Telehealth coverage has been extended, but commercial insurance policies differ on coding and coverage

The Centers for Medicare & Medicaid Services (CMS) has extended telehealth flexibilities for Medicare beneficiaries through Sept. 30, 2025, ensuring continued access to virtual care services. Originally introduced during the COVID-19 pandemic, these policies have revolutionized care delivery, especially in rural and underserved areas, by removing barriers to access and expanding provider reach.

Three key updates for physicians:

• Payment parity remains in place – Medicare will continue to reimburse telehealth services at the same rate as in-person visits. This applies across a wide range of services, including chronic disease management, preventive care, and specialty consultations.
• Geographic restrictions have been lifted – All Medicare beneficiaries, regardless of location, may receive telehealth services from their home. Additionally, audio-only services remain reimbursable under specific conditions, benefiting patients without reliable broadband access.
• Provider and place of service expansion remains in place – Physicians, nurse practitioners, psychologists, and therapists can all continue to deliver care via telehealth. Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) also retain their ability to serve as telehealth providers, maintaining access for underserved populations. Furthermore, hospital-based telehealth services are still permitted, allowing hospitals to bill for care delivered remotely by their physicians—even when the patient is at home.

New codes for reporting telehealth services

The 2025 CPT update included new codes to describe telehealth services more precisely:

• 98000–98007 for synchronous audio-visual telehealth services
• 98008–98015  for synchronous audio-only telehealth
• 90816 for "virtual check-in"

 CMS did not adopt the new CPT telehealth codes (98000–98015) for Medicare billing. Instead, providers must continue to use existing evaluation and management (E/M) codes and other approved telehealth services. When reporting telehealth services, use Place of Service (POS) 10 (for patients at home) or POS 02 (for patients in other locations). Additionally, Modifier 93 must be appended to audio-only services to ensure proper identification and reimbursement.

Guidance for billing private payers

Given the variability and frequent updates to payer guidelines, physician practices are strongly encouraged to verify coverage and reporting requirements for each payer and plan with which they work.

• Elevance Health has indicated it will accept both the 2025 CPT telehealth codes and traditional outpatient E/M codes—with appropriate modifiers—for its commercial products. Note however that a final policy is pending publication. United Healthcare does not recognize the new CPT telehealth codes but will reimburse telehealth services billed with outpatient E/M codes and Modifier 95.
• Blue Cross/Blue Shield and other payers have state-specific or plan-specific policies, which may vary significantly.

Looking ahead

Telehealth has emerged as a transformative force in healthcare, improving access, continuity, and convenience for millions of patients. The extension of Medicare telehealth flexibilities through Sept. 30, 2025 solidifies virtual care as a core component of patient-centered delivery. 

The ACG, AGA, and ASGE continue to advocate for permanent telehealth expansion, urging policymakers to ensure that both access and reimbursement remain intact beyond the current expiration. Providers and practices should remain informed and engaged as this evolving care model continues to shape the future of medicine. 

If you should have additional questions, please contact:

ACG: Emily Hill  emily@codingandcompliance.com
AGA: Leslie Narramore  Lnarramore@gastro.org
ASGE: Denise Garris  denise@jdgadvisorsgroup.com

Resources:

CMS list telehealth services:   https://www.cms.gov/medicare/coverage/telehealth/list-services   
Department of HHS: https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates
National Consortium of Telehealth Resource Centers: https://telehealthresourcecenter.org/resources/the-telehealth-policy-cliff-preparing-for-october-1-2025/