Telehealth Billing in 2025: The Rules Have Changed and Most Practices Are Getting It Wrong

Telehealth Billing Is More Complicated Than It Was

During the COVID-19 public health emergency, CMS temporarily relaxed nearly all restrictions on telehealth services — where patients could be located, what technologies could be used, which services were covered, and at what rates. Many physicians built telehealth into their practice model during this period. But as the public health emergency ended, the rules changed — and not all the flexibilities were made permanent.

The result is that a significant number of practices are continuing to bill telehealth services using pandemic-era rules that no longer apply. This creates two problems simultaneously: compliance risk if you are billing for services that are no longer covered, and revenue loss if you are not taking full advantage of the flexibilities that were made permanent.

What Became Permanent vs What Expired

Understanding what is permanent versus what expired is essential for correct telehealth billing. On the permanent side: patients can receive most telehealth services from their home (not just healthcare facilities), audio-only telehealth visits are covered for established patients with appropriate documentation, and mental health services via telehealth have expanded permanently with some conditions.

Federally Qualified Health Centers and Rural Health Clinics can serve as distant sites for telehealth permanently. The in-person visit requirement for mental health telehealth has specific rules that providers must follow — an in-person visit is required within the first year of initiating telehealth mental health services in most cases.

What did NOT become permanent: the geographic restrictions were relaxed permanently for most services, but some specific services retained location requirements. The expanded list of services covered by Medicare telehealth was trimmed from the pandemic-era list. And some state-specific restrictions on cross-state telehealth practice resumed after the emergency ended.

Place of Service Codes and Why They Matter

One of the most common telehealth billing errors is using the wrong place of service (POS) code. Under current rules, when a patient receives telehealth services in their home, the claim should use POS 10 (Telehealth Provided in Patient's Home). When the patient is at a healthcare facility receiving a service via telehealth from a distant provider, POS 02 (Telehealth Provided Other than in Patient's Home) applies.

Getting the POS code wrong affects your reimbursement rate. Medicare pays the facility rate (lower) when POS 02 is used and the non-facility rate (higher) when POS 10 is used for services delivered to a patient in their home. Many practices are using POS 02 across the board and losing reimbursement as a result.

The Audio-Only Visit Coding Requirement

Audio-only telephone visits — where there is no video component — are billable under specific CPT codes (99441, 99442, 99443) based on the duration of the call. These are different from standard office visit codes. Many practices are either not billing these calls at all or billing them incorrectly as standard office visits.

For Medicare, audio-only visits for established patients are covered with appropriate documentation of the call duration, the medical content of the discussion, and the reason video was not used. The medical reason for audio-only should be documented — the patient did not have video capability, the patient preferred telephone, or there was a technical barrier to video.

Commercial payer policies on audio-only visits vary significantly. Some payers have adopted Medicare's approach, others have their own policies, and some do not cover audio-only visits at all. You need to know each payer's specific policy before billing.

State Licensure and the Interstate Medical Licensure Compact

One aspect of telehealth that the pandemic flexibilities changed was the enforcement of state licensure requirements. Most states require a physician to hold an active license in the state where the patient is located at the time of service — not where the physician is located. During the pandemic, many states suspended these requirements.

As these suspensions have ended, physicians providing telehealth to patients in states where they are not licensed face compliance risk. The Interstate Medical Licensure Compact (IMLC) provides an expedited pathway to licensure in multiple states, and if you regularly see patients in states other than your primary practice state, investigating the IMLC is worthwhile.

Documentation Requirements for Telehealth

The documentation requirements for telehealth visits are the same as for in-person visits — the clinical content must support the code billed. But there are additional documentation elements that are specific to telehealth: you should document that the visit occurred via telehealth, the modality (audio-video or audio-only), the patient's location and consent, and confirmation that the patient was in a state where you are licensed to practice.

For audio-only visits, document the specific reason video was not used. For mental health telehealth, document compliance with the in-person visit requirement. These details are not optional — they are what distinguishes a compliant telehealth visit from one that could be recouped on audit.