Revised Telehealth Codes Illuminate FWA Changes: A Closer Look at Audio-Only Consultations

CMS Shifts Telehealth Coding Rules: providers Brace for Documentation scrutiny

Washington D.C. – As of january 1,2025,the Centers for Medicare & Medicaid Services (CMS) is implementing significant changes to telehealth reimbursement policies,primarily impacting audio-only consultations. These updates,coupled with heightened scrutiny of documentation practices,are forcing providers to adapt and prioritize accurate record-keeping to avoid potential fraud,waste,and abuse (FWA) claims. The shift represents a critical juncture for the rapidly evolving telehealth landscape.

The End of Audio-Only Codes: A New Era for Telehealth Billing

A cornerstone of these changes is the elimination of Current Procedural Terminology (CPT) codes 99441-99443, which specifically covered audio-only telehealth services. Previously, these codes allowed reimbursement for virtual consultations conducted solely via audio. Now, these codes are obsolete, creating a ripple effect across the industry. In their place, CMS is prioritizing CPT code 98016, formerly HCPCS code G2012, for audio-only interactions. this transition signals a move toward a more thorough approach to telehealth reimbursement, emphasizing the need for interactive services.

Interactive Services: expanding Definitions and documentation Demands

CMS has broadened its definition of “interactive services” to include two-way, real-time audio-only communication – a crucial clarification for providers. Though, this expanded definition is inextricably linked to stricter documentation requirements. Specifically, for services delivered through audio-only channels, providers must meticulously detail the communication encountered with the patient in the medical record. This includes specifying the type of interaction-was it a simple phone call, or a more involved discussion? This emphasis reflects a growing concern about potential misrepresentation of services.

Place of Service matters: Clarifying Locations of Care

the place of service (POS) codes-02 (patient not in their home) and 10 (patient in their home)-remain valid. Yet, documentation surrounding the location where telehealth services are provided is now more critical than ever. Without precise records, it becomes increasingly challenging to verify whether services were legitimately delivered remotely or potentially duplicated through in-office visits. Providers must diligently state whether services were rendered from their practice address or home address, allaying concerns about billing discrepancies.

Potential for FWA: Increased Audit risk

Industry experts anticipate an uptick in medical record audits following these policy changes. The lack of specific audio-only codes increases the risk of FWA, especially when documentation is incomplete or inaccurate. Providers might, for instance, attempt to register a telephone conversation as a failed audio-visual connection, leading to improper reimbursement. Similarly, a failure to clearly establish the location of care-whether it occurred in the patient’s home or the provider’s-can lead to double billing or inappropriate billing for services outside the permitted timeframe.

Preventing Fraud Through Diligent Documentation

To mitigate these risks, health plans are urged to reinforce their documentation guidelines and meticulously verify the accuracy of place of service codes. Moreover, a comprehensive review of the 2025 AMA CPT and HCPCS code books is paramount. Auditors will be scrutinizing medical records for evidence of compliant documentation, emphasizing the need to prove the nature of the interaction and the precise location of the service delivery.

Expert Insight: Cotiviti’s 360 Pattern Review™

Navigating these complex changes and proactively preventing improper telehealth coding requires a strategic approach. Cotiviti’s 360 Pattern Review™ offers a robust solution for health plans, providing unparalleled insights into emerging fraud schemes and aiding in the identification of inaccurate claims.By leveraging advanced analytics, this technology empowers organizations to safeguard their members and maintain financial integrity. Learn more about 360 Pattern Review™ today.

Key Takeaways for Telehealth Providers

• Audio-only CPT codes 99441-99443 are obsolete as of 2025.
• “interactive services” are now more broadly defined by CMS.
• Detailed documentation of patient communication is critical.
• Place of service codes 02 and 10 remain relevant, but accurate documentation is paramount.

Frequently Asked questions about 2025 Telehealth Coding Updates

• Q: What happens to audio-only telehealth codes?

  A: These codes (99441-99443) are no longer valid for reimbursement starting in 2025.

• Q: What is ‘interactive services’?

  A: CMS has redefined “interactive services” to include two-way, real-time audio-only communication, requiring detailed documentation.

• Q: How does the place of service code impact telehealth?

  A: Accurate documentation of where the telehealth service was provided (patient’s home or provider’s office) is essential to avoid billing errors.

• Q: Will CMS continue to allow providers to use their practice address for home telehealth?

  A: Yes, this policy remains in effect.

• Q: What must providers document when using audio-only telehealth?

  A: They must document the type of communication with the patient,including the mode of interaction.

• Q: What should health plans do to prepare for these changes?

  A: They should ensure proper documentation guidelines are in place and diligently verify place of service codes.

• Q: Where can I find more facts about these changes?

  A: Consult the official CMS guidance and the 2025 AMA CPT and HCPCS code books.

