Telehealth CPT Codes: The Complete 2026 Billing Guide

Telehealth CPT codes mean two different things, and mixing them up is one of the most common causes of denied claims. One's the new AMA-created 98000 code family built specifically for telemedicine, and the other is the older approach of billing a standard office visit code with a telehealth place-of-service designation. Which one applies depends entirely on the payer sitting across from your claim.

This guide breaks down both systems, the audio-only and virtual check-in codes, and the modifiers that determine whether a telehealth claim gets paid.

The Two Systems: 98000 Family vs. Standard E/M Codes

In 2025, the AMA introduced a dedicated telehealth E/M code family, CPT 98000–98016, built specifically for virtual visits rather than adapted from in-person codes. Commercial payers largely accept this new family. Medicare mostly doesn't.

For Medicare, providers continue billing standard office visit codes (99202–99215) for new and established patients, paired with a telehealth place-of-service code and modifier. CMS classifies most of the 98000–98015 range as invalid for payment purposes, so Medicare will deny claims submitted under those codes.

The One Exception: CPT 98016

CPT 98016, the virtual check-in code, is the single exception Medicare pays from the new 98000 family. It replaced HCPCS G2012 and covers brief communication technology-based services - a quick check-in with an established patient that doesn't rise to the level of a full visit.

Virtual check-in codes like 98016 are meant for exactly this: real-time communications, typically 10 minutes or less, where a fuller E/M visit isn't clinically warranted.

Place of Service and Modifiers: What Actually Determines Payment

For Medicare claims using the standard 99202–99215 series, three elements determine whether the claim reflects the visit accurately:

• Place of Service (POS) 02 - Telehealth provided somewhere other than the patient's home, paid at the facility rate
• Place of Service (POS) 10 - Telehealth provided in the patient's home, paid at the higher non-facility rate
• Modifier 95 - Indicates the visit was conducted via audio-video technology
• Modifier 93 - Indicates the visit was audio-only

Choosing the wrong POS code is a common, quiet source of underpayment, since POS 02 and POS 10 pay different rates for functionally similar visits.

Audio-Only Telehealth CPT Codes

Audio-only visits - phone calls without video - have their own specific billing requirements that differ from standard telehealth. Medicare requires modifier 93 to flag an audio-only encounter, and documentation should confirm that audio-video was unavailable or the patient declined it, not simply skipped by default.

Audio-only billing generally requires at least 10 minutes of medical discussion, even when the code is ultimately selected based on medical decision-making complexity rather than time.

Where Telephone-Only and Virtual Check-In Codes Diverge

Telephone-only CPT codes (the older 99441–99443 series) were deleted effective January 1 2025, and no longer pay under current Medicare rules - a detail that trips up practices still coding from outdated references. Current audio-only visits should instead use the standard E/M codes with modifier 93 attached, not the retired telephone-specific codes.

Virtual check-ins remain distinct from both audio-only visits and full telehealth E/M visits. They're brief, provider-initiated or patient-initiated communications meant to determine whether an in-person or full telehealth visit is needed - not a substitute for either.

Federal Telehealth Flexibilities Extending Through 2027

Several pandemic-era flexibilities remain in effect well into 2026 and beyond. Per CMS's official record of changes to the Medicare telehealth services list, additions and deletions to covered telehealth services are made annually through the Physician Fee Schedule rulemaking cycle, with the current flexibilities - including no geographic restrictions and coverage for patients receiving care from home - running through December 31, 2027.

For the specific billing mechanics behind those flexibilities, Medicare's telehealth payment and reimbursement policies lay out how originating site rules, provider eligibility, and FQHC/RHC billing all apply during this extended period, including a separate behavioural health in-person visit waiver extending through January 1, 2028.

