- 55+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
CPT codes 98008–98015 are for synchronous audio-only telemedicine visits that require >10 minutes of medical discussion:
For new patients:
- 98008: requires straightforward medical decision-making or 15-29 minutes
- 98009: requires low medical decision-making or 30-44 minutes
- 98010: requires moderate medical decision-making or 45-59 minutes
- 98011: requires high medical decision-making or 60-74 minutes
- 75+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
For established patients:
- 98012: Requires straightforward medical decision-making or 10-19 minutes
- 98013: Requires low medical decision-making or 20-29 minutes
- 98014: Requires moderate medical decision-making or 30-39 minutes
- 98015: Requires high medical decision-making or 40-54 minutes
- 55+ minutes or longer, use prolonged services code 99417 (non-Medicare) or G2212 (Medicare)
For services provided by asynchronous communication, do not use codes 98000–98015. Instead, providers should report CPT code 98016: brief communication technology-based services with established patients (e.g., virtual check-in) and 5-10 minutes of medical discussion instead of MDM or time. CPT code 98016 is for established patients, at the request of the patient/caregiver, to determine if a more intensive E/M service is required. Note: CPT code 98016 cannot be reported if the problem originates from a related E/M service within the previous seven days or if the service leads to an urgent visit within 24 hours or the next available appointment.
Changes in Policies
Congress was able to extend certain telehealth flexibilities through March 31, 2025. These include:
- Removing geographic requirements and expanding originating sites for telehealth services;
- Expanding practitioners eligible to furnish telehealth services;
- Extending telehealth services for Federally Qualified Health Centers and Rural Health Clinics;
- Delaying in-person requirements under Medicare for mental health services furnished through telehealth and telecommunications technology;
- Allowing for the furnishing of audio-only telehealth services; and
- Extending use of telehealth to conduct face-to-face encounters prior to recertification.
Medicare Telemedicine Policies for CY 2025
Although the extension was passed, Medicare’s telemedicine policies continue to evolve with continuous updates, which the ACR is monitoring. Because the agency has chosen not to recognize the new telemedicine codes 98000–98015, these are not eligible for reimbursement. Instead, providers must continue to use standard E/M codes (99202–99215) along with the appropriate modifier (e.g., 95 for audio-visual, or 93 for audio-only) and place of service for most telemedicine services. Subsequently, Medicare has decided to recognize the new brief virtual check-in CPT code 98016, which will replace HCPCS Level II code G2012, set to be deleted.
