Telehealth Billing Landscape in 2025: A Guide for Doctors and Billers in Texas
- Vinee Patel
- Sep 17
- 5 min read
The world of telehealth is in a constant state of evolution, and 2025 brings new rules and a mix of established and new codes that healthcare providers in Texas must master to ensure accurate and timely reimbursement. The key to successful telehealth billing lies in understanding the nuanced differences between payers—especially Medicare and commercial plans—and correctly applying the right codes, modifiers, and places of service.
Will Medicare Continue to Pay for Telehealth? The "Telehealth Policy Cliff"
This is the most pressing question for providers and patients alike. As of the current date, the robust telehealth flexibilities introduced during the COVID-19 pandemic have been extended through September 30, 2025. This means that through this date, Medicare beneficiaries can continue to receive a wide range of telehealth services from their homes, regardless of their location.
However, after October 1, 2025, the situation changes dramatically unless Congress takes further action. The pre-pandemic rules are set to return, which would generally restrict most telehealth services to beneficiaries located in rural areas and only at an eligible originating site (like a clinic or hospital). While some exceptions, such as for behavioral health services, may remain, the broad coverage for telehealth visits from a patient's home is at risk.
For Texas providers, this means:
Now through September 30, 2025: Continue to bill telehealth services as you have been, following the guidelines below.
After October 1, 2025: Stay vigilant for legislative updates. Without an extension, be prepared for a significant shift in Medicare telehealth policy.
Mastering CPT Codes and Modifiers: The New vs. The Old
A major source of confusion in 2025 is the split between Medicare and commercial payer policies regarding CPT codes. The American Medical Association (AMA) has released new telemedicine-specific CPT codes for 2025, while Medicare has chosen to stick with the established E/M codes.
Service Type | Payer | CPT/HCPCS Codes | Modifiers | Place of Service (POS) | Key Notes |
Synchronous Audio-Video E/M (New Patient) | Medicare | 99202 - 99205 (Standard Office/Outpatient E/M Codes) | Not required by Medicare, but 95 is recommended for commercial. | POS 10 (Patient's Home) or POS 02 (Other location) | Medicare did NOT adopt new AMA 98000-series codes. You must use standard E/M codes. |
Synchronous Audio-Video E/M (Established Patient) | Medicare | 99212 - 99215 (Standard Office/Outpatient E/M Codes) | Not required by Medicare | POS 10 (Patient's Home) or POS 02 (Other location) | Medicare did NOT adopt new AMA 98000-series. Must use standard E/M codes. |
Synchronous Audio-Video E/M (New Patient) | Commercial Plans (e.g., BCBS PPO, HMO, Humana) | 98000 - 98003 (AMA's new Telemedicine E/M codes for Audio-Video) | 95 (Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System) | POS 10 (Patient's Home) or POS 02 (Other location) | Crucial to verify with each commercial payer. Some may adopt these, others may prefer standard E/M codes with 95. Selection is based on MDM or time. |
Synchronous Audio-Video E/M (Established Patient) | Commercial Plans (e.g., BCBS PPO, HMO, Humana) | 98004 - 98007 (AMA's new Telemedicine E/M codes for Audio-Video) | 95 | POS 10 (Patient's Home) or POS 02 (Other location) | Crucial to verify with each commercial payer. Some may adopt these, others may prefer standard E/M codes with 95. Selection is based on MDM or time. |
Audio-Only vs. Audio-Video: The Modifier Difference
This is where the correct use of modifiers is paramount. The modifier you choose tells the payer the modality of the visit, and a mismatch can lead to a denial.
Modifier 95: This modifier is for audio-video telehealth services. It signifies that the visit was conducted using a real-time, interactive communication system that included both audio and video components.
Modifier 93: This modifier is specifically for audio-only telehealth services. It should be used when the visit was conducted via a real-time interactive audio-only telecommunications system (e.g., telephone).
Medicare's Audio-Only Policy: For Medicare, audio-only visits are generally permitted if the patient is in their home and the provider is technically capable of an audio-video visit, but the patient is not or declines video. You must document the reason for the audio-only visit in the patient's record to justify the use of modifier 93.
What if the Patient Initiates the Audio Visit?
This is a critical distinction in telehealth billing. A brief, patient-initiated audio call to determine if a full visit is needed may not qualify for a standard E/M code. Instead, you should consider the new CPT code for a Virtual Check-in.
