New Telehealth CPT Codes: 2026 Billing Guide

Telehealth billing changes rarely stay confined to the coding desk. A revised code family can affect scheduling, eligibility checks, documentation, claim edits, and denial follow-up across the organization.

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For 2026, the practical starting point is understanding what changed in the CPT set and where payer rules diverge. That foundation makes it easier to update billing logic without separating revenue-cycle work from the clinical and operational workflows that produce the record.

How the New Telehealth CPT Codes Fit Into 2026 Billing

The 2026 CPT update gives telehealth teams clearer labels for certain virtual services. It does not create a universal payment rule. The 98000-98016 family also reflects revised telehealth service definitions for digital health technologies. Providers must still check payer recognition, documentation requirements, and claim instructions.

What changed with the 98000-98016 family?

The family organizes several telehealth services by the way the encounter is delivered and by the nature of the service. It includes categories for synchronous audio-video visits, audio-only services, and brief communication technology-based services. The series also distinguishes between new and established patient contexts, which means the code selection still depends on the relationship and service documented for the encounter.

CPT 98016 is a notable example. It replaced HCPCS G2012 for brief synchronous communication technology-based services lasting 5 to 10 minutes. That change affects code maps, charge capture rules, and staff reference materials for organizations that previously used the HCPCS code. It does not, by itself, establish that every payer will process the replacement code in the same way.

When did the new codes become effective?

New Category I CPT codes in the 2026 set became effective for clinical use on January 1, 2026, according to the American Medical Association’s CPT 2026 announcement. An effective date is the starting point for using a code within the CPT system. It is not a guarantee that a health plan has completed its own claim-system configuration, coverage review, or reimbursement policy.

CMS separately updates its list of covered Medicare telehealth services on an annual basis, with additions or deletions taking effect January 1. This creates an important distinction between a code’s publication in CPT and its treatment under a particular federal or commercial benefit policy. Medicare has not adopted the 98000-98015 series, describing those codes as duplicative of established evaluation and management codes. Medicare guidance instead directs providers toward standard office visit E/M codes, such as 99202-99215, with applicable telehealth place-of-service indicators and modifiers. See the HHS telehealth billing guidance for the current reference point.

Why the code label is only one billing input

A clean claim depends on more than the descriptor attached to a CPT number. Payer adoption, patient eligibility, service setting, modality, documentation, modifiers, and organizational policy can all affect how an encounter should be submitted and reviewed. Commercial, self-funded, and Medicare Advantage plans do not universally handle the 98000-98016 family the same way, so teams should verify requirements with each payer before changing production workflows.

Use the 2026 code family as a structured starting point for review, not as a promise of reimbursement. Coding teams should map each service to the payer’s current policy, test the result in the claim workflow, and monitor denials after implementation.

What Do the 98000-98016 Telehealth Codes Cover?

The 98000-98016 family is designed to organize several telehealth encounter types within the CPT framework. The practical distinction is not simply whether a visit happened remotely. Teams must identify how the service was delivered, whether it involved real-time audio and video, whether it was audio-only, and whether the interaction was brief communication technology-based care. The 2026 CPT update includes revisions to telehealth service definitions intended to better accommodate digital health technologies. Providers should use the AMA and CMS references cited in this guide, along with current payer instructions, rather than relying on a commercial summary.

Audio-video encounters

The audio-video portion of the family addresses synchronous encounters in which the clinician and patient communicate in real time using both sound and video. Within the broader 98000-98015 range, code selection depends on the applicable encounter characteristics, including whether the patient is new or established and the service level documented. Those distinctions should be mapped to the organization’s coding policy and the payer’s instructions, rather than inferred from the presence of a video connection alone.

Audio-only encounters

Audio-only care is treated separately from synchronous audio-video care. That separation matters operationally because payer rules may require different modifiers, documentation, or coverage conditions. The HHS telehealth billing guidance identifies modifier 93 for audio-only services and modifier 95 for synchronous audio-video services, while also noting that requirements can vary. A code-family reference is therefore a starting point for review, not a guarantee that a claim will be accepted.

Brief communication services

CPT 98016 covers brief synchronous communication technology-based services lasting 5 to 10 minutes. HHS identifies 98016 as the replacement for HCPCS G2012 for this type of brief communication. It should not be used as a catch-all for every short message, portal exchange, or incomplete visit. Staff should confirm that the documented interaction meets the relevant service definition and the payer’s policy before assigning it.

The following table offers a high-level orientation.

The table is an orientation tool, not a payment policy. Adoption of the 98000-98016 series is not universal across commercial, self-funded, and Medicare Advantage plans. Verify each payer’s current policy, including covered code ranges, patient-status rules, modifiers, documentation requirements, and effective dates.

