On September 10, the American Medical Association released the CPT 2025 code set. It carries 420 changes: 270 new codes, 112 deletions and 38 revisions, all effective January 1, 2025. For most practices the volume is manageable. The part that will change daily work is a new family of telemedicine evaluation and management codes, 98000 through 98016, and the deletion of the telephone E/M codes 99441 to 99443 that many practices have used since 2020.
We have spent the last week reading the new descriptors with the coders we train, and the reaction is the same every time: the structure is sensible, and the payer response is the open question. A CPT code existing does not mean anyone pays for it, and the largest payer in the country has already hinted that it won't. Below is what the codes do, what disappears, what we know about payer positions as of mid-September, and the setup work that belongs in October and November rather than the last week of December.
Key takeaways
- CPT 2025 adds 17 telemedicine E/M codes (98000 to 98016) split by modality, patient status and level, and deletes the telephone E/M codes 99441 to 99443.
- CMS signaled in the CY2025 proposed rule that Medicare would not pay separately for most of the new codes; the final rule around November 1 will settle it, and commercial payers will publish their own positions afterwards.
- Plan for two code paths in January: the 98000 series for payers that adopt it, and the office visit codes with modifier 95 or place of service 02 and 10 for payers that don't.
- Any charge rule, superbill line or template that produces 99441 to 99443 will generate invalid codes on January 1 unless it is rebuilt.
The new telemedicine E/M family
The 17 codes are organized the way office visits are organized: new versus established patient, then level. The difference is that they also split by modality.
| Codes | Modality | Patient | Level selection |
|---|---|---|---|
| 98000 to 98003 | Synchronous audio-video | New | MDM or total time, four levels |
| 98004 to 98007 | Synchronous audio-video | Established | MDM or total time, four levels |
| 98008 to 98011 | Synchronous audio-only | New | MDM or total time, four levels; more than 10 minutes of medical discussion |
| 98012 to 98015 | Synchronous audio-only | Established | MDM or total time, four levels; more than 10 minutes of medical discussion |
| 98016 | Brief communication technology-based service | Established | 5 to 10 minutes of medical discussion, patient initiated |
The audio-video codes mirror 99202 to 99205 and 99212 to 99215 in their MDM levels and time thresholds. The audio-only codes carry the additional requirement of more than 10 minutes of medical discussion; a shorter call does not qualify for an audio-only E/M level. Code 98016 is the CPT equivalent of the virtual check-in that Medicare has paid under G2012, and it carries the same fences: established patients only, patient initiated, not originating from a related E/M service in the previous seven days and not leading to one in the next 24 hours.
One structural point that coders ask about: the new codes have no 99211 equivalent. There is no telemedicine code for a visit that does not require a physician or qualified health professional. A nurse-only phone call remains unbillable as an E/M service, which is what it was before.
What is deleted
CPT 99441, 99442 and 99443, the telephone E/M codes billed by time (5 to 10, 11 to 20 and 21 to 30 minutes), are gone as of January 1. Practices that built telephone visit templates around those codes need new templates that capture either MDM elements or total time, plus a statement that the encounter was audio-only and why video was not used. Any charge rule or superbill entry that maps a "phone visit" appointment type to 99441 to 99443 will produce invalid codes on New Year's Day, and the clearinghouse will reject them before the payer ever sees them.
The deletion also removes a habit. Under the telephone codes, a 12-minute call was 99442 regardless of what was discussed. Under the new set, the same call is 98012 to 98015 depending on MDM or time, which means the note needs the same elements an office visit note needs. Providers who documented phone calls in two sentences will need to document them in the same structure as a visit.
The payer question nobody can answer yet
In the CY2025 Physician Fee Schedule proposed rule this summer, CMS signaled that it does not see a programmatic need to pay separately for most of the new telemedicine E/M codes, and that it would continue to expect Medicare telehealth visits to be reported with the office visit codes and the place of service or modifier conventions already in use. The final rule is expected around November 1, and we will know then. Commercial payers and Medicaid programs will each publish their own position, and in our experience they do so between November and February, often after the effective date.
Our advice is to plan for two code paths in January: one for payers that adopt 98000 to 98016, and one for payers that keep the office visit codes with modifier 95 or place of service 02 and 10. That is annoying, and it is also exactly what happened when telehealth rules diverged in 2021 and 2022. The practical tool is a one-page payer grid, maintained by the billing lead, with a row per payer and three columns: telemedicine E/M code set accepted, audio-only code or modifier accepted, and the date and source of the answer. Fill it as bulletins arrive. Until a payer has published, assume the office visit codes.
