Understanding New Audio-Only and Brief Telehealth E/M Codes: Documentation, Compliance, and Medicare Guidelines
Written by: Gabriel Aponte Moberg
The audio-only codes 98008 through 98015 require more than ten minutes of synchronous, real-time verbal communication. These services may be selected based on either total time or medical decision-making (MDM). Each code corresponds to specific MDM levels and time thresholds. For example, code 98008 represents straightforward MDM for new patients with a minimum time of 15 minutes, while code 98015 reflects high-complexity MDM for established patients with a minimum of 40 minutes. Regardless of whether the code is selected based on time or MDM, documentation must support that the service included more than ten minutes of medical discussion and clearly indicate that the encounter was conducted using audio-only communication.
Brief Communication Services (98016 and G2252)
Code 98016 is intended for brief, patient-initiated communication technology-based services with an established patient. It reflects 5–10 minutes of medical discussion and replaces HCPCS code G2012. Notably, 98016 is the only telemedicine code in this new family currently recognized by Medicare. It should not be reported if the communication leads to an in-person or telemedicine E/M visit within 24 hours, or if it is related to a visit that occurred within the previous 7 days.
For encounters that exceed 10 minutes but remain brief and do not meet the criteria for a full telemedicine E/M service, HCPCS code G2252 may be reported. G2252 shares the same requirements as 98016, including being patient-initiated and unrelated to a recent or upcoming E/M service, but represents a longer virtual check-in lasting 11–20 minutes and must be conducted by a physician or other qualified health care professional. These requirements must be clearly supported by documentation. G2252 remains billable under Medicare, particularly when the newer AMA audio-only codes are not recognized by the payer.
Medicare Requirements for Modifier 93
Modifier 93 is appended when an E/M service typically delivered via audio-video is instead provided using audio-only technology. To comply with Medicare policy, documentation must specify that:
- The provider was equipped to provide audio-video service;
- The patient declined or was unable to participate via video; and
- The visit was completed using audio-only communication.
Additionally, Modifier 93 may only be used when the place of service is POS 10 (telehealth provided in patient’s home). Use of Modifier 93 with POS 02 is not covered under Medicare policy. Auditors should confirm the presence of these elements in the medical record and validate that the correct POS code was used (CMS, 2024).
In conclusion, the implementation of these new E/M codes for telemedicine services represents an opportunity to refine coding precision and provider engagement. Yet, without a concerted effort to audit proactively and educate consistently, health systems and provider groups risk improper billing and payer denials. Auditors serve a pivotal role in ensuring that these services are not only properly documented and coded, but also meet the evolving standards for telemedicine care delivery.
References
- February 28, 2025. National Correct Coding Initiatives, Chapter I General Correct Coding Policies.
- 2024. 2025 AMA CPT Professional.
- December 9, 2024. Final Rule
About the Author: Gabriel Aponte Moberg
Gabriel Aponte Moberg, MSHIA, RN, RHIA, CPC, COC, CRC, CIC, CPMA, CCC, CHONC, CDEO, CDEI, CCS, CCS-P, CDIP, CCDS, CCDS-O, is a nationally recognized expert in clinical documentation integrity, medical coding, and auditing. With over 20 years of experience in healthcare operations and compliance, he has audited thousands of Evaluation and Management (E/M) services, including critical care, emergency department, inpatient, outpatient office visits, preventive services, and consultations. Gabriel currently serves as the Condition Management and Documentation Manager at Advocate Health, where he oversees value-based coding audits, health informatics initiatives, and provider education. His background spans payer and provider settings, and he is a published author and frequent speaker on topics such as E/M coding, risk adjustment, ICD-10-CM, clinical documentation integrity, and CMS regulatory updates.
