Medicare telehealth billing in the U.S.: CPT basics and documentation flow

The first time I tried to bill a Medicare telehealth visit, I stared at the claim form like it was a puzzle with half the pieces flipped over. Which code? Which modifier? Whose “place” is the place of service when we’re both on screens? I wanted to write this out the way I keep notes for myself—part diary, part field guide—so that the next time I’m choosing between audio-only and audio-video, or deciding whether to use POS 02 or POS 10, I can follow a calm, repeatable path. If you’re trying to make sense of 2025’s rules (and the what happens after September 30, 2025 question), this is the exact checklist I wish I had a year ago.

What finally made billing click for me

My “aha” moment was realizing that Medicare telehealth billing in 2025 has three moving parts that always travel together: the CPT/HCPCS code (what you did), the modifier (how you did it—audio-video or audio-only), and the place of service (where the patient was). If I anchor every claim to those three pivots, the rest tends to fall in line.

• Codes: For most office/outpatient E/M telehealth, Medicare continues to have you bill the familiar 99202–99215 family rather than the new CPT telemedicine E/M series (more on that below). CMS spelled out its 2025 telehealth policies in the PFS final rule fact sheet.
• Modifiers: Use 95 for real-time audio-video; use 93 when the encounter is audio-only and you meet Medicare’s conditions (patient can’t use or declines video, etc.). CMS reiterates the billing mechanics in its 2025 Telehealth FAQ.
• Place of service: Use POS 10 if the patient is in their home; use POS 02 if they’re somewhere else that isn’t their home (for example, work, a clinic, or another non-facility location). See the HHS and CMS explanations here: HHS billing overview and the CMS FAQ.

Two more truths that keep me grounded: cost sharing for beneficiaries is generally the same as in person (Part B deductible + 20% coinsurance), and some of the expanded flexibilities end September 30, 2025 unless Congress acts. Medicare confirms the cost point on its public page here, and HHS tracks the temporary flexibilities here.

Where CPT stands in 2025 and what Medicare actually wants

In the 2025 CPT code set, the AMA retired old telephone-only E/M codes 99441–99443 and created new telemedicine E/M families (distinct for audio-video versus audio-only). That’s a big structural change on the CPT side. But Medicare didn’t adopt most of those new E/M telemedicine codes for payment in 2025—instead, CMS kept the pragmatic path: bill the standard office/outpatient E/M codes (99202–99215) and append modifier 95 or 93 as appropriate, with POS 02 or 10. AMA and CMS both describe this fork in the road (CPT changes vs. Medicare payment policy) in their 2025 materials: see the AMA’s explanation here and CMS’s 2025 PFS fact sheet here.

• Bottom line for E/M: For Original Medicare claims in 2025, think: 99202–99215 + 95 (AV) or 93 (audio-only) + POS 02/10. Check your MAC’s articles for any local nuance and keep a payer grid for Medicare Advantage plans (many follow CMS but some adopt parts of CPT’s new families sooner).
• Audio-only guardrails: CMS allows audio-only for patients in their home when the clinician can technically use video but the patient cannot or does not consent; this is emphasized in the CMS Telehealth FAQ and 2025 PFS materials (FAQ • PFS fact sheet).
• Behavioral health exception: Medicare has permanent flexibilities for behavioral/mental health telehealth, including audio-only in the patient’s home, while non-behavioral telehealth home coverage is currently extended through September 30, 2025. HHS summarizes these timelines here.

The documentation flow I actually use on busy clinic days

When my brain is juggling labs, refills, and a surprise portal message, I follow a simple flow that keeps claims clean and auditable:

