Future-Proofing Your Practice: 2025 Telemedicine Billing
Navigating the 2025-2026 Telehealth Policy Cliff and Medicare Changes
As we move through the 2025-2026 period, the biggest date on our radar is September 30, 2025. This marks the end of several COVID-era flexibilities that have defined virtual care for years. Unless Congress intervenes, we are heading toward what many in the industry call the "telehealth policy cliff."
For Medicare Fee-for-Service (FFS), the rules for how to bill telemedicine visits 2025 and 2026 change significantly on October 1. Prior to the pandemic, Medicare restricted telehealth primarily to "rural" areas, and patients had to be at an authorized "originating site" (like a clinic or hospital) rather than their own home. While many of these restrictions were paused, they are scheduled to return for non-behavioral health services this autumn.
Key shifts include:
Geographic Restrictions: The requirement that a patient reside in a rural area to receive non-mental health telehealth may be reinstated.
Originating Site vs. Distant Site: The "originating site" is where the patient is located, and the "distant site" is where we, the providers, are located. After the cliff, the patient's home may no longer qualify as an originating site for general medical visits.
Provider Eligibility: While physicians and NPs remain eligible "distant site" practitioners, therapists like PTs, OTs, and SLPs face uncertainty regarding their permanent status as telehealth providers under Medicare.
To stay updated on these shifting sands, we recommend frequently checking the Billing for telehealth | Telehealth.HHS.gov resource and reviewing the AAFP's guide on How to bill Medicare for telehealth in 2025 | AAFP.
Master the Coding: CPT, POS, and Modifiers for 2025-2026
The biggest coding shake-up in the 2025-2026 era is the American Medical Association’s (AMA) introduction of the 98000–98016 series. These codes were designed to streamline telemedicine by creating specific buckets for different technologies. However, there is a catch: Medicare has not adopted the 98000-98007 series for audio-video visits.
For Medicare, you must continue using the standard Evaluation and Management (E/M) codes (99202-99215). For commercial payers, you might need the new codes. This "dual-track" system is exactly why many practices see their denial rates spike.
Service Type Medicare Code Commercial/AMA Code Key Requirement Audio-Video (New) 99202-99205 98000-98003 Synchronous real-time interaction Audio-Video (Est.) 99211-99215 98004-98007 Synchronous real-time interaction Audio-Only (New) 99202-99205 + Mod 93 98008-98011 Min. 10 mins medical discussion Audio-Only (Est.) 99211-99215 + Mod 93 98012-98015 Min. 10 mins medical discussion Virtual Check-in 98016 98016 5-10 mins; patient-initiated
Essential CPT Codes and Modifiers for how to bill telemedicine visits 2025
When determining how to bill telemedicine visits 2025, your choice of modifiers and Place of Service (POS) codes is just as important as the CPT code itself.
POS 10: Use this when the patient is in their home. This is the most common code for modern telehealth.
POS 02: Use this when the patient is at a location other than their home (e.g., a nursing home or a rural clinic).
Modifier 95: Append this for synchronous audio-video visits (though Medicare often doesn't require it if you use POS 10/02, many private payers still do).
Modifier 93: This is the "gold standard" for audio-only visits in 2025 and 2026. Medicare allows this if the provider has video capability but the patient is unable or unwilling to use it.
Modifier FQ: Specific to FQHCs and RHCs for audio-only mental health services.
The AMA's push for these codes aims to better reflect the work involved in virtual care. You can read more about their rationale here: How the AMA meets need for new telehealth CPT codes. For a deep dive into modality-specific coding, see How to Code for Telehealth, Audio-Only, and Virtual-Digital Visits.
Payer-Specific Variations and Specialized Billing for 2025-2026
If only every payer followed the same rules! Unfortunately, how to bill telemedicine visits 2025 and 2026 depends entirely on who is cutting the check.
Medicare Advantage (MA): These plans are required to cover everything original Medicare covers, but they often offer expanded telehealth benefits. Some MA plans may accept the new 98000-series codes even if FFS Medicare doesn't. Always check the specific plan's 2025 and 2026 Evidence of Coverage.
Medicaid: This is a state-by-state patchwork. For example, some states have "payment parity" laws that require insurers to pay the same rate for telehealth as in-person visits. Others do not. In Florida, we keep a close eye on these variations to ensure our local providers aren't being underpaid.
Originating Site Facility Fee (Q3014): If a patient comes to your office to use your equipment for a telehealth visit with a specialist elsewhere, you can bill a facility fee.
