Navigating E/M changes in 2025

The American Medical Association (AMA) has released a new list of Evaluation and Management [E/M] codes which is effective from January 2025. Healthcare providers must prepare for the major updates in Evaluation and Management(E/M) coding. 

These changes include the addition of new audio-video and audio-only codes for telehealth services, replacing the outdated audio-only codes 99441-99443 and others.

The Centers for Medicare & Medicaid Services (CMS) has also proposed revisions to the Physician Fee Schedule (PFS). This will impact payment models and quality reporting measures. Read this blog to learn how to get your practice set for 2025.

1. New Telehealth codes

The American Medical Association [AMA] created a new set of codes for Telehealth services. However, CMS has decided not to adopt the new codes introduced by the AMA.

For 2025, a new table has been added to the CPT code set to help distinguish telemedicine services from non-face-to-face digital services. This table provides clear guidelines on the appropriate use of codes. It is for various types of telemedicine encounters, including synchronous audio-video and audio-only visits, as well as other digital services that do not involve direct face-to-face interaction.

List of CMS rules for telehealth E&M visits:

ModalityCodeModifier appendedPlace of service
Audio-only visitsUse appropriate in-person E/M code9302[or]10
Audio-video visitsUse appropriate in-person E/M code9502[or]10

The above table shows the detailed CMS rules for telehealth E/M visits.

      • Audio-only visits: When the provider has video capabilities but the patient either does not or chooses not to use video, the correct in-person E/M code should be applied with a 93 modifier and the 02 or 10 place of service.

        • Audio/video visits: For audio/video visits, the correct in-person E&M code should be applied with a 95 modifier and the 02 or 10 place of service.

      Place of service:

      Place of Service [POS] codes will continue to feature two telehealth designations.

      POS 02- This code is used when the patient is not located in their home during the telehealth service.

      POS 10– This code is used when the patient is located in their home during the telehealth service. The non-facility rate will continue to apply to POS 10. Medicare makes sure providers are properly compensated for the extra costs involved in home-based telehealth services.

      2. Deletion of old codes

      Physicians and other healthcare professionals should be aware of the deletion of old codes. For 2025, the older telephone service codes 99441- 99443 will be deleted. It is replaced with new telemedicine codes.

      Several other Evaluation and Management(E/M) codes are deleted. This includes CPT® code 99201 through CPT® code 99205. These codes are focused on office or other outpatient visits for the evaluation and management of a new patient. It requires a medically appropriate history and/or examination and straightforward medical decision making.

      3. New codes for synchronous visits

      New telemedicine codes are included for both synchronous audio-video and audio-only visits. The changes are made to ensure that the telehealth services are properly documented and reimbursed. 

      For 2025, Medicare will not recognize 16 of the 17 newly added telehealth CPT® codes (98000-98016). The CPT® codes 98000-98015 will be marked as Invalid. Medicare will only provide separate payment for CPT® code 98016.

      Below are the updated CPT® codes for Synchronous audio-video visits and audio-only visits. These changes are made for both new and established patients.

      ModalityNew PatientsEstablished Patients
      Synchronous audio-video visitsCPT® codes (98000-98003)CPT® codes (98004-98007)
      Synchronous audio- only visitsCPT® codes (98008-98011)CPT® codes (98012-98015)

      New Patients: According to code descriptors, new patients should report 98000 through 98003 for synchronous audio-video visits and 98008 through 98011 for synchronous audio-only visits.

      Established Patients: The established patients should report 98004 through 98007 for synchronous audio-video visits and 98012 through 98015 for synchronous audio-only visits.

      CONDITIONS

      In 2025, the code descriptors for new and established patients include specific conditions that must be met for accurate coding. The code changes are based on medical decision- making or total time.

      New patients

      Synchronous Audio-video visits: [CPT® code 98000 through CPT® code 98003]

      These visits require a medically appropriate history and/or examination and straightforward to high medical decision making. The total time on the date of the encounter must meet or exceed the specified minutes for each code.

      CPT® codesLevel of medical decision makingDuration
      98000Straightforward15 minutes
      98001Low30 minutes
      98002Moderate45 minutes
      98003High60 minutes
      Synchronous Audio-only visits: [CPT® code 98008 through CPT® code 98011]
      These visits also require a medically appropriate history and/or examination, straightforward to high medical decision making, and more than 10 minutes of medical discussion. The total time on the date of the encounter must meet or exceed the specified minutes for each code.

      CPT® codesLevel of medical decision makingDuration
      98008Straightforward15 minutes
      98009Low30 minutes
      98010Moderate45 minutes
      98011High60 minutes

      Established Patients

      Synchronous Audio-video visits: [CPT® code 98004 through CPT® code 98007]

      These visits require a medically appropriate history and/or examination and straightforward to high medical decision-making. The total time on the date of the encounter must meet or exceed the specified minutes for each code.

      CPT® codesLevel of medical decision makingDuration
      98004Straightforward10 minutes
      98005Low20 minutes
      98006Moderate30 minutes
      98007High40 minutes

      Synchronous Audio-only visits: [CPT® code 98012 through CPT® code 98015]

      These visits require a medically appropriate history and/or examination, straightforward to high medical decision making, and more than 10 minutes of medical discussion. The total time on the date of the encounter must meet or exceed the specified minutes for each code.

      CPT® codesLevel of medical decision makingDuration
      98012Straightforward10 minutes
      98013Low20 minutes
      98014Moderate30 minutes
      98015High40 minutes

      Virtual check- in visits

      CPT® code 98016

      CPT® code 98016 has been introduced for virtual check -in visits. This code replaces the previous HCPCS Level II code G2012, which has been deleted due to redundancy. CPT® code 98016 is used for brief virtual check-in encounters and is intended for established patients. It is a patient-initiated service designed to evaluate whether a more extensive visit type is required, such as an office or other outpatient E/M service.

      4. Simplified Documentation

      These updates aim to reduce the documentation burden. They emphasize the medical decision-making process and the total time spent during encounters. Instead of requiring extensive documentation of history and physical exams, they focus on the importance of the decision-making process and the time spent with the patient.

      The goal is to make the coding process more efficient. This includes reducing administrative workload and ensuring accurate reimbursement for healthcare services.

      The updates to simplify documentation requirements in 2025 include:

          • Focus on Medical-Decision Making

          • Time-based coding

          • Streamlined Code Descriptors

          • Telemedicine codes

          • Elimination of Redundant codes

          • New table for Telemedicine and digital services

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