CMS separately updates its list of covered Medicare telehealth services each year. Additions or deletions take effect January 1. Check HHS billing guidance and CMS coverage guidance alongside the payer contract and claims instructions.

Are the New Telehealth CPT Codes Accepted by Medicare?

Providers should not assume that Medicare accepts the 98000-98015 family simply because these new telehealth CPT codes appear in the current code set. CMS has determined that the 98000-98015 series is duplicative of established evaluation and management codes and has not adopted it for Medicare billing. For Medicare telehealth encounters, the federal guidance directs providers toward standard office visit E/M codes, with the applicable place of service and modifiers. Review the current HHS telehealth billing guidance and CMS coverage updates before submitting claims.

Use standard E/M codes when Medicare guidance calls for them

The HHS guidance identifies office and other outpatient E/M codes 99202 through 99215 as the standard family to use for Medicare telehealth billing. The correct code still depends on the encounter, including factors such as whether the patient is new or established and the level of service supported by the documentation. A telehealth designation does not, by itself, determine the E/M code or guarantee payment.

Do not use the presence of a 98000-series code in a commercial payer fee schedule as evidence that Medicare will process it. Maintain a payer-specific code map, and route exceptions for review by the organization’s coding or revenue-cycle team. CMS updates its covered Medicare telehealth services list annually, with additions or deletions taking effect on January 1. That schedule makes an annual policy review necessary, but it does not replace checking current instructions for a specific service.

Choose POS 02 or POS 10 based on the patient’s location

Place of service identifies where the patient was located during the encounter. POS 10 indicates that the patient was in their home. POS 02 indicates that the patient was in a telehealth location other than home, such as a clinic. The distinction should be captured during intake and carried consistently into the claim workflow. A scheduling label or provider location alone may not establish the correct POS code.

Apply modifiers only after confirming payer requirements

Modifier 93 is used for audio-only telehealth services, while modifier 95 is used for synchronous audio-video services. HHS notes that Medicare requirements can vary, so these modifiers should not be applied mechanically across every payer or encounter type. Confirm the current Medicare instructions, the service’s coverage status, and any required documentation before final claim submission.

For brief synchronous communication technology-based services lasting five to 10 minutes, CPT 98016 replaced HCPCS G2012 according to the HHS guidance. Because telehealth policy changes, organizations should date their internal references, monitor CMS updates, and investigate denials rather than treating any code, POS, or modifier combination as universally accepted.

How Should Providers Handle Commercial Payer Rules?

Do not treat publication of the 98000-98016 family as evidence that every commercial plan will accept every code. Adoption varies among commercial, self-funded, and Medicare Advantage plans, so the operational question is not only which code describes the encounter. It is also whether the member’s plan recognizes that code, under what conditions, and with which submission requirements. The U.S. Department of Health and Human Services recommends verifying payer policies rather than assuming uniform treatment.

Build that verification into the workflow before claims are submitted:

1. Confirm eligibility. Verify active coverage on the date of service, the patient’s plan type, network status, and whether the planned telehealth service is subject to authorization or other utilization controls. Eligibility confirmation does not guarantee payment, but it can identify coverage problems before the encounter.
2. Confirm the policy. Check the payer’s current provider guidance or obtain written confirmation from the payer representative. Ask whether the applicable 98000-98016 code is accepted, whether the plan distinguishes audio-only from audio-video care, and which place-of-service, modifier, taxonomy, or authorization requirements apply. Repeat this check for self-funded plans and Medicare Advantage products instead of assuming the commercial policy carries over.
3. Document the encounter. Capture the service delivered, modality used, patient location, medical necessity, time or other code-specific elements, and any required consent or technology details in the clinical record. Documentation should support the code selected without implying that a payer must reimburse it.
4. Apply claim edits. Before transmission, compare the encounter data with the payer-specific rule set. Check code and diagnosis compatibility, required modifiers, place of service, authorization status, and duplicate or mutually exclusive combinations. Keep the edit logic traceable so staff can determine why a claim was changed or held.
5. Feed denials back into the process. Track denials by payer, product, code, reason, and missing data. Separate eligibility failures from policy nonadoption, documentation gaps, and claim-format errors. Escalate recurring patterns for payer clarification, then update the payer matrix, templates, and staff guidance through a controlled review process.

Foundational controls still matter when the code set changes. Teleray’s guide to proper reimbursement coding provides broader context for coding discipline in telehealth image-sharing environments. Use it alongside current payer instructions, not as a substitute for plan-specific verification.

