Telehealth Billing: Updates and Challenges for 2025
As telehealth continues to evolve, particularly after the global health crisis, understanding the updates and overcoming the challenges in telehealth billing is vital for chiropractic and physical therapy practitioners. Here, we delve into the current state of telehealth billing for 2025, highlighting the key changes and hurdles providers are navigating.
Key Updates in Telehealth Billing for 2025
- Permanent Audio-Only Services: Medicare has now made certain audio-only telehealth services a permanent fixture, especially for behavioral health, recognizing the need for care access for those without video capabilities. This includes new coding for audio-only visits, ensuring providers can still be reimbursed for these services.¹
- New CPT Codes: The introduction of new Current Procedural Terminology (CPT) codes (98000-98015) for evaluation and management via telehealth aims to streamline the billing process. However, not all these codes are recognized by CMS for payment, leading to continued use of traditional E/M codes for reimbursement.²
- Extended Flexibilities: Many telehealth flexibilities implemented during the public health emergency have been extended through legislative action. However, these could sunset without further congressional intervention. These include allowing patients to receive services in their homes without geographic restrictions, with specific billing modifiers like “93” for audio-only services.³
- Billing Modifiers and POS Codes: The use of modifiers such as “95” for audio-video and “93” for audio-only, along with place of service (POS) codes like 02 (patient not at home) and 10 (patient at home), has become integral for accurate telehealth billing, reflecting where and how the service was delivered.⁴
Challenges in Telehealth Billing
- Reimbursement Variability: Despite the updates, reimbursement policies differ significantly among payers. Private insurers might offer more liberal coverage but with greater variability, requiring practitioners to stay updated on each payer’s policy to ensure accurate billing.⁵
- Coding Accuracy: The complexity of new and existing codes, combined with the necessity to apply the correct modifiers and POS, poses a significant challenge. Mistakes here can result in claim denials or underpayments, affecting revenue.⁶
- Regulatory Uncertainty: The temporary nature of some telehealth policies creates uncertainty about the future of current billing practices, especially if Congress does not act to make these changes permanent or extend waivers.⁷
- Compliance with State Laws: Each state may have its own set of rules for telehealth billing, adding another layer of complexity for practices serving patients across multiple states. Compliance with these varying regulations is essential yet challenging.⁸
Strategies for Navigating Telehealth Billing
- Stay Informed: Regularly check updates from CMS, state health departments, and insurance providers to keep up with changes in telehealth billing policies.
- Use Technology: Invest in billing software that can automate coding suggestions, apply the correct modifiers and POS based on the type of telehealth service, and update with new regulations as they emerge.
- Educate Staff: Continuous education for billing personnel on the latest telehealth billing practices can reduce errors and enhance compliance.
- Engage with Professional Networks: Joining or participating in professional organizations can provide insights into best practices and upcoming changes in telehealth billing.
The landscape of telehealth billing in 2025 is marked by significant updates alongside ongoing challenges. For chiropractic and physical therapy providers, mastering this evolving field means staying informed, ensuring coding accuracy, and preparing for potential regulatory shifts. By employing strategic approaches to billing, practices can navigate these complexities, ensuring they continue to deliver high-quality care while maintaining financial viability.
Sources:
- “Telehealth 2025: The Final Rule,” AAPC Knowledge Center, accessed January 17, 2025, .
- “2025 MPFS: Key Updates on Telehealth and Frequency Limitations,” StreamlineMD, accessed January 17, 2025, .
- “Telehealth policy changes after the COVID-19 public health emergency,” Telehealth.HHS.gov, accessed January 17, 2025, .
- “Billing Medicare for Telehealth Services in 2024,” AAPC Knowledge Center, accessed January 17, 2025, .
- “Telehealth Reimbursement 2024: Behavioral Professional’s Guide,” Telehealth.org, accessed January 17, 2025, .
- “Key Telehealth Updates in the CY 2025 Physician Fee Schedule Proposed Rule,” Healthcare Law Blog, accessed January 17, 2025, .
- “Telehealth Update: DEA/HHS Temporary Rule, Medicare Coverage of Telehealth Services, and What to Watch For in 2025,” Mintz, accessed January 17, 2025, .
- “Telehealth: Regulatory Questions Amid Legislative Uncertainty,” McDermott+, accessed January 17, 2025, .
