The healthcare landscape has been evolving rapidly, especially since the pandemic of 2020. With the signing of H.R. 10545, telehealth services remain at the forefront of modern healthcare delivery. The American Relief Act, 2025, extends several key telehealth flexibilities through March 31, 2025. Here's a closer look at what this means for providers and patients.
Keeping Telehealth Accessible
H.R. 10545 is helping to make telehealth accessible to more people. By removing geographic restrictions, patients can receive telehealth services from the comfort of their homes, regardless of where they live. Rural or underserved communities, which often face barriers to in-person care, stand to benefit the most from these continued provisions.
Additionally, the bill allows Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to continue serving as distant sites for non-behavioral telehealth services. These facilities are vital in extending care to populations that may otherwise struggle to access specialized services.
Expanded Provider Eligibility and Service Options
The new legislation allows all Medicare-enrolled providers to offer telehealth services. This ensures that patients have access to a broader range of healthcare professionals and visit types. Providers can also continue delivering care using audio-only, an essential option for patients who may not have reliable internet access or video-capable devices.
Supporting Mental Health Through Telehealth
Mental health services are a key focus of H.R. 10545. One critical change is the delay of an in-person visit requirement for behavioral health care. Previously, Medicare beneficiaries would have needed to see their provider in person within six months of a telehealth session. This delay ensures flexibility and accessibility, especially as mental health care remains in high demand.
Preparing for the Future
These flexibilities are important and highlight planning for what comes next. After March 31, 2025, unless further legislative action is taken, telehealth policies may revert to their pre-pandemic restrictions. This would reinstate geographic and originating site limitations, reduce provider eligibility, and end reimbursement for audio-only services.
Steps for Providers and Patients
Stay Informed: Keep an eye on updates from the Centers for Medicare & Medicaid Services (CMS) and other reliable sources.
Plan: Providers and patients should be prepared to adjust if restrictions return after March 2025.
Educate Patients: Inform patients about the current state of telehealth flexibilities and any potential changes.
Communicate with Providers: Stay informed about how these changes may impact your care and what other options are available.
Looking Ahead
The DEA and HHS have also extended certain telemedicine flexibilities through December 31, 2025, particularly for prescribing controlled substances. Telehealth has a positive impact in areas such as mental health care and addiction treatment.
As we move closer to the March 2025 deadline, it seems crucial to advocate for continued telehealth access. Whether through permanent legislative changes or further extensions, the goal remains clear: ensuring that patients have the tools and support they need to access quality healthcare, even from home and remote areas.
Updated Coding
1. Deleted Phone Consultation Codes 99441 - 99443
In 2025, the previous telephone evaluation and management (E/M) codes 99441, 99442, and 99443 will no longer be used. These codes, which were for established patients, covered telephone consultations lasting between 5 and 30 minutes.
Replacement Codes: For Direct Medicare and insurance companies following Medicare guidelines, new synchronous audio-only service codes are introduced:
CPT | Technology | Patient Type | MDM (Medical Decision Making) | Time Minimum |
|---|---|---|---|---|
98008 | Audio-only | New | Straightforward plus more than 10 minutes of medical discussion | 15 minutes |
98009 | Audio-only | New | Low plus more than 10 minutes of medical discussion | 30 minutes |
98010 | Audio-only | New | Moderate plus more than 10 minutes of medical discussion | 45 minutes |
98011 | Audio-only | New | High plus more than 10 minutes of medical discussion | 60 minutes |
98012 | Audio-only | Established | Straightforward plus more than 10 minutes of medical discussion | 10 minutes |
98013 | Audio-only | Established | Low plus more than 10 minutes of medical discussion | 20 minutes |
98014 | Audio-only | Established | Moderate plus more than 10 minutes of medical discussion | 30 minutes |
98015 | Audio-only | Established | High plus more than 10 minutes of medical discussion | 40 minutes |
Note: For other commercial insurances that do not recognize these new codes, you may need to submit regular office E&M codes with modifier 93 or follow the same guidelines that followed in 2024.
2. Telehealth Billing: Changes Coming in 2025
2024 Guidelines: In 2024, telehealth services were billed with modifier 95 for Medicare and some commercial insurances. You had to submit regular office visit codes with place of service being 02 (telehealth) or 10 (remote patient monitoring), depending on the insurer's guidelines.
2025 Guidelines: The guidelines for telehealth services are getting more specific. For Direct Medicare and insurers following Medicare guidelines, here are the new synchronous audio-visual service codes:
CPT | Technology | Patient Type | MDM (Medical Decision Making) | Time Minimum |
|---|---|---|---|---|
98000 | Audio-video | New | Straightforward | 15 minutes |
98001 | Audio-video | New | Low | 30 minutes |
98002 | Audio-video | New | Moderate | 45 minutes |
98003 | Audio-video | New | High | 60 minutes |
98004 | Audio-video | Established | Straightforward | 10 minutes |
98005 | Audio-video | Established | Low | 20 minutes |
98006 | Audio-video | Established | Moderate | 30 minutes |
98007 | Audio-video | Established | High | 40 minutes |
Note: For commercial insurances that do not recognize these new telehealth codes, you may need to continue the billing methods used in 2024.
3. Deleted Code G2012: Replacement Code is 98016
The G2012 code for brief communication via technology-based services (like virtual check-ins) has been deleted. It has been replaced with CPT Code 98016 for brief virtual consultations lasting 5-10 minutes.
Key Points About CPT 98016:
Brief Communication (5-10 minutes): This code is for short, focused medical discussions via technology (like a phone call or video chat).
Technology-Based: The service is provided remotely, not in-person.
Established Patients: It only applies to patients who have been seen before; it doesn’t cover new patients.
Unrelated to Recent or Upcoming Visits: The consultation shouldn’t be connected to a visit within the last 7 days or one scheduled in the next 24 hours.
Diagnosis Billing for CPT 98016: This service is typically used for brief follow-ups or check-ins, such as discussing test results or ongoing management of a condition on established patients. For proper billing, the diagnosis should reflect the reason for the virtual consultation, such as:
Chronic Conditions: ie hypertension (I10)
Symptoms: ie cough (R05)
Test Results: ie hyperlipidemia (E78.5)
Medication Management: ie anxiety (F41.9)
Post-Surgical Follow-up: ie Z48.89 for post-operative care.
4. Revised Policy for CPT Code G2211 (2025)
Starting in 2025, CPT code G2211 has been revised to indicate the complexity of an office or outpatient evaluation and management (E/M) visit. This code is used when a visit involves managing a serious or complex condition that requires specialized knowledge and ongoing care.
Key Aspects of CPT Code G2211:
It can be billed alongside a standard E/M code, especially when the visit includes a Medicare Part B preventive service (like an annual wellness visit or vaccine administration).
The G2211 code is typically used with modifier 25 to show that the E/M service was separate from the preventive care.
Take Action Today: Enhance Your Telehealth Services with Enable Healthcare
As the landscape of telehealth continues to evolve, it's essential to stay ahead of the curve. At Enable Healthcare, we’re committed to helping healthcare providers navigate the complexities of telehealth and ensure they’re ready for the changes ahead. Whether you're looking for EHR solutions or need guidance on the latest telehealth billing updates, our team is here to support you.
Schedule a demo today to learn more about how our services can streamline your telehealth operations and keep you compliant with the latest legislation. Book a demo now to see how we can help your practice thrive in a rapidly changing healthcare environment.