2025 CPT coding updates

By Faith C. M. McNicholas, RHIT, CPC, CPCD, PCS, CDC, Manager, Lead Coding and Reimbursement Strategist, December 1, 2024

Academy coding staff address important coding topics each month in DermWorld Coding Consult. Read more Derm Coding Consult articles.

The American Medical Association (AMA) has released the Current Procedural Terminology (CPT^®) coding updates that will go into effect on Jan. 1, 2025.

Telemedicine services

One notable change is the removal of the telemedicine symbol (*) from codes 99202-99205 and 99211-99215, as these codes will no longer be used to report telemedicine office visits. Starting Jan. 1, 2025, telemedicine encounters will instead be reported using the newly created codes 98000-98016.

A new ‘Telemedicine Services’ subsection has been added to the ‘Evaluation and Management’ (E/M) section, including new guidelines and 17 new codes for reporting synchronous (real-time) E/M services. These guidelines clarify the services covered by the new telemedicine codes and provide instructions on appropriately and accurately reporting these services.

For detailed coding guidelines and a complete list with descriptors, please review the AAD’s 2025 Coding & Billing for Dermatology.

Telemedicine services can be provided via synchronous, real-time interactions between a dermatologist or non-physician clinician (NPC) and a patient, using either combined audio-video or audio-only technology. To facilitate reporting for these services, the AMA has introduced new codes that differentiate E/M encounters based on the type of telecommunication technology used.

Telemedicine codes should be used to report E/M services provided in place of an in-person encounter when this format of care is medically appropriate and agreed upon by the patient and/or caregiver. These codes are NOT intended to be used for routine follow-up communications (e.g., providing lab results), but may be used for follow-up visits requiring reassessment for treatment response or complications related to the treatment plan of a previous visit — similar to in-person E/M follow-up care.

With the exception of CPT code 98016 (discussed further below), telemedicine services do not require a specific time interval since the last in-person or telemedicine encounter. These services can be initiated by the dermatologist/NPC or by the patient and/or caregiver, provided they are performed on a separate date of service from any other E/M service.

Unless specified otherwise in the code descriptor, level selection for telemedicine services is based on the level of medical decision making (MDM) or the total time of E/M services performed on the date of the encounter, as outlined for each service.

• When a telemedicine visit occurs on the same date as another E/M service, the elements and time of both services should be combined and reported as a single E/M code to avoid duplicate billing. If the minimum time for reporting a telemedicine service is not met, the time spent may still count toward the total time of an in-person E/M service provided on the same day. To aid in coding, a table clarifying the use of codes 98000-98016, as well as other online and non-face-to-face E/M services, has been included in the coding manual.

• In the 2025 Medicare physician fee schedule final rule, CMS announced that it will not pay for CPT codes 98000, 98001, 98002, 98003, 98004, 98005, 98007, 98008, 98009, 98010, 98011, 98012, 98013, 98014, and 98015.
  
  However, CMS will pay CPT code 98016 in place of HCPCS G2012, when reported.
  
  As a result, the telemedicine service codes 98000-98015 CANNOT be reported to Medicare with the expectation of reimbursement.

• Please check directly with the individual private payers you are contracted with to ascertain their coverage policies for these new telemedicine codes.

Synchronous audio-video E/M services

Synchronous audio-video codes may be reported for services for new or established patients that are provided using both audio and video telecommunication technology. These services are reported based on either medical decision-making (MDM), or the total time spent addressing the patient’s concern(s) and are defined as follows:

• New patient: 98000-98003
  Synchronous audio-video visit for the E/M of a new patient, which requires a medically appropriate history and/or examination and an appropriate level of MDM.

• Established patient: 98004-98007
  Synchronous audio-video visit for the E/M of an established patient, which requires a medically appropriate history and/or examination and an appropriate level of MDM.

When using time to report an audio-video encounter on the date of service, code selection for both new and established patients should be based on the total time spent, as specified in the code descriptors. The total time documented must meet or exceed the time threshold required to report a specific level of service.

Synchronous audio-only E/M services (telephone services)

Another notable development is that with the establishment of the new telemedicine codes 98000-98016, telephone service codes 99441-99443 — along with their associated guidelines and parenthetical notes — have been deleted. To report services provided via telephone, please refer to codes 98008, 98009, 98010, 98011, 98012, 98013, 98014, 98015.

The new synchronous audio-only codes are also based on either MDM, or the total time spent addressing the patient’s concern(s) and are defined as follows:

• New patient: 98008-98011
  Synchronous audio-only visit for the E/M of a new patient, which requires a medically appropriate history and/or examination, including an appropriate level of MDM.

• Established patient: 98012-98015
  Synchronous audio-only visit for the E/M of an established patient, which requires a medically appropriate history and/or examination, including an appropriate level of MDM.

When using time to report an audio-only encounter on the date of service, code selection for new and established patients should be based on the total time spent, as specified in the code descriptors. The total time documented must meet or exceed the time threshold required to report a specific level of service.

Brief communication technology service

CPT code 98016, like the Medicare HCPCS code G2012, describes a brief communication technology-based service (e.g., virtual check-in), lasting 5-10 minutes, which is shorter in duration than the audio-only encounter service mentioned above and is defined as follows:

Brief communication technology-based service (e.g., virtual check-in) by a physician or other qualified health care professional who can report E/M services, provided to an established patient, not originating from a related E/M service provided within the previous seven days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment, 5-10 minutes of medical discussion.

This code is used to report patient-initiated encounters with an established patient, during which the dermatologist/NPC evaluates whether a more extensive visit (e.g., an office or other outpatient E/M service [99212, 99213, 99214, 99215]) is required. Video technology is not required for this encounter.

• This code includes additional restrictions, as outlined in the coding manual, reflecting its intended use as a “virtual check-in” or triage to assess if an E/M service is necessary.

If this patient-initiated check-in encounter leads to an E/M service on the same calendar date, and time is used as the basis for selecting the level of that E/M service, the time from CPT code 98016 may be added to the total time for that day’s encounter.

Online digital E/M services

Additionally, the establishment of codes 98000-98016 has resulted in the ‘Online Digital Evaluation and Management Services’ guidelines being revised to reflect the changes discussed above.

Efforts have also been made to standardize the terminology “nonphysician qualified health care professional” throughout the 2025 CPT code set, and the Online Digital Evaluation and Management Services guidelines preceding code 99421.

Other coding updates

The 2025 Medicare fee schedule final rule indicated the following, beginning Jan. 1, 2025:

• An interactive telecommunications system may include two-way, real-time, audio-only communication technology for any Medicare telehealth service provided to a beneficiary in their home, when the distant-site dermatologist or NPC has the capability to use video technology, but the patient is either unable or does not consent to its use.

• CMS will continue to allow dermatologists/NPCs located in a distant site to use their currently enrolled practice location, rather than their home addresses, when delivering telehealth services from their home.

• CMS has permanently adopted a definition of direct supervision that allows supervising dermatologists/NPCs to provide oversight virtually, using real-time audio and video telecommunications, for services furnished “incident to” a dermatologist’s or NPC’s professional services. This applies to auxiliary personnel employed by the billing dermatologist or supervising practitioner and working under their direct supervision.
  
  This policy includes services with a PC/TC indicator of “5,” services (e.g., 96900-96912) and the service described by CPT code 99211, as well as other office or outpatient E/M visits for established patients who may not require the dermatologist’s or NPC’s physical presence.

• CMS has also finalized that for all other “incident to” services requiring direct supervision by a dermatologist or NPC, direct supervision may be provided via real-time audio and video interactive telecommunications technology through Dec. 31, 2025.

• CMS will continue to allow teaching physicians to have a virtual presence during the key portion of services involving residents in all teaching settings for billing purposes. This applies only in clinical situations where the service is provided virtually (e.g., a three-way telehealth visit with the patient, resident, and teaching physician at separate locations) through Dec. 31, 2025.

In the context of this year’s CPT updates, it appears that dermatology has been minimally affected by the significant revisions that could impact coding practices.

Enjoy this brief respite!

See more information on 2025 CPT coding updates to E/M services.

Additional DermWorld Resources