• Before the visit
  • Confirm the patient’s coverage (Original Medicare vs. MA plan) and note whether they’re likely to be at home (POS 10) or not at home (POS 02). The POS choice affects the rate and routing, per CMS’s 2025 FAQ (link).
  • Obtain and record telehealth consent (your EHR can prompt this), including whether the patient consents to video. If they decline video or cannot use it, note that clearly for audio-only rules.
  • Set up a smart-phrase that pulls in: patient location, clinician location, technology used, who else was present, and emergency back-up plan (e.g., “If we disconnect, I will call you at ###-###-####.”)
• During the visit
  • Start the note with identity verification + location + modality: “I verified Name/DOB. Patient located at home (POS 10). Visit via secure audio-video [or audio-only due to patient preference/technical limitation].”
  • Document per 2021 E/M guidelines: medical decision making or total time on the date of service. If you code by time, record start/stop or a defensible total time.
  • For audio-only: state why audio-only was used (e.g., vision impairment, connectivity, patient declination). That sentence is tiny, but it matters for compliance under Medicare’s 2025 policy (CMS fact sheet).
  • If trainees are involved, remember: CMS continues to allow teaching physician virtual presence and direct supervision via real-time tech through December 31, 2025 (see the 2025 PFS materials; link above).
• After the visit
  • Select the CPT (often 99202–99215), add modifier 95 (audio-video) or 93 (audio-only), set POS 10 if the patient was at home or POS 02 otherwise, and submit.
  • If the patient was physically at an eligible originating site (not their home), that facility may bill the Q3014 originating site fee—the 2025 amount is $31.01. CMS keeps the annual table on its Telehealth Services page (link).
  • For RHCs/FQHCs, check your internal cheat sheet for HCPCS G2025 usage and any date-based transitions; Medicare and HHS maintain current RHC/FQHC guidance in their telehealth pages (see CMS FAQ and HHS policy updates above).

Simple frameworks that keep me from second-guessing

On days when the rules feel slippery, I come back to three quick questions:

• Step 1 — Where was the patient? If “home,” that’s POS 10; if anywhere else that’s not home, that’s POS 02. This one choice drives payment routing and clears up half of my confusion (reinforced in the CMS Telehealth FAQ here).
• Step 2 — What modality did we use? Audio-video gets 95. Audio-only gets 93 if Medicare’s conditions are met (and I document the reason). The core E/M code still comes from 99202–99215 for Medicare in 2025 (see PFS fact sheet link).
• Step 3 — How did I select the level? Either by MDM or total time under the 2021/2023 E/M rule set. If by time, my note includes total minutes and what I did during that time.

One more framework that helps: I keep a small “pocket list” of services that are not telehealth but still virtual, like communication technology–based services (brief “virtual check-ins” and remote image evaluations). Medicare handles those separately from telehealth E/M, and the codes/coverage may differ; Medicare keeps the high-level beneficiary explanation on Medicare.gov and links to professional policies from the CMS pages.

Costs, coinsurance, and a few surprises I learned the hard way

Patients ask, “Is a video visit cheaper?” I’ve learned to answer plainly: for most telehealth services under Part B, your cost sharing is the same as in person—after the deductible, you generally pay 20% of the Medicare-approved amount. Medicare states this clearly on its coverage page (link).

• If a patient goes to a facility for telehealth (not their home), that facility can bill the Q3014 originating site fee, and standard deductible/coinsurance rules apply. The 2025 amount is $31.01 (CMS table).
• If the visit is from the patient’s home, there’s no originating site fee—just the professional service, typically paid at the non-facility rate when billed with POS 10 (see the CMS FAQ).
• Medicare Advantage plans must cover Medicare telehealth basics but can add plan-specific rules and cost-sharing designs; my habit is to verify MA instructions every quarter.

As for the looming policy date: non-behavioral home-based telehealth flexibilities are in place through September 30, 2025. HHS tracks this on its policy page (link). I try to phrase this in my notes to patients without drama—“current Medicare rules allow [X] through Sept 30, 2025; we’ll revisit if national policy changes.”

