5 Steps to Update Your Audit Plan for Office Visits via Telehealth
Article Reference Code: NAMAS.12.19.2025
Written by: Sonal Patel, BA, CPMA, CPC, CMC, ICDCM
Is your practice overwhelmed by all the noise? When it comes to updating your audit plan, it’s best to keep the focus on each service line you provide. For example, telehealth has received its fair share of flux in recent months. From Medicare proposed rules that became final, to all the coding updates, and when a government shutdown is in the mix, it’s no wonder that practices are left fumbling to meet compliance standards.
If you haven’t started auditing for telehealth services at your practice, that’s ok. Creating compliance initiatives are great proactive steps towards mitigating risk. It’s never too late to begin auditing and avoid unnecessary scrutiny by payors.
Here are five simple steps to start updating your audit plan if you are offering office visits via telehealth through January 30, 2026.
Step 1: Develop a Current Telehealth Payor Matrix
Identify how payors will reimburse you for office visits rendered via telehealth.
Stratify by government and commercial payors.
Step 2: Identify Correct Coding
Place of Service
Medicare prefers place of service (POS) 02 for Telehealth Provided Other than in Patient’s Home and POS 10 for Telehealth Provided in Patient’s Home (which is a location other than a hospital or other facility where the patient receives care in a private residence).
Commercial and Medicaid payors may prefer POS 11 for Office with a modifier identifying the service as rendered via telehealth. In your payor matrix, it is important to verify every payor’s preference when auditing telehealth services.
*The Office of Inspector General (OIG) and Special Investigation Units (SIUs) are identifying POS errors as a top cause of reimbursement errors.
Modifiers
Medicare prefers modifier 95 for Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system.
Modifier GT for service rendered via real-time interactive audio and video telecommunications system is still preferred by some commercial and Medicaid payors. Fun fact – Medicare stopped requiring its use on professional claims as of January 1, 2018.
Medicare prefers modifier 93 for Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. Note, this modifier is for use with CPT® codes listed in Appendix T of the CPT® Manual.
Understand and apply other applicable telehealth modifiers like FQ, FR, GO, and GQ as appropriate.
CPT® Codes
Medicare prefers telehealth services to be billed as Evaluation and Management (E/M) codes for Office and Other Outpatient Services developed by the American Medical Association (AMA) for CPT®. These codes range from 99202-99215 for new and established patients.
Commercial and Medicaid payors may prefer utilizing the new 2025 set of Telemedicine Synchronous Audio and Video E/M codes developed by the AMA for CPT®. These codes range from 98000-98007 for new and established patients.
There are even new 2025 Telemedicine E/M codes for Synchronous Audio Only E/M Services. These codes range from 98008-98015 for new and established patients.
I’m curious: Are these codes even loaded into your electronic medical record (EMR) system?
*The OIG and SIUs are identifying E/M errors as a top cause of reimbursement errors.
Step 3: Ensure Adequate Documentation
Telehealth encounters require adherence to multiple elements to justify reimbursement:
Patient Consent
Documentation must include the patient verbally consenting to a telehealth encounter after all risks to the mode of healthcare delivery have been presented to the patient. A detailed, separate telehealth consent and / or financial responsibility form is also acceptable.
Mode of Communication
Encounter notes must state the HIPAA-compliant mode of communication used during the patient visit. For example, the Office of Civil Rights (OCR) allows use of telehealth platforms that are compliant with HIPAA rules and when they are entering into business associate agreements with platform vendors. Doxy.me and Zoom for Healthcare are two examples of HIPAA-compliant platforms.
Audio-only visits must also be clearly identified in documentation.
Provider / Patient Locations
Documentation must capture the locations of both the provider and the patient during the telehealth service, even if the encounter is audio-only.
Note, Medicare also requires that a provider must be technically capable of using video, but what happens when the patient cannot use or does not consent to video technology? In those instances, the provider must document the patient’s inability to use video or their lack of consent.
Start / Stop Times
Best practice recommendations include documenting start / stop times for time-based office services, like psychotherapy rendered via telehealth.
Step 4: Look for Patterns
Telehealth elements are not the only areas that need to be addressed in your updated audit plan for office visits rendered via telehealth. Don’t forget about the office visits themselves!
Are your office visits rendered via telehealth medically appropriate and meeting the standards and requirements of E/M services?
Start with 10 records for all your providers rendering E/M via telehealth. This sample size is reasonable to capture all areas of possible deficiency, especially if the practice utilizes low, moderate, and high levels of medical decision-making (MDM) or time. Note, these level 3, 4, and 5 E/M codes are currently in the crosshairs of the OIG and various SIUs.
Step 5: Provide Feedback and Education
After performing a detailed analysis of telehealth claims and coordinating documentation, an auditor must document all findings in a comprehensive report and discuss it with the practice.
Delivering feedback is crucial to the provider. This helps the provider understand all aspects of how services are being documented and coded. The audit helps the practice see what has been identified as high-volume or high-risk and allows for ample time to make corrective actions in either documentation or coding, or both.
Always include suggestions and positive findings in education sessions with providers. It’s remarkable how the tone of delivery can impact relationships and build trust.
Record Your Compliance Activity
Auditing is a fundamental part of your compliance initiative. Document the date you received the findings report, as well as the date you had your education session with your auditor. Make note of any improvements you made in documentation or if your EMR system required some tweaks. Great job for taking charge of your revenue by updating your audit plan and ensuring your practice remains compliant!
References: https://www.cms.gov/files/document/telehealth-faq-updated-11-26-2025.pdf
If you have questions about this article or it’s content- Click here to connect with Sonal on LinkedIn
Sonal Patel, BA, CPMA, CPC, CMC, ICDCM
A seasoned healthcare professional who understands the business of medicine and can transform your coding and compliance practices into ones that optimize revenue and alleviate risk. Creator. Content Developer. Host of the Paint The Medical Picture Podcast series that shares valuable industry news, best practice tips, insights, and inspiration.
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