What Should the Operational Workflow Capture?

Implementing new telehealth CPT codes is not only a billing-team exercise. The workflow should preserve the information that allows clinical, operational, and revenue-cycle teams to review an encounter consistently. A unified virtual care platform can reduce handoffs between disconnected video, imaging, documentation, and billing systems. It should support organizational policy rather than choose codes or guarantee reimbursement.

Confirm eligibility before the encounter

Before service begins, capture the patient and payer information needed for a reliable eligibility check. This includes the active plan, coverage status, authorization requirements, patient location, service modality, and any payer-specific telehealth conditions. Patient location matters because payer rules may distinguish a patient at home from one receiving care at another site. The workflow should make these fields visible to the appropriate team and preserve the verification result with a timestamp, rather than relying on memory or an isolated note. Organizations can also review TeleRay’s healthcare technology platform and solution areas when evaluating how operational systems fit together.

Connectivity also belongs in the pre-service process. Teams should know which platform will host the encounter, whether the required participants can join, and where the resulting documentation will be stored. TeleRay describes its platform as HIPAA compliant and SOC 2 Type II certified, providing a security and governance context for virtual care operations. Those controls support responsible handling of protected health information, but they do not replace payer verification or the organization’s compliance review.

Document the encounter without duplicating work

Documentation should connect the encounter to the patient record and clearly distinguish what occurred. Depending on the service, that may include the date and duration, participants, modality used, patient location, clinical purpose, relevant consent or attestation, and the resulting assessment and plan. Clinical judgment remains with the treating professional. The technology should make accurate documentation easier to complete and retrieve, not generate a clinical conclusion or determine the appropriate code.

Integration can reduce re-keying and conflicting records when virtual care activity must move between the care platform and the electronic medical record. See TeleRay’s EMR/EHR integration guide for its approach to connected workflows. For encounters involving remote imaging collaboration, TeleRay also identifies FDA 510(k) cleared diagnostic viewing as a platform capability. That clearance describes the viewing technology; it is not a coding or reimbursement determination.

Review claims and denials as a control loop

Before submission, route the documented encounter through a claim review that checks payer, code family, place of service, modifiers, required records, and internal billing policy. A reviewer should be able to see the source documentation and identify whether a mismatch came from eligibility, missing information, or a payer rule. After submission, track denials by payer and reason, then feed recurring findings back into templates, staff training, and verification steps. This approach is more dependable than assuming that a new code label will produce payment.

A virtual care platform can provide a more coherent operational layer for these handoffs. Organizations evaluating interoperability can also review TeleRay’s EMR integration capabilities and secure image exchange and storage approach. For broader governance context, review your organization’s compliance policies with qualified personnel. Security features, imaging support, and connected documentation are valuable when they reduce fragmentation. Code selection and reimbursement decisions remain the responsibility of qualified staff and applicable payer guidance.

A Practical Checklist for Updating Telehealth Billing Workflows

Use a controlled implementation process rather than replacing code selections in isolation. The new telehealth CPT codes may affect code maps, claim edits, documentation, and staff decisions, but payer policy remains the final operational checkpoint. Review the workflow with qualified coding and compliance personnel, and confirm current requirements directly with each applicable payer.

1. Review payer policies first. Confirm whether each commercial, self-funded, Medicare Advantage, or Medicare workflow recognizes the relevant services and code combinations. Adoption of the 98000-98016 series is not universal, so document the payer source, effective date, and any prior authorization or eligibility requirements.
2. Update the code map. Map covered service scenarios to the organization’s approved code set, including distinctions between audio-video, audio-only, and brief communication services. For Medicare workflows, do not assume the new series applies. CMS guidance indicates that standard office visit E/M codes may be required instead.
3. Build POS and modifier logic. Add validation for the patient’s location. POS 10 indicates the patient is at home, while POS 02 indicates a location other than home. Where appropriate, check modifier 93 for audio-only services and modifier 95 for synchronous audio-video services, while preserving payer-specific edits.
4. Standardize documentation templates. Capture the service modality, patient location, encounter details, time or other required elements, participants, and any consent or eligibility information required by policy. Templates should support accurate coding without directing clinical judgment.
5. Train staff by role. Give clinicians, schedulers, billers, and claim reviewers workflow-specific guidance. Use examples that show when a missing location, modality, or payer detail should trigger clarification before submission.
6. Monitor denials and corrections. Track denials by payer, code, POS, modifier, and documentation gap. Feed recurring patterns back into the code map and templates. A denial trend is a signal to investigate, not evidence that a service is never payable.
7. Schedule recurring review. Recