- CPT 2025 added 98000-98015 (synchronous telemedicine E/M - audio-video and audio-only, new and established patient) plus 98016, a brief virtual check-in that replaces HCPCS G2012.
- The telephone E/M codes 99441-99443 were deleted effective January 1, 2025.
- Medicare did NOT adopt 98000-98015 (assigned an invalid status). For Medicare, keep using office/outpatient E/M (99202-99215) with a telehealth POS and modifier.
- Medicare does recognize the 98016 CPT code, paying it in lieu of G2012 for a brief virtual check-in.
- Append modifier 95 for audio-video and 93 for audio-only; use POS 10 (patient at home) or 02 (patient not at home). Always verify each payer's policy.
For years, telehealth E/M billing leaned on telephone codes 99441-99443 and the Medicare virtual check-in HCPCS code G2012. CPT 2025 rebuilt that landscape. The AMA introduced a dedicated telemedicine E/M family - 98000-98016 - and deleted the old telephone codes. The hard part for 2026 is not the codes themselves; it is that Medicare and commercial payers diverge sharply on which ones they accept.
What changed for 2025-2026
Effective January 1, 2025, CPT deleted the telephone E/M codes 99441, 99442, and 99443. In their place, the AMA created a structured telemedicine E/M section, organized by modality (audio-video vs. audio-only) and patient type (new vs. established):
- 98000-98003 - synchronous audio-video E/M, new patient (4 levels)
- 98004-98007 - synchronous audio-video E/M, established patient (4 levels)
- 98008-98011 - synchronous audio-only E/M, new patient (4 levels)
- 98012-98015 - synchronous audio-only E/M, established patient (4 levels)
- 98016 - brief synchronous virtual check-in (~5-10 minutes), replacing HCPCS G2012
Code range reference table
| Code range | Modality | Patient type |
|---|---|---|
| 98000-98003 | Synchronous audio-video | New patient (4 levels) |
| 98004-98007 | Synchronous audio-video | Established patient (4 levels) |
| 98008-98011 | Synchronous audio-only | New patient (4 levels) |
| 98012-98015 | Synchronous audio-only | Established patient (4 levels) |
| 98016 | Brief virtual check-in (~5-10 min) | Established patient (replaces G2012) |
The Medicare vs. commercial divide
This is the nuance that drives most denials. Medicare did not adopt 98000-98015. In the CY2025 Physician Fee Schedule, CMS assigned these codes an invalid status (status indicator I - not valid for Medicare purposes). For Medicare telehealth E/M, you continue to bill the standard office/outpatient E/M codes (99202-99215) with the appropriate telehealth place of service and modifier.
The one exception is the 98016 CPT code. Medicare does recognize 98016 and pays it separately in lieu of G2012 for a brief virtual check-in. Many commercial payers, by contrast, are adopting the full 98000-98016 family. Because policy varies by carrier and even by plan, the operational rule is simple: verify each payer's telehealth policy before you bill.
Modifiers and place of service
- Modifier 95 - synchronous telemedicine via real-time audio and video.
- Modifier 93 - synchronous telemedicine via audio-only telecommunications.
- POS 10 - patient located in their home (telehealth); non-facility payment rate.
- POS 02 - patient located somewhere other than their home (telehealth); facility rate.
For Medicare audio-only encounters, report the office/outpatient E/M (99202-99215) with modifier 93; audio-only is generally tied to the patient being at home (POS 10). The new 98000-series already distinguishes audio-video from audio-only by code, but commercial payers may still expect the corresponding 95/93 modifier - confirm in policy.
Common denials and how to fix them
| Denial / scenario | Why it happens | Fix |
|---|---|---|
| Medicare rejects 98000-98015 | CMS assigned these codes invalid status | Rebill with standard office E/M (99202-99215) plus telehealth POS (10/02) and modifier (95/93) |
| Commercial payer denies 98000-series | That carrier/plan has not adopted the new codes | Check the payer's telehealth policy; if not recognized, bill 99202-99215 with telehealth POS/modifier |
| Audio-only service denied | Audio-only restrictions, or patient not at home (POS 02) | Confirm audio-only is covered, patient at home (POS 10), append modifier 93, document why video wasn't used |
| Wrong POS or missing modifier | POS doesn't reflect patient location, or 95/93 omitted | Match POS to patient location (10 home / 02 not home) and append 95 (audio-video) or 93 (audio-only) |
| Still billing 99441-99443 | Telephone E/M codes deleted 1/1/2025 | Replace with audio-only 98008-98015 (commercial) or 99202-99215 + modifier 93 (Medicare) |
| G2012 denied for a check-in | G2012 superseded by 98016 | Report 98016 for the brief virtual check-in (Medicare recognizes it in lieu of G2012) |
Frequently asked questions
98016 is a brief synchronous communication technology service - a virtual check-in of roughly 5 to 10 minutes for an established patient. It replaced HCPCS code G2012, and Medicare recognizes and pays 98016 in lieu of G2012.
Yes. The telephone E/M codes 99441, 99442, and 99443 were deleted effective January 1, 2025. For audio-only telehealth, use the new 98008-98015 family with commercial payers that adopted it, or office/outpatient E/M (99202-99215) with modifier 93 for Medicare.
No. Medicare did not adopt 98000-98015 and assigned them an invalid status. For Medicare telehealth E/M, continue billing 99202-99215 with the telehealth place of service and the appropriate modifier. Medicare does recognize 98016.
Use modifier 95 for audio-video and modifier 93 for audio-only synchronous telemedicine. Use POS 10 when the patient is in their home and POS 02 when the patient is located somewhere other than their home. Confirm each payer's specific requirements.
Many commercial payers are adopting the full 98000-98016 telemedicine E/M family, but adoption varies by carrier and plan. Medicare uses only 98016 and otherwise expects 99202-99215 with telehealth POS/modifier. Always verify the individual payer's telehealth policy before billing.