Virtual Check-in (CPT 98016): This new code replaces the old HCPCS code G2012 for 2025. It is for a brief communication of 5-10 minutes with an established patient to determine if a more extensive E/M visit is required. It is not billable if it occurs within 7 days of a previous E/M service or if it leads to an E/M service within the next 24 hours.
Reimbursement Examples for Texas Providers
While specific rates vary by contract, here are general billing strategies and general reimbursement rates for Texas Providers.
Commercial | Audio Only | |||
CPT code | Modifer | Fees | Time (min.) | POS |
98012 | 93 | $68.92 | 10+ | Patient Home |
98013 | 93 | $120.38 | 20+ | Patient Home |
98014 | 93 | $176.10 | 30+ | Patient Home |
98015 | 93 | $256.12 | 40+ | Patient Home |
Medicare | Audio Only | |||
CPT code | Modifer | Fees | Time (min.) | POS |
99212 | 93 | 106.38 | 10+ | Patient Home |
99213 | 93 | 172.68 | 20+ | Patient Home |
99214 | 93 | 243.32 | 30+ | Patient Home |
CPT code | Modifer | Fees | Time (min.) | POS |
98016 | 31.01 | 5-10 | Patient Home | |
Patient-initiated, to determine if more extensive E/M is needed. | Not for services within 7 days of previous E/M or leading to an E/M within 24 hours. | |||
BCBS PPO | Audio-Video | |||
CPT code | Modifer | Fees | Time (min.) | POS |
98004 | 95 | $54.11 | 10+ | Patient Home |
98005 | 95 | $94.58 | 20+ | Patient Home |
98006 | 95 | $139.59 | 30+ | Patient Home |
98007 | 95 | $185.06 | 40+ | Patient Home |
BCBS HMO | Audio-Video | |||
CPT code | Modifer | Fees | Time (min.) | POS |
98004 | 95 | $48.91 | 10+ | Patient Home |
98005 | 95 | $85.49 | 20+ | Patient Home |
98006 | 95 | $126.18 | 30+ | Patient Home |
98007 | 95 | $167.28 | 40+ | Patient Home |
Humana | Audio-Video | |||
CPT code | Modifer | Fees | Time (min.) | POS |
98004 | 95 | $38.68 | 10+ | Patient Home |
98005 | 95 | $67.63 | 20+ | Patient Home |
98006 | 95 | $99.70 | 30+ | Patient Home |
98007 | 95 | $132.24 | 40+ | Patient Home |
Beyond E/M: Other Telehealth Services
Remember that telehealth extends beyond E/M visits. The following services also have specific coding requirements for 2025:
Prolonged Services (99417): Can be billed as an add-on code when total time for a telehealth E/M visit exceeds the maximum for the primary code.
Remote Patient Monitoring (RPM): A suite of codes (99453, 99454, 99457, 99458) for monitoring physiological data from patients at home.
Remote Therapeutic Monitoring (RTM): A similar suite of codes (98975, 98976, 98977, 98980, 98981) for non-physiological data, such as medication adherence or musculoskeletal data.
Is Your Office Billing Correctly?
With the constant shifts in policy, it is more important than ever to have a robust billing process. To ensure your office is billing telehealth the right way:
Verify Payer Policies: Before every visit, confirm the patient's plan and check the latest provider manual for their specific telehealth billing rules. Your Google Sheets are a great starting point, but they must be updated continuously.
Use the Right POS Code: The difference between POS 10 (patient's home) and POS 02 (other location) is critical and can affect reimbursement.
Apply Correct Modifiers: The difference between modifiers 95 (audio-video) and 93 (audio-only) is the primary way payers identify the visit modality.
Document Everything: Your clinical notes must support the billing codes. For audio-only visits, explicitly document why video was not used.
Stay Informed: Follow updates from CMS, AMA, and major payers. Subscribe to newsletters, attend webinars, and work with a billing partner who specializes in telehealth.
By proactively managing these changes, Texas physicians and their billing teams can continue to provide essential care while securing accurate and timely payment in the dynamic 2025 telehealth landscape.
Please note: The following is an informational article based on current telehealth billing rules and anticipated changes for 2025. Billing and coding are subject to frequent changes, and it is crucial for healthcare providers and billers to verify all information with specific payers, including Medicare, and stay current on the latest updates from organizations like CMS and the AMA.
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