2025 Payment: $31.04
2026 Payment: $31.85
For a comprehensive list of what Medicare covers permanently versus temporarily, refer to the [PDF] Telehealth FAQ Calendar Year 2025 | CMS. At National Billing, we help practices manage these payer-specific nuances to capture every dollar. Learn more about our Services.
Billing for Mental Health and Safety-Net Providers in 2025-2026
Mental health is the "exception to the rule" for many of the 2025 expirations. Medicare has permanently removed geographic restrictions for telemental health. However, there is a looming in-person mandate.
Starting in late 2025 and continuing through 2026, Medicare will require an in-person visit within six months prior to the initial telemental health service and every 12 months thereafter. There are exceptions for cases where an in-person visit would be "suboptimal" or for certain substance use disorder (SUD) treatments, but these must be documented meticulously.
FQHCs and RHCs: These providers have a special billing code, G2025, for most telehealth services. This has been extended through December 31, 2026, allowing these safety-net providers to receive a consolidated payment rate for virtual visits. For detailed instructions on RHC/FQHC billing, see the [PDF] MLN901705 - Telehealth & Remote Monitoring - CMS.
Documentation and Compliance for how to bill telemedicine visits 2025 and 2026
If it isn't documented, it didn't happen—and in the 2025-2026 period, the auditors are looking closer than ever. To successfully navigate how to bill telemedicine visits 2025, your notes must be bulletproof.
We've seen a rise in "AI-driven audits" where Medicare and private payers use algorithms to flags claims that lack specific phrasing. To protect your practice, every telehealth note should include:
Patient Consent: Explicitly state that the patient consented to a telehealth visit.
Modality: State whether it was "synchronous audio-video" or "audio-only."
Rationale for Audio-Only: If you used audio-only, document that video was available but the patient was unable or unwilling to use it.
Time Tracking: For codes leveled by time (like the new 98000 series or 98016), you must document the exact start and stop times or total duration.
Location: Note both the provider's location and the patient's location to justify the POS code.
Compliance is at the heart of what we do at National Billing. Our 100% USA-based team ensures that your documentation meets the highest HIPAA and CMS standards. Learn more about our Company-Info.
Best Practices for how to bill telemedicine visits 2025 and 2026
To maximize your revenue and minimize headaches, follow these three golden rules:
Verify Before the Visit: Don't wait until the claim is denied to find out a patient's commercial plan doesn't cover audio-only visits. Verify eligibility 24-48 hours before the appointment.
Standardize Your Templates: Create EHR templates that force providers to select the modality and confirm consent. This prevents "forgetfulness" that leads to downcoding.
Audit Yourself: Conduct a small internal audit of 10-15 telehealth claims every quarter. If you're seeing a pattern of denials, it's time to adjust your workflow.
Practices that choose us often see a 15-30% increase in revenue simply because we catch the small coding errors that internal teams miss. See why-choose-national to learn how we maintain the industry's lowest denial rates.
Frequently Asked Questions about how to bill telemedicine visits 2025 and 2026
What happens to PT, OT, and SLP provider eligibility after 2025?
Currently, Physical Therapists, Occupational Therapists, and Speech-Language Pathologists are allowed to bill Medicare for telehealth under temporary waivers. These are set to expire on September 30, 2025. Unless new legislation is passed, these providers may lose their "distant site" status for Medicare FFS in 2026, meaning they would only be reimbursed for in-person care.
Can I still bill for audio-only visits under Medicare in 2025 and 2026?
Yes, but the rules have tightened. As of January 1, 2025, and continuing through 2026, Medicare allows audio-only visits (using standard E/M codes with Modifier 93) if the provider has the capacity for video, but the patient is in their home and is either unable or unwilling to use the video component. You must document this specific reason in the medical record.
What is the 2025-2026 payment amount for the originating site facility fee (Q3014)?
For the calendar year 2025, the fee is $31.04. For 2026, it is scheduled to increase slightly to $31.85. This fee is typically billed by the facility where the patient is physically located during the telehealth encounter.
Conclusion
Mastering how to bill telemedicine visits 2025 and preparing for the 2026 landscape is no small feat. Between the AMA's new CPT codes, Medicare's refusal to adopt them, and the "policy cliff" in October 2025, the margin for error has never been thinner.
At National Billing Institute, we’ve spent over 30 years helping practices in Boca Raton and across the United States turn billing challenges into revenue opportunities. Our 100% USA-based team uses AI-automated claims processing to ensure your telehealth claims are clean the first time, leading to a 15-30% average revenue increase for our clients.
Don't let shifting regulations drain your practice's resources. Schedule a billing review with our experts today, or explore our full suite of Services to see how we can future-proof your revenue cycle.
