The experts at Radiation Business Solutions have put together a summary of the 2025 E&M Changes for your convenience. Radiation Business Solutions is committed to supporting practices through these changes.

New Telehealth E&M CPT Code Set

For 2025 the American Medical Association added a list of telehealth E&M codes that mirror the office/outpatient new and established patient codes. There are audio/video codes and audio only codes. The former audio only codes 99441-99443 have been deleted. Below is a table of the new telehealth codes matched up with their in-person counterparts.

CMS Telehealth Rules for 2025

CMS has opted to not accept the new codes created by the AMA. Below is a summation of the CMS rules for telehealth E&M visits in 2025.

• For audio/video visits continue to use the appropriate in-person E&M code with a 95 modifier appended, and the 02 or 10 place of service.
• For audio only visits, if the provider has video capabilities but the patient either does not or refuses to use video, use the appropriate in-person E&M code with a 93 modifier appended, and the 02 or 10 place of service.

Virtual Check-in Visits

For 2025 AMA created CPT code 98016, which mirrored the current HCPCS code G2012 for virtual check-ins lasting 5-10 minutes. CMS will eliminate HCPCS code G2012 and replace it with CPT 98016. Meanwhile, HCPCS code G2252, which covers virtual check-ins lasting 11-20 minutes, will remain unchanged as there is no corresponding CPT code.

CMS Complexity Code Update

For CY 2025, CMS will allow extra payments for complex office or outpatient visits (code G2211) when these visits occur on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventive service, including the Initial Preventive Physical Examination (IPPE). This applies when the same practitioner provides both services on the same day.

Telehealth In General

Starting January 1, 2025, unless Congress acts, pre-COVID-19 restrictions on Medicare telehealth services will return, including geographic and location limitations and restrictions on eligible practitioners. However, CMS aims to retain some flexibilities and expand telehealth access where possible. We encourage you to reach out to your congressmen and voice your concerns relating to telehealth services in general. Please note that CPT 77427 (physician OTV) is still on the list of approved telehealth services with a provisional status for 2025. OTVs done via telehealth require video and need a 95 modifier attached to the code.

UPDATE: Congress acted and extended telehealth availability at the patient home through March 31, 2025.

Update 2: In House Rule 1968, section 2207 (also known as the Full-Year Continuing Appropriations and Extensions Act, 2025), Congress moved the expiration date of telehealth to September 30, 2025. This is the fiscal year-end.

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