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Coding Medicare Audio-only telehealth during ongoing telehealth extensions

Updated March 2025

Clinicians may provide audio-only telehealth services to patients regardless of geographic location, including from the patient’s home, through September 30, 2025. Congress must pass legislation to extend audio-only telehealth for most non-behavioral services beyond September.

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.

AAN 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 AAN encourages members to review their individual coverage policies prior to submitting claims for telehealth services in 2025.