Not All Programs Follow the Same Telehealth Rules

These extensions don't apply uniformly across every Medicare program. Annual Wellness Visits, for instance, follow their own specific coverage logic - the Medicare vs. commercial Annual Wellness Visit CPT code guide confirms that AWVs can be delivered via two-way audio-video telehealth, but audio-only phone calls specifically do not qualify for AWV billing, a distinction that catches practices assuming all telehealth rules apply the same way across every program.

How This Connects to Broader Care Management Billing

Telehealth billing rarely exists in isolation from the rest of a practice's Medicare programs. The G2211 billing and reimbursement guide explains how this add-on code expanded in 2026 to cover telehealth and audio-only visits, meaning practices running longitudinal chronic care relationships can now capture this add-on across virtual encounters, not just in-person ones.

Similarly, the Advanced Primary Care Management overview explains how APCM integrates directly with telehealth, allowing non-emergency check-ins and follow-up visits to happen virtually - though APCM cannot be billed alongside virtual check-ins for the same patient in the same month, a bundling rule worth confirming before mixing programs.

Remote Monitoring Codes Now Require Audio-Video Interaction

Newer remote monitoring codes are also tightening their telehealth requirements. This RPM solutions guide for medical practices covers CPT 99470, which specifically requires at least one real-time audio or video interaction as part of qualifying documentation - reinforcing that "telehealth" isn't a single monolithic billing category but a set of interconnected, code-specific requirements across RPM, RTM, and standard E/M services.

Broader 2026 rule changes have also made virtual direct supervision permanent, a shift covered in detail in CMS's 2026 RPM rule breakdown, allowing supervising clinicians to oversee care teams remotely via real-time audio-video technology.

Choosing a Telehealth Platform That Handles This Correctly

Given how fragmented these rules are across payers and programs, this buyer's guide to virtual health platforms is worth reviewing before selecting a vendor - a platform that automatically applies the correct POS code, modifier, and code family based on payer and visit type reduces the manual judgment calls that otherwise generate denials.

Conclusion

Telehealth CPT codes split into two systems that don't behave the same way: the AMA's dedicated 98000 family for commercial payers, and Medicare's standard E/M codes paired with POS designations and modifiers. Audio-only visits, virtual check-ins, and the now-retired telephone-only codes each carry their own specific documentation requirements. With federal flexibilities extended through 2027 and telehealth increasingly integrated into chronic care and RPM programs, getting the code, modifier, and POS combination right on every claim is what separates clean reimbursement from a steady stream of avoidable denials.

Frequently Asked Questions

What are the main telehealth CPT codes for 2026?

The AMA's 98000–98016 family covers telehealth E/M visits for commercial payers, while Medicare generally uses standard office visit codes 99202–99215 with the appropriate telehealth POS code and modifier.

Does Medicare pay the new 98000–98016 telehealth codes?

CMS generally classifies 98000–98015 as invalid for payment under the Physician Fee Schedule. CPT 98016, the virtual check-in code, is the exception, and Medicare reimburses it.

What modifier is used for audio-only telehealth visits?

Modifier 93 indicates an audio-only encounter, while modifier 95 indicates an audio-video telehealth service. Using the appropriate modifier helps ensure accurate claim processing.

Are the old telephone-only CPT codes 99441–99443 still billable?

No. CPT codes 99441–99443 were deleted effective January 1, 2025. Practices should follow current Medicare and payer-specific requirements for reporting audio-only services.

What's the difference between a virtual check-in and an audio-only visit?

A virtual check-in, reported with CPT 98016, is a brief communication used to determine whether a more comprehensive visit is needed. An audio-only visit involves a complete telehealth encounter conducted by telephone.

How long do current Medicare telehealth flexibilities last?

Most current Medicare telehealth flexibilities, including coverage for patients receiving telehealth at home, are extended through December 31, 2027. Practices should verify CMS updates as policies change.

Does Place of Service code affect telehealth reimbursement?

Yes. POS 02 identifies telehealth provided outside the patient's home, while POS 10 identifies telehealth provided in the patient's home. The selected POS can affect Medicare reimbursement.