Telehealth After October 1, 2025: What Every Medical Practice Must Do to Stay Compliant and Profitable

Telehealth transformed how medical practices operate. During the pandemic, the Centers for Medicare & Medicaid Services (CMS) granted broad flexibilities that let clinicians care for patients at home, bill for audio-only phone visits, and use almost any digital platform to keep care moving. These changes created unprecedented access and new revenue opportunities for primary care, specialty clinics, and multi-site practices.

That era of open-ended telehealth reimbursement is about to change. Starting October 1, 2025, Medicare will implement new site-of-service and billing rules that directly affect how physicians, advanced practitioners, and practice administrators schedule visits, document care, and secure payment. Commercial payers are already signaling that they will follow Medicare’s lead.

For physician groups and medical practices of every size this is more than a technical adjustment. These changes can reshape revenue streams, staffing patterns, patient experience, and long-term business strategy.
This article provides a comprehensive guide to the coming shift. You will learn:
✅ What exactly changes on October 1, 2025, and why CMS is drawing a clear line between the temporary pandemic policies and permanent telehealth regulations
✅ How the new CPT code 98016 replaces the older audio-only telephone visit codes and what that means for compliance and revenue
✅ The operational and financial implications for medical practices across all specialties
✅ Concrete steps practice leaders must take—from updating scheduling workflows to educating providers and patients—to remain compliant and profitable.

By understanding the rationale behind the new rules and preparing strategically, medical practices can continue to offer convenient virtual care while protecting revenue and avoiding audit risk.
Pandemic Telehealth Expansion: A Quick BackgroundBefore the COVID-19 Public Health Emergency, Medicare telehealth was tightly limited. Patients generally had to be in a rural area and physically present at an approved originating site such as a hospital or clinic, to receive covered telehealth services. Audio-only visits were not reimburse,d and most physicians used telehealth only occasionally.

The Public Health Emergency changed everything. To maintain access to care, CMS temporarily allowed patients to receive telehealth visits from home, permitted billing for audio-only services using CPT codes 99441 to 99443 for brief telephone visits, and expanded the list of eligible providers and services.
These flexibilities fueled an explosion in telehealth use. Practices invested in telehealth platforms, trained staff, and wove virtual care into daily operations. Many organizations built entire business lines such as remote chronic care management, same-day urgent visits, and hybrid scheduling around these temporary rules.

Why October 1, 2025 Matters
​When Congress extended pandemic-era telehealth flexibilities, it set September 30, 2025 as the final date for many of those provisions. CMS has confirmed that beginning October 1, 2025, Medicare will revert to a more traditional telehealth framework:
• Patients must be at an approved originating site such as a rural clinic, hospital, or federally qualified health center for most telehealth services to be reimbursed
• Home-based telehealth visits for most specialties will no longer be covered unless the patient meets very specific exceptions
• Audio-only visits are no longer broadly payable. The telephone E/M codes 99441 to 99443 were deleted

January 1, 2025. CMS has introduced a new brief-communication code, CPT 98016, but it is not a direct substitute for the deleted telephone codes
For medical practices, this is a fundamental shift. The convenience of checking in with patients at home through a quick phone call will no longer generate revenue under Medicare rules. Without proactive planning, practices risk denied claims, lost revenue, and compliance exposure.

CPT 98016: The New Brief Communication CodeCPT 98016 is now Medicare’s only payable option for a brief technology-based interaction that is shorter and less formal than a full telehealth visit.
Purpose and format
✅ Short clinical discussion to assess a problem, give advice, or decide whether an in-person visit is needed
✅ Telephone, video, or other HIPAA-compliant two-way communication
✅ Five to ten minutes of professional time
✅ Must be patient-initiated or performed with documented patient consent when staff offers the service
Critical billing conditions
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• The communication cannot occur within seven days of a related E/M service or procedure for the same problem
• It cannot lead to an in-person or telehealth E/M visit within 24 hours or the soonest available appointment for the same problem
• Documentation must include patient consent, time spent, and the clinical decision made
Because of these guardrails, a routine follow-up call a few hours after a medial branch block to document pain relief does not qualify for 98016. That contact is considered part of the procedure’s global service and is not separately billable.

Financial reality
Reimbursement for 98016 is modest—generally in the $15 to $20 range depending on locality. It can still be valuable for brief, patient-initiated interactions that meet all criteria, but it cannot replace the revenue once generated by 99441 to 99443.

Originating Sites and Licensing Requirements:
The patient’s originating site is the physical location where the patient sits during the telehealth visit. Beginning October 1 2025, Medicare will pay for most telehealth services only if the patient is physically present at an approved site such as:
✅ Physician or practitioner office
✅ Hospital outpatient department or critical access hospital
✅ Rural health clinic or federally qualified health center
✅ Skilled nursing facility
✅ Community mental health center
✅ Hospital-based or independent renal dialysis center
✅ Mobile stroke unit or other CMS-approved facility
✅ Patient’s home only if the service qualifies for a permanent exception such as specific behavioral health services.

Every telehealth note and claim must clearly document the patient’s exact location and the name of the qualifying facility.

Licensing is equally important.
The provider must hold an active license in the state where the patient is physically located at the time of the visit.
Example: A cardiologist licensed in New York who delivers a telehealth visit to a patient sitting in New Jersey must also be licensed (or hold a telehealth permit or compact privilege) in New Jersey, because New Jersey is the patient’s originating site.

Key tips:
• Capture the patient’s exact location in every telehealth note and on the billing claim
• Verify provider licensure or telehealth reciprocity for every state where patients may be located
• Maintain a crosswalk of provider licenses and patient locations in the credentialing system
• For multi-state practices, consider joining the Interstate Medical Licensure Compact to simplify multi-state licensing

2025 Billing & Coding Guide for Telehealth
Beyond CPT 98016, the AMA added a set of new 2025 CPT codes for telehealth, though CMS has not adopted them for Medicare payment. Practices need to know the difference between what exists in the CPT book and what CMS actually reimburses.

