In December 2025, telehealth medical coding guidelines are shaped by a critical divergence between new AMA standards and CMS telehealth 2025 policies. While the AMA introduced new telehealth CPT codes 2025, Medicare continues to rely on traditional E/M codes, creating significant telehealth coding compliance and medical coding compliance updates challenges. Additionally, several pandemic-era Telehealth Policy Changes are scheduled to expire on January 30, 2026, increasing Medicare telehealth audit risk for providers and billing teams.

1. Medicare Reporting Requirements

Under CMS telehealth billing guidelines 2025, Medicare does not recognize the new 98000–98015 telehealth CPT codes 2025, with the exception of CPT 98016. For Medicare claims in December 2025, providers must follow established telehealth billing guidelines to avoid telehealth billing errors:

• Use traditional E/M codes:
  Continue billing 99202–99215, in line with E/M coding changes 2025 and Medicare policy.
• Apply Modifiers correctly:
  • Modifier 95: For synchronous audio-video telehealth services
  • Modifier 93: Mandatory for audio only telehealth coding when video is unavailable or declined

• Place of Service (POS):
  • POS 10: Telehealth provided in the patient’s home (reimbursed at the non-facility/office rate).
  • POS 02: Telehealth provided in other locations (reimbursed at the facility rate). 

Accurate modifier and POS usage is essential to reduce telehealth billing errors and strengthen telehealth coding compliance.

2. December 2025 Status of Flexibilities

Due to recent legislative extensions, several temporary Telehealth Policy Changes remain active through January 30, 2026, directly impacting telehealth medical coding guidelines:

• Geographic Restrictions:
  Suspended—Medicare beneficiaries may receive telehealth services from any location, including their home.
• Behavioral Health Telehealth :
  Permanent home-based coverage and audio only telehealth coding remain in place. However, the requirement for a prior in-person visit is delayed until January 1, 2026.

• Direct Supervision: Virtual presence via real-time audio-video is still permitted to meet “direct supervision” requirements through December 31, 2025. The allowance for “direct supervision” to be met via real-time audio and video (instead of physical presence) is slated to end, creating new telehealth coding compliance risks.
• FQHCs and RHCs: Federally Qualified Health Centres and Rural Health Clinics may continue acting as distant site providers for non-behavioural telehealth until January 30, 2026.

3. Teaching Physician Rules:

Virtual presence requirements for teaching physicians involved in Medicare telehealth services are currently set to sunset.

In December 2025, Teaching Physician rules entered a pivotal transition as temporary pandemic-era flexibilities concluded. Effective January 1, 2026, Medicare finalized policies that significantly impact telemedicine coding changes 2026 and telehealth documentation requirements.

1 .Permanent Policy for Telehealth Services

CMS has permanently authorized teaching physicians to meet presence requirements virtually only when the service qualifies as a Medicare telehealth service under CMS telehealth 2025 rules:

• Three-Way Connection: The teaching physician, resident, and patient can all be in separate locations.
• Technology Requirement: Virtual presence must be through real-time, two-way audio and visual communication. Audio-only telehealth coding is strictly prohibited for teaching physician presence.
• Documentation: Clear telehealth documentation requirements must reflect the teaching physician’s virtual presence during key and critical portions of care to avoid Medicare telehealth audit risk.

2. Return to Physical Presence for In-Person Care

As of December 31, 2025, the temporary waiver allowing virtual supervision for residents’ in-person visits in all settings has expired. 

• Requirement: For services furnished in person, the teaching physician must again be physically present during the key portion of the service.
• Rural Exception: The long-standing exception for certain services furnished by residents in designated rural areas (which allows for general supervision) remains in effect.

3. Expiration of General “Virtual Presence” Flexibilities

Prior to this update, teaching physicians could satisfy certain direct supervision requirements virtually. However, under updated CMS telehealth 2025 rules and evolving telehealth policy changes, these flexibilities are now significantly narrowed, increasing Medicare telehealth audit risk if not followed correctly.

• Scope Narrowing:
  While direct supervision via real-time audio-video has been made permanent for select diagnostic tests and low-risk incident-to services (such as 99211), this flexibility does not apply to standard teaching physician “key portion” requirements for in-person E/M services. Providers must align with updated telehealth coding guidelines 2025 and E/M coding changes 2025 to avoid telehealth billing errors.
• Global Surgeries:
  Virtual presence is explicitly excluded for any surgical procedures with 10-day or 90-day global periods, reinforcing stricter telehealth medical coding guidelines and heightened telehealth coding compliance

4. Primary Care Exception

CMS continues to evaluate the Primary Care Exception, which allows teaching physicians to bill for certain low-to-mid-level E/M services (typically 99202–99203 and 99211–99213) without being present for the key portion of the visit, provided specific supervision, training, and telehealth documentation requirements are met. Accurate application of this exception is critical to reduce Medicare telehealth audit risk.

• Behavioral Health In-Person Requirement:

A previously delayed requirement for patients to have an in-person visit within six months of initiating telehealth behavioural health services is expected to resume in 2026, marking a key telemedicine coding change 2026 and reinforcing stricter telehealth coding compliance standards.

Continued 2025 Standards (Through Dec 31) for Telehealth Medical Coding 

For the remainder of December 2025, providers should continue to follow established telehealth billing guidelines and telehealth documentation requirements to minimize telehealth billing errors:

• Use Modifier 93 for audio only telehealth coding and Modifier 95 for synchronous audio-video services
• Utilize G2211 for visit complexity in longitudinal care, including when performed on the same day as certain preventive services
• Prioritize Medical Decision Making (MDM):
  MDM remains the primary driver for code selection under E/M coding changes 2025, with total time serving as an alternative when supported by documentation