Little habits I’m testing in real life

These are small, boring habits that have saved me from denials and rework:

• One-line modality justification for audio-only: “Audio-only used due to patient’s connectivity limitations; clinician is video-capable.” It takes five seconds and future-proofs the chart against audits under CMS’s 2025 policy (link).
• POS discipline: If I catch myself typing POS 11 for telehealth, I stop. For Medicare in 2025, it’s 02 or 10—full stop (per CMS FAQ, link).
• Smart phrases with dates: I include the policy end date in my template comment so my team doesn’t forget: “Non-behavioral home telehealth covered through 09/30/2025 per HHS policy update (link), subject to change.”
• Resident supervision note: If a trainee is involved, I add: “Teaching physician participated via real-time audio-video during key portions per CMS allowance through 12/31/2025” (summarized in the CMS PFS 2025 fact sheet).

Signals that tell me to slow down and double-check

• Mixed payer signals: Medicare Advantage plan adopts new CPT telemedicine codes, but Original Medicare doesn’t. I re-read the plan bulletin and keep Medicare FFS on 99202–99215 + 95/93.
• Ambiguous location: Patient in a car outside their home—still POS 10 (home) if it’s essentially an extension of the home setting; POS 02 if they’re at another non-home location with staff/resources (I follow CMS’s descriptions).
• Audio-only without a reason: If I can’t justify why audio-only was used, I switch to audio-video when feasible or convert to a non-telehealth service type. The reason sentence matters.
• Facility participation: If another site helped host the connection, I confirm whether they’re billing Q3014 so we don’t confuse the patient with duplicate narratives about fees.

What I’m keeping and what I’m letting go

I’m keeping three principles on a sticky note next to my webcam:

• Clarity beats cleverness: E/M code, modifier, POS—those three anchors solve 90% of problems.
• Document the “why” for audio-only: One line now prevents a lot of explaining later.
• Cost is about parity: I tell patients that, under Part B, their costs are generally the same as in person (see Medicare.gov) so they aren’t surprised by coinsurance.

And what I’m letting go: fighting CPT vs. CMS in my head. CPT did real housecleaning in 2025, but Medicare’s asked us (for now) to stick with 99202–99215 plus the right modifiers and POS. I file away the CPT changes so I’m not blindsided with commercial payers, but I don’t try to force them on Medicare.

FAQ

1) Which modifier do I use for Medicare telehealth in 2025?
Answer: Use 95 for audio-video and 93 for audio-only when Medicare’s criteria are met (patient can’t use or doesn’t consent to video, clinician is video-capable). Pair with POS 10 (home) or POS 02 (not home). See the CMS Telehealth FAQ and 2025 PFS materials for details.

2) Does Medicare recognize the new CPT telemedicine E/M codes?
Answer: CPT 2025 introduced new telemedicine E/M families and deleted 99441–99443, but Medicare hasn’t adopted most of those new E/M codes for payment in 2025. For Original Medicare, bill 99202–99215 with 95/93 and POS 02/10, per CMS’s 2025 PFS fact sheet and FAQ.

3) How should I document an audio-only visit?
Answer: Include the patient’s location, the fact that audio-only was used, and why (patient could not access or declined video). Then document E/M level by MDM or time. This aligns with CMS’s 2025 guidance on audio-only for patients in their home.

4) What if the patient was at a clinic instead of home—who bills Q3014?
Answer: The facility where the patient physically sat during the telehealth encounter may bill Q3014 (originating site fee). In 2025 that fee is $31.01. Your professional claim still uses 99202–99215 plus the appropriate modifier and POS 02.

5) Do patients pay less for telehealth than in-person?
Answer: Generally, no. Under Part B, after the deductible, patients usually owe 20% coinsurance—the same as in-person for most telehealth services. Medicare’s public page says this plainly; always check plan specifics for Medicare Advantage.

Sources & References

• CMS — CY 2025 Physician Fee Schedule final rule (fact sheet)
• CMS — Telehealth FAQ (CY 2025)
• HHS — Telehealth policy updates (2025)
• AMA — How CPT 2025 updated telehealth codes
• CMS — Medicare Telehealth Services list and Q3014 fee table

This blog is a personal journal and for general information only. It is not a substitute for professional medical advice, diagnosis, or treatment, and it does not create a doctor–patient relationship. Always seek the advice of a licensed clinician for questions about your health. If you may be experiencing an emergency, call your local emergency number immediately (e.g., 911 [US], 119).