New CPT Telehealth Codes (2025)
• 98000–98007: synchronous audio-video telehealth E/M visits (new and established patients)
• 98008–98015: synchronous audio-only telehealth E/M visits (new and established patients)
• 98016: brief communication technology-based service (replaces G2012)

CMS Coverage Reality
• Medicare continues to require E/M codes 99202–99215 for telehealth office/outpatient visits.
• CMS does not cover 98000–98015 for standard telehealth visits.
• 98016 is the only newly recognized code, under the strict conditions noted above.

Billing Tips for 2025
✅ Use E/M codes 99202–99215 for full telehealth visits, with modifier 95 when video is used and the patient is at an approved originating site.
✅ For audio-only encounters allowed by CMS exceptions, use modifier 93 and document why video was not possible.
✅ Ensure the correct Place of Service (POS): POS 02 when the patient is at an approved site other than home, POS 10 when the patient is at home for an approved service.
✅ Remove deleted codes 99441–99443 from your charge-capture system to avoid denials.
✅ Keep payer-specific grids updated because some commercial plans or Medicaid programs may adopt 98000-series codes for their own telehealth coverage even if Medicare does not.

Operational and Financial Impact for Medical Practices
The new rules require careful changes to scheduling, documentation, and revenue-cycle management.
Scheduling and verification
Front-desk and scheduling teams must confirm that a Medicare patient will be physically present at an approved site before booking a telehealth slot. Quick screening questions and clear patient instructions will help prevent denials.
EHR updates and documentation
Electronic health records should capture the patient’s originating site for any telehealth encounter and provide fields for consent and time documentation when CPT 98016 is used. Clinicians should note when a call is strictly post-procedure monitoring so it is correctly bundled.
Revenue cycle and forecasting
Revenue-cycle teams need to remove 99441 to 99443 from charge capture systems, monitor denial trends, and adjust financial forecasts. Practices should plan for a reduction in telehealth revenue and a possible rise in in-person visits that require more staff and exam room time.
Patient communication
Patients who are accustomed to home-based telehealth will need clear explanations of the new requirements. Use portal messages, printed notices, and staff scripts to help patients understand why some phone check-ins can no longer be billed and why in-person visits may be necessary.
Compliance safeguards
Misusing CPT 98016 or continuing to bill deleted telephone codes creates audit risk. Practices should conduct internal chart reviews and provide ongoing staff education to ensure claims meet documentation standards.

Recommended Action Plan
To stay compliant and profitable, practices should begin preparing now.

1. Audit current telehealth services and identify encounters that rely on home-based visits or deleted codes
2. Update scheduling protocols so staff confirm patient location and payer eligibility before every telehealth appointment
3. Revise EHR templates to capture originating site, patient consent, and timing for CPT 98016
4. Educate clinicians and billers on the strict conditions for 98016 and proper use of modifier 25 when an E/M is performed the same day as a minor procedure
5. Communicate with patients about the new requirements and provide information on approved originating sites or alternative care options
6. Monitor denials and revenue trends and adjust budgets to reflect reduced telehealth income

The broad telehealth flexibilities of the pandemic allowed medical practices to reach patients in ways that once seemed impossible. Those flexibilities are ending. Beginning October 1, 2025, Medicare will require an approved originating site for most telehealth services, the familiar audio-only telephone codes are gone, and CPT 98016 stands as the sole brief communication code with strict usage limits.

Medical practices that act now will avoid claim denials and audit risk while preserving patient access. Audit policies, train staff, update EHR templates, and communicate proactively with patients. Aligning with the new rules not only keeps your practice compliant but also creates an opportunity to streamline workflows, strengthen revenue integrity, and build a sustainable hybrid-care model for the future.
By approaching this change with a clear strategy and disciplined execution, your organization can continue to deliver high-quality care and remain profitable in the new telehealth era.

References for Readers
Medicare Telehealth Coverage: https://www.medicare.gov/coverage/telehealth
HHS Telehealth Policy Updates: https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates
CMS MLN Telehealth & RPM Booklet: https://www.cms.gov/files/document/mln901705-telehealth-remote-patient-monitoring.pdf
NCCI Policy Manual 2025 – Modifier 25: https://www.cms.gov/files/document/01-chapter1-ncci-medicare-policy-manual-2025finalcleanpdf.pdf
AMA CPT 2025 Telehealth Update (includes 98000–98016): https://www.ama-assn.org/practice-management/cpt/how-ama-meets-need-new-telehealth-cpt-codes

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Telehealth After October 1, 2025: What Every Medical Practice Must Do to Stay Compliant and Profitable

About the Author
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Pinky Maniri-Pescasio is the CEO and Founder of GoHealthcare Practice Solutions LLC, a nationally recognized consulting firm specializing in medical billing, revenue cycle management, and healthcare operations. With nearly 30 years of healthcare leadership experience, she has guided physician groups, specialty clinics, multi-site practices, and ambulatory surgery centers through complex regulatory changes, coding updates, and large-scale operational transformations.
Pinky is known for turning complex policy into clear, actionable strategies that keep medical practices compliant and profitable. She leads organizations through CMS rule updates, CPT code changes, and telehealth policy shifts—most recently helping practices prepare for the October 1, 2025 Medicare telehealth transition.
Beyond consulting, Pinky is a sought-after speaker and thought leader, mentoring medical-practice executives and championing clarity and innovation in healthcare revenue cycle management.
Connect with Pinky to stay ahead of regulatory changes and build a stronger, more profitable medical practice.