Coding & billing

Telehealth

Given the evolving regulatory and legislative future of coding and billing for telehealth, the Âé¶¹´«Ã½Ó³»­ has created and curated the following resources to help maximize coding efficiency and payment of telehealth services.

Have questions about coding and billing? Email practice@aan.com to reach staff and member experts.

Top resources

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  • - Includes a discussion of telehealth coding updates in the 2026 Final Rule

Coding Medicare audio-only telehealth during ongoing telehealth extensions

Updated February 2026

Clinicians may provide audio-only telehealth services to patients regardless of geographic location, including from the patient’s home, through December 31, 2027. Congress must pass legislation to extend audio-only telehealth for most non-behavioral services beyond 2027.

In the CY 2025 Physician Fee Schedule Final Rule (PFS), Medicare finalized that it will not cover the audio-only telemedicine office codes (CPT 98008-90815) that were added to the CPT manual in January 2025. Additionally, the telephone E/M codes (CPT 99441-99443) have been eliminated beginning in 2025. Therefore, providers submitting audio-only Medicare telehealth claims should use the in-person office/outpatient E/M CPT codes 99202-992015 that already exist on the Medicare Telehealth Services List with the appropriate telehealth modifiers:

  1. Place of service (POS) code 10, which indicates that telehealth was provided to a patient in their home. Note: CMS finalized that audio-only telehealth is only permissible to patients in their homes and not while they are located in a facility or office.
  2. CPT modifier ‘93’ to indicate audio-only communication was used.

Âé¶¹´«Ã½Ó³»­ members should be aware that the office/outpatient E/M codes have more extensive billing requirements than the deleted telephone E/M codes.

Lastly, CMS finalized that interactive two-way audio-only communication technology can be furnished to a Medicare beneficiary in their home IF:

  • The distant site physician or practitioner is technically capable of using an interactive audio-video telecommunications system… AND
  • …the patient is not capable of, or does not consent to, the use of video technology.

Both conditions must be met and could occur if a patient does not have sufficient broadband access or does not feel comfortable navigating audiovisual technology. Whatever the reason, providers should use their clinical judgment to determine if audio-only telehealth is appropriate for the clinical situation to be addressed. 

Documentation suggestions

  • Relevant POS code and CPT modifier ‘93’
  • Note that the encounter occurred using real-time audio-only technology and that the patient requested an audio-only encounter.
  • Information supporting the use of the particular E/M code related to the level of medical decision-making or time provided on the date of service.

Note: Not all private payers will follow Medicare policy. As with other coding regulations, the Âé¶¹´«Ã½Ó³»­ encourages members to review their individual coverage policies prior to submitting claims for telehealth services in 2025.

Coding non-face-to-face telehealth

Also known as curbside or eConsults, non-face-to-face interprofessional consults are documented consultations between providers without the patient present.

Interprofessional consultations (e-consults)
Understand how to code non-face-to-face consultations between health care professionals.

Patient portal messages
Review when interactions via the patient portal are billable.