Other 2025 changes worth a look
Beyond telemedicine, the 2025 changes cluster in areas that matter to specific specialties rather than every practice. Proprietary laboratory analyses account for the largest share of new codes, mostly genetic tests, and Category III codes for emerging services are about a third of the additions, including a new appendix that classifies artificial intelligence applications as assistive, augmentative or autonomous. Remote therapeutic monitoring gains codes for shorter data collection periods. Surgical practices should review the new and revised codes in their sections, and anyone billing digital health services should read the revised guidelines carefully because the AMA continues to tighten descriptors in that area. The AMA's own summary and the CPT 2025 book's Appendix B (summary of additions, deletions and revisions) are the authoritative lists; the specialty society summaries that follow in October are usually easier to read.
Where the codes have to be loaded
A code set update in an independent practice touches more places than the fee schedule. The table below is the checklist we use for the telemedicine change specifically.
| Place | Change for January 1 | Owner |
|---|---|---|
| Practice management fee schedule | End-date 99441 to 99443 at December 31, 2024; add 98000 to 98016 with placeholder fees and a January 1 start date | Billing lead |
| Appointment type to code mapping | Point "phone visit" and "video visit" types at the new codes for adopting payers, or at 99202 to 99215 with modifier 95 for the rest | EHR administrator |
| Telephone and video visit templates | Add modality, patient consent, reason video was not used, MDM elements and total time | Clinical lead with coder |
| Superbill or encounter form | Remove the telephone codes; add the new family with short descriptions | Practice manager |
| Claim edits | Reject 99441 to 99443 for 2025 dates of service; require modifier 93 or the audio-only code where the payer wants it | Billing lead |
| Payer grid | Row per payer with the code set accepted and the source | Billing lead |
Three coding examples for training
Example 1. A 58-year-old established patient with hypertension has a video visit; the physician adjusts a medication and orders a metabolic panel. Two chronic conditions, one stable and one not at goal, prescription drug management: moderate MDM. Under the new set that is 98006. Under a payer that has not adopted the set, it is 99214 with modifier 95, place of service 10 if the patient was at home.
Example 2. An established patient calls about a rash and the nurse practitioner spends 12 minutes in medical discussion by phone, recommends an over-the-counter treatment and documents the plan. Audio-only, more than 10 minutes, low MDM: 98013. Before 2025 that was 99442. Under a payer that keeps the office visit codes, it is 99213 with modifier 93 for audio-only, if the payer covers audio-only E/M at all.
Example 3. An established patient calls with a question about a lab result and the physician spends seven minutes on the phone; no visit is scheduled as a result and there was no related visit in the previous week. That is 98016 if the payer recognizes it, or G2012 for a payer that keeps the HCPCS code.
Questions we hear
Can we start using 98000 to 98016 now?
No. The codes are effective January 1, 2025. Claims with those codes for 2024 dates of service will reject as invalid, and the telephone codes remain the correct codes for audio-only visits through December 31.
Do the new codes change the telehealth rules about where the patient is?
No. CPT describes the service. Coverage rules about originating site, geography and eligible practitioners come from Medicare law, state law and payer policy. The Medicare flexibilities that allow patients to be at home are currently set to expire on December 31, 2024 unless Congress extends them, and that question is separate from which code is on the claim.
Where can our coders get structured training on the 2025 changes?
The Revelrex live RCM training courses cover the annual code set changes each winter, with practice cases in the Revelrex EHR training environment so coders can work the new codes on realistic charts before they meet them on real claims.
What to do this month
- Ask your practice management and EHR vendors for the CPT 2025 release date and whether the update loads automatically or needs a request.
- Run Appendix B against your fee schedule, superbill, charge rules and provider favorites; list every deleted code the practice actually uses.
- Rebuild the telephone visit template to capture modality, consent, MDM or time, and the reason video was not used.
- Add 98000 to 98016 to the fee schedule with placeholder fees and a January 1, 2025 start date; end-date 99441 to 99443 at December 31.
- Start the payer grid and add a row each time a payer bulletin arrives.
- Schedule a 30-minute provider briefing for the first week of December, after the PFS final rule, with the three examples above.
