Telehealth has become a cornerstone of modern healthcare delivery, offering flexibility for both providers and patients. However, navigating the billing rules can be a challenge. At Compass Healthcare Consulting, we help practices streamline their revenue cycle, and a key part of that is mastering telehealth reimbursement.
This guide breaks down the essential billing guidance for non-Medicare patients to ensure your practice is coding correctly and maximizing appropriate reimbursement.
The Foundation: What Qualifies as a Billable Telehealth Service?
A billable telehealth service is a synchronous (real-time) interaction with a patient via audio-video or audio-only communication. It can serve as a substitute for an in-person visit when clinically appropriate and with patient consent. These services are billable for both new and established patients.
Crucial Rule: Telehealth services must occur on a separate calendar day from any other Evaluation and Management (E/M) service. If you provide multiple E/M services on the same day, you must combine the time and/or medical decision-making (MDM) and bill them as a single service.
How to Select the Correct CPT Code
For non-Medicare patients, you will use a specific set of CPT codes (98000-98016). Code selection is based on one of two factors:
The complexity of Medical Decision Making (MDM), or
The total time spent on the encounter on the date of the service.
Audio-Video Services (CPT Codes 98000-98007)
No minimum time requirement. Code selection is based purely on MDM level or total time.
Audio-Only Services (CPT Codes 98008-98015)
Require more than 10 minutes of medical discussion – or soonest available appointment.
For established patient encounters lasting 5-10 minutes, you may report CPT 98016, but only if it is not related to a visit in the previous 7 days and does not lead to a visit within the next 24 hours.
Discussions under 5 minutes are not separately billable.
Key Reporting Table for Non-Medicare Patients
| Patient Type | MDM Level / Time | Audio-Video CPT Code | Audio-Only CPT Code |
|---|---|---|---|
| New | Straightforward / 15 min | 98000 | 98008 |
| Low / 30 min | 98001 | 98009 | |
| Moderate / 45 min | 98002 | 98010 | |
| High / 60 min | 98003 | 98011 | |
| Established | Straightforward / 10 min | 98004 | 98012 |
| Low / 20 min | 98005 | 98013 | |
| Moderate / 30 min | 98006 | 98014 | |
| High / 40 min | 98007 | 98015 | |
| Established | 5-10 min (Time-Based) | N/A | 98016 |
What Not to Bill
Do not report telehealth codes for routine communications that do not require full E/M, such as:
Sharing lab results
Scheduling a follow-up appointment
Brief check-ins that don’t meet the MDM level or time thresholds.
Documentation is Key
Your medical record must support the service billed. Ensure documentation includes:
Patient, family, or caregiver’s informed consent for telehealth
Start and stop times of the encounter
Technology used (audio-video or audio-only) and reason if video wasn’t used
The patient’s and provider’s locations
Need help navigating your telehealth billing? The rules are complex and ever-changing. Compass Healthcare Consulting offers expert guidance to ensure your practice remains compliant and optimized for reimbursement. Contact us today for a consultation.
