Telehealth Codes & FWA: Recent Changes Explained
- The rise of telehealth enhances access to care, but also introduces opportunities for fraud, waste, and abuse (FWA).
- The Centers for medicare & medicaid Services (CMS) has updated telemedicine guidelines, especially impacting audio-only services.
- CMS clarifies that direct supervision via real-time audio and visual interactive services remains permissible.The definition of "interactive services" now includes two-way, real-time audio-only communication if a patient cannot...
The latest CMS updates demand immediate action: Understanding new telehealth codes is essential to avoid fraud, waste, and abuse (FWA). In 2025, audio-only telehealth coding undergoes important changes, including the deletion of CPT codes 99441-99443 and the introduction of CPT code 98016 to replace HCPCS code G2012. Health plans and providers must now meticulously document communication types and verify the place of service to ensure accurate billing. Failing this can lead to improper reimbursement. Vigilance in documentation,along with a keen understanding of the place of service requirements,is key for compliance. news Directory 3 can help you stay informed. Discover what’s next in navigating these critical shifts.
Telehealth Fraud Prevention: Navigating Audio-Only Coding changes
Updated June 8, 2025
The rise of telehealth enhances access to care, but also introduces opportunities for fraud, waste, and abuse (FWA). Whether due to unintentional errors or malicious intent, providers and health plans must stay vigilant.Coding errors and place-of-service inaccuracies are common issues.
The Centers for medicare & medicaid Services (CMS) has updated telemedicine guidelines, especially impacting audio-only services. These changes, effective in 2025, include deleting CPT codes 99441-99443 and introducing CPT code 98016 to replace HCPCS code G2012.
CMS clarifies that direct supervision via real-time audio and visual interactive services remains permissible.The definition of “interactive services” now includes two-way, real-time audio-only communication if a patient cannot or does not consent to video, provided this is documented. Place of service (POS) codes 02 and 10 remain applicable,and physicians can still list their practice address when providing telehealth from home.
Potential FWA schemes often surface during medical record audits, particularly in documentation. Without audio-only codes, providers must clearly document the communication type. As a notable example, failing to properly document a telephone call after a failed audio-visual connection coudl lead to inappropriate reimbursement. Issues also arise concerning the place of care and service duration, potentially leading to double-billing or inaccurate time records.
To enhance FWA prevention, health plans must adhere to documentation requirements for telehealth services starting in 2025 and verify place of service. Neglecting these details can lead to over- or under-billing, or even billing for unfeasible days. Reviewing coding updates in the 2025 AMA CPT code book and 2025 HCPCS code book is also essential. Medical record auditors must scrutinize patient records for discrepancies that technology might miss.
What’s next
As telehealth evolves, staying current with coding changes and documentation needs is crucial for preventing fraud, waste, and abuse. Vigilance and partnering with trusted experts can ensure accurate billing and compliance.