 2025
The South Central Region Virtual Visit Billing Guides have been updated with the most recent payor changes. Below is this quarter's most recent updates, or click on any state to go directly to that state's guide.
The quarterly updates for the Arkansas, Tennessee, and Mississippi Virtual Visit Billing Guides have been released! Numerous telehealth changes occurred at the end of 2024 that will significantly impact telehealth coding and billing.
The American Medical Association (AMA) added 17 new telehealth codes. CPT 98000-98007 will represent a telehealth E/M visit performed over an audio-visual connection, while CPT 98008-98015 will represent a telehealth E/M visit performed over an audio-only connection. The AMA also released CPT 98016, for a brief virtual check-in, that will replace G2012.
With the addition of the audio only telehealth E/M codes, the AMA made the decision to delete telephone E/M codes, CPT 99441-99443 due to redundancy. However, the telephone assessment and management codes for qualified non-physician health care professionals, CPT 98966–98968, will remain active.
CMS acknowledged the deletion of the telephone CPT codes 99441-99443 and accepted the replacement of the virtual check in code G2012 with 98016. However, Medicare will not recognize the newly created telehealth E/M codes, CPT 98000-98016 and 98000-98015. These codes will have an “I”, Invalid status.
In the Medicare Physician Final Rule, CMS extended what telehealth flexibilities they could, and even made some flexibilities permanent. However, absent any legislation, some flexibilities would expire at the end of 2024, such as the geographic restriction waiver, provider type extension, etc. At the last minute, Congress did vote to pass the American Relief Act of 2025, which extended the majority of current telehealth flexibilities until March 31st, 2025.
For RHCs and FQHCs, there were also several updates regarding continued flexibilities. A very significant coding/billing change occurred in regards to Care Coordination services for RHCs and FQHCs. Effective January 1st, 2025, G0511 will no longer be utilized as a blanket code for numerous Care Coordination services, rather the individual CPT code, reflective of the actual service, will be reported.
In the commercial payor arena, there were only a couple of updates. Aetna recognized the newly created audio/video E/M codes, CPT 98000-98007, but will not recognize the audio-only E/M codes, CPT 98008-98015. UHC followed suit with CMS, and will only recognize the deletion of CPT 99441-99443 and the replacement of G2012 with CPT 98016. The remaining of the commercial payors have not issued guidance on these newly developed codes yet. However, it is expected updates to their policies will be coming.
The majority of Medicaid payors, except UHC Community Plan, have not yet issued guidance on these new codes. Again, updates to their telehealth policies are expected. UHC Community Plan, similar to their commercial plan, has aligned with CMS.
See the detailed updates below and stay tuned for expected updates to policies in quarter one of 2025!
CPT/HCPCS Updates
New CPT Codes
- Synchronous Audio/Video Telehealth CPT Codes: 98000-98007
- Synchronous Audio Only CPT Codes: 98008-98015
- Virtual Check-In: CPT 98016
Deleted CPT Codes:
- Telephone CPT Codes 99441-99443
- Virtual Check-In CPT G2012- Replaced with CPT 98016
Updated CPT Descriptions:
- Telephone Services for non-physician qualified healthcare professionals: CPT 98966-98968
- E-Visits for non-physician qualified healthcare professionals: CPT 98970-98972
New HCPCS Codes:
- Interprofessional Consultations G0546-G0511
Aetna
Effective with 01/01/2025, commercial Aetna plans will recognize newly created telehealth audio/visual E/M codes, CPT 98000-98007, G0546. Aetna will also recognize the new interprofessional consultation codes, G0546- G0551.
BCBS of MS
HCPCS G0546- G0551, Interprofessional consultations, were included as codes NOT considered medically necessary and, therefore, will not be covered
UHC
- In line with CMS, UHC will not recognize CPT codes 98000-98015
- Updated the following code set lists: Telehealth Eligible Services Code List, Communication Technology-Based Services and Remote Physiologic Monitoring Eligible Code List, Telehealth Audio-Only Eligible Services Code List
BlueCare of Tennessee
- Bluecare:
- Published Telehealth Approved Code list
- POS 02 and/or 10 coverage designated within the list
- UHC Community Plan:
- CPT 98016 replaced G2012 for virtual check-in
- Published Telehealth Approved Code list
Medicare
- 2025 Medicare Telehealth List Updated:
- Added CPT 96202, 96203, 97550, 97551, 97552, G0011, G0013, G0539, G0540, G0541, G0542, G0543, G0560
- Deleted CPT 99441-99443
- American Relief Act 2025: Extends certain telehealth flexibilities for Medicare patients through March 31st, 2025:
- Originating Site & Geographic Restriction Waiver
- Allows any health care provider who is eligible to bill Medicare for covered services to continue to provide and bill for telehealth services, expanding beyond the previously limited list of eligible provider types.
- Audio only telehealth services allowed
- In person requirement for mental health services via telehealth waived
- Extension of FQHC/RHC to serve as originating site for non-behavioral/mental telehealth services
- Flexibilities That Will Expire
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- Cardiac and Pulmonary Rehabilitation: Providers will no longer receive reimbursement for cardiac and pulmonary rehabilitation services provided through telehealth to patients in their homes.
- Audio Only: Effective January 1, 2025, an interactive telecommunications system may include two-way, real-time, audio-only communication technology for any Medicare telehealth service furnished to a beneficiary in their home, if the distant site physician or practitioner is technically capable of using an interactive telecommunications system, but the patient is not capable of, or does not consent to, the use of video technology
- Supervision: Effective January 1st, 2025 CMS will permanently adopt a definition of direct supervision that allows the supervising physician or practitioner to provide such supervision via a virtual presence through real-time audio and visual interactive telecommunications.
- The supervising physician or practitioner may provide such virtual direct supervision:
- For services furnished incident to a physician or other practitioner’s professional service, when provided by auxiliary personnel employed by the billing physician or supervising practitioner and working under his or her direct supervision, and for which the underlying HCPCS code has been assigned a PC/TC indicator of “5” and services described by CPT code 99211
- For office or other outpatient visits for the evaluation and management of an established patient who may not require the presence of a physician or other qualified health care professional
- For all other services furnished incident to that require the direct supervision of the physician or other supervising practitioner, we are finalizing to continue to permit direct supervision be provided through real-time audio and visual interactive telecommunications technology only through December 31, 2025
- The supervising physician or practitioner may provide such virtual direct supervision:
- Provider Location: Through CY 2025, CMS will continue to permit distant site practitioners to use their currently enrolled practice locations instead of their home addresses when providing telehealth services from their home
- Teaching Physicians: CMS will allow teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in all teaching settings, but only in clinical instances when the service is furnished virtually (for example, a three-way telehealth visit, with the patient, resident, and teaching physician in separate locations) through December 31, 2025
- RHCs/FQHCs:
- Under the 2025 Medicare Physician Final Rule, RHCs and FQHCs can continue to bill for RHC and FQHC services furnished using telecommunication technology, including services furnished using audio-only communications technology through December 31, 2025
- Effective January 1st, 2025 RHCs and FQHCs will report the individual CPT and HCPCS codes that describe care coordination services instead of the single HCPCS code G0511
- Add on codes associated with these services will also be allowed
- CMS is allowing for a transition period of six-months, at least until July 1, 2025, to allow RHCs/FQHCs to update their billing systems
- Supervision: CMS will continue to allow direct supervision via interactive audio and video telecommunications and to extend the definition of “immediate availability” as including real-time audio and visual interactive telecommunications (excluding audio-only) through December 31, 2025