Share this article with your network! Comment below with your thoughts on these changes.

What specific changes to the Facility Fee Waiver Adjustment (FWA) now impact reimbursement rates for audio-only telehealth consultations compared to during the Public Health Emergency (PHE)?

Understanding the Shifting Landscape of Telehealth Reimbursement

The world of telehealth, and specifically reimbursement for telehealth services, is constantly evolving. Recent revisions to telehealth codes, notably concerning the Facility Fee Waiver Adjustment (FWA), have important implications for providers offering audio-only telehealth consultations. These changes demand a thorough understanding to ensure accurate billing and continued access to care for patients. This article breaks down the key updates and provides practical guidance for navigating this new terrain.

What is the Facility Fee Waiver Adjustment (FWA)?

Initially implemented during the Public Health Emergency (PHE), the FWA allowed Medicare to reimburse telehealth services at the same rate as in-person visits, even when delivered in non-customary locations – like a patient’s home. This was crucial for expanding telehealth access during a time of critical need. However, with the end of the PHE, the FWA has undergone revisions, impacting how certain telehealth modalities, especially audio-only visits, are reimbursed.

The core change revolves around the location of the provider and the patient.Previously, location was less critical. now, stricter guidelines apply, particularly regarding the provider’s location and whether it qualifies as a “distant site.”

Decoding the Revised Telehealth Codes for Audio-Only Consultations

Several CPT codes are directly affected by these changes. Here’s a breakdown:

99441-99443 (Telephone Evaluation of Medical History or Review of Medical Records): These codes remain relevant for brief, non-interactive phone calls. Though, they are generally reimbursed at a lower rate than full telehealth consultations.

G2012 (Remote Physiologic Monitoring, 20 minutes or more of clinical staff/physician time per calendar month): While not strictly audio-only, this code ofen incorporates phone consultations for data review and patient education. FWA implications here depend on the monitoring setup and provider location.

G2010 (Remote Physiologic Monitoring, device(s) with daily transmission/monitoring, 30 days): Similar to G2012, the FWA impacts reimbursement based on the overall remote monitoring program.

99211-99214 (Office or other outpatient visit): These codes can be used for audio-only visits if they meet all the requirements of an equivalent in-person visit, including a extensive evaluation and medical decision-making. This is where the FWA changes are most impactful.

Key Considerations:

Distant Site Location: The provider must be located in a designated Health Professional Shortage Area (HPSA) or a Rural Census Tract to qualify for full reimbursement under the revised FWA for certain audio-only services.

Established Patient Relationship: A pre-existing relationship with the patient is frequently enough required for audio-only visits to be reimbursed at a higher rate.

Medical Necessity: All telehealth services, including audio-only, must be medically necessary.

The Impact on Rural Healthcare and Access to Care

The revised FWA has sparked concern among healthcare providers serving rural communities. Audio-only telehealth has been a lifeline for patients in areas with limited broadband access or transportation options. Restricting reimbursement based on provider location could disproportionately affect these vulnerable populations, possibly exacerbating healthcare disparities.

Several rural hospitals and clinics have reported a decrease in revenue from telehealth services following the FWA changes. This has led to calls for legislative action to reinstate broader telehealth coverage and ensure equitable access to care.

Benefits of Audio-Only Telehealth – Why It Still Matters

Despite the reimbursement challenges, audio-only telehealth continues to offer significant benefits:

Increased Accessibility: Reaches patients without broadband internet or video capabilities.

Convenience: Offers a convenient option for follow-up appointments, medication refills, and brief consultations.

Cost-effectiveness: Can reduce healthcare costs by minimizing travel time and expenses.

Improved Patient Engagement: Allows for more frequent check-ins and proactive care management.

Mental Health Support: Particularly valuable for delivering teletherapy and mental health counseling.

Practical Tips for Navigating the New Regulations

Here are actionable steps providers can take to adapt to the revised FWA:

1. Verify Provider Location: Confirm whether your practise is located in a HPSA or Rural Census Tract.
2. Document Medical Necessity: Thoroughly document the medical necessity of each audio-only consultation.
3. Establish Patient Relationships: Prioritize establishing established patient relationships before offering audio-only services.
4. Stay Updated on Coding Changes: regularly review updates from CMS (Centers for Medicare & Medicaid Services) regarding telehealth coding and reimbursement.
5. Consider Hybrid Models: Explore combining audio-only consultations with other telehealth modalities (video, remote monitoring) to maximize reimbursement opportunities.
6. Utilize Telehealth Platforms: Invest in telehealth platforms that facilitate accurate coding and billing.
7. Advocate for Policy Changes: Engage with professional organizations and policymakers to advocate for broader telehealth coverage.

Real-World Example: A Rural Clinic’s Response

A small, rural