There is a lot of confusion regarding billing of telehealth for Calendar Year (CY) 2025. There are new CPT codes for telehealth services, but the Centers for Medicare & Medicaid Services (CMS) is not yet recognizing most of the codes for reimbursement. Also, the American Relief Act of 2025 (HR 105450) approved by Congress at the end of 2024 extended the waiver of the geographic, site of service, and practitioner type restrictions; thereby, allowing Medicare patients in non-rural areas and in their homes, to continue to get telehealth services through March 31, 2025. This has left physician offices with questions on how to appropriately bill for telehealth services for CY 2025. Below is a summary of the information MSMS has been able to confirm from various payers to date:
- Blue Cross and Blue Shield of Michigan (BCBSM) and Blue Care Network (BCN) will reimburse procedure code range 98000 – 98011, with an effective date of January 01, 2025, this policy has been updated and each code is listed in Benefit Explainer as active and covered.
The Fee Schedule and the fee allocated to each procedure code should be published at the end of the week of January 19, 2025.
**NOTE: MSMS has asked for clarification on code range as the new codes are 98000 – 98016, and the communication received was for code range 98000 – 98011.
- Medicare has CPT codes 98000 – 98015 as an “I” status on the Medicare Fee Schedule Database (MFSDB), meaning these codes are invalid for reimbursement. CPT code 98016 is a valid code for Medicare and will receive reimbursement if billed.
Since CMS does not recognize the new CPT Telemedicine Services codes, CMS directs physicians to refer to the list of telehealth services for Calendar Year 2025 and choose the most appropriate code for the service rendered.
For audio-only services to Medicare in 2025, use the standard Evaluation and Management (E/M) CPT code for the service provided, and append modifier "93" to indicate that the service was delivered via audio-only communication technology; essentially, bill the same as an in-person visit but with the added modifier "93" to denote the audio-only nature of the encounter.
- HAP will follow Medicare guidelines and will not reimburse CPT codes 98000 – 98015 for any product line. HAP will reimburse 98016 since CMS is allowing reimbursement for this code.
- Priority Health aligns telehealth/virtual services billing guidelines with AMA, CMS and MDHHS. AMA and CMS recently released updates effective January 1, 2025. Priority Health will apply the following policies:
Priority Health will reimburse new CPT telehealth codes (98000-98016) effective January 1, 2025, for commercial plans, in addition to the regular evaluation and management (E/M) codes.
The new codes are outlined in Priority Health’s medical policy #91604 – Telemedicine / Virtual Services. Continue to follow the billing guidance available here.
Priority Health will not be reimbursing them for Medicare plans, because CMS does not recognize the new Telehealth Services CPT codes. Additionally, Medicaid has not yet issued a 2025 fee schedule so Priority Health will continue to follow Medicaid’s guidelines as they are released.
Priority Health will apply the extension of the geographic, site of service, and practitioner type restrictions, to Medicare plans as well. These flexibilities loosened geographic and location restrictions on where services could be provided, and loosened limitations on the scope of practitioners who can provide telehealth services. See CMS’s MLN Matters article MM13887 for more details.
MSMS will continue to monitor telehealth payment policies and report on any updates as they become available.