Telehealth in Fertility Practices: Billing the 98xxx CPT Code Series Correctly

Telehealth has become a standard part of fertility care — initial consultations, cycle review visits, and post-treatment follow-ups are routinely conducted via video. But the way you bill those visits changed significantly in 2025. The CPT code book introduced an entirely new set of telehealth E/M codes (98000–98016) that replace the pandemic-era practice of appending modifier 95 or 93 to standard office visit codes. Understanding the new structure is essential to avoiding denials and billing compliantly.

What Changed in 2025

Before COVID-19, telehealth was rarely billed due to geographic and equipment restrictions. During the pandemic, all prior rules were waived — providers reported standard E/M codes (99202–99215) with modifier 95 for audio-video, modifier 93 for audio-only, and modifier GT for Medicare. The 2025 CPT code book ended that workaround by creating a dedicated telehealth E/M code series: 98000–98015 for real-time patient encounters, and 98016 for brief technology-based check-ins.

The New Code Structure: 98000–98015

The new codes are organized across two patient types (new and established) and two delivery modes (audio/video and audio-only). Coding can be based on Medical Decision Making (MDM) or Total Time — the same approach used for in-person E/M codes.

New Patient E/M — Audio/Video and Audio-Only

Established Patient E/M — Audio/Video and Audio-Only

98016 — Brief Communication Technology-Based Service

CPT 98016 covers audio-only or audio/video telehealth services lasting 5–10 minutes. It is for established patients only, and replaces the prior Medicare check-in code G2012. It cannot be billed if the encounter is related to an E/M service provided in the previous 7 days, or if it leads to an E/M visit within the next 24 hours. This code is appropriate for brief nursing protocol check-ins or quick medication confirmations in a fertility practice.

Prolonged Service Add-On

Add-on code +99417 may be used with the new telehealth codes when the service exceeds the maximum time threshold for the selected level. The rules for +99417 mirror its use with in-person E/M codes — bill one unit for each additional 15 minutes beyond the base code time.

Medicare vs. Commercial Payers: Critical Difference

This is the single most important distinction for fertility billing teams in 2025. Medicare will NOT accept the new 98000–98015 codes. Medicare continues to require the pandemic-era approach: bill standard office E/M codes (99202–99215) with modifier 95 for audio-video and modifier 93 for audio-only. Commercial payers and Medicaid vary — some have adopted the new codes, many have not. You must verify each payer individually before switching to the new code series.

Place of Service Codes

Place of service requirements also depend on the payer. POS 10 indicates the patient was at home — the most common scenario in fertility telehealth. POS 02 indicates telehealth to a non-home location. POS 11 (office) should not be used for telehealth visits, as this is a common error that triggers denials. Confirm the POS your payer requires: some require 11, 02, or 10 depending on their own guidelines.

Documentation Requirements

• Document patient consent for telehealth — most payers require this to be on file.
• Specify the delivery mode in the note: audio/video or audio-only — this determines which code series applies.
• For audio-only services, document the duration of the medical discussion (minimum 10 minutes required).
• Note the patient's location at the time of service to support the correct place of service code.
• Apply the same E/M documentation standards as in-person visits: MDM or total time, whichever basis is used for code selection.
• Do not bill a new 98xxx telehealth E/M on the same date as another E/M — if both occur, apply the telehealth time to the MDM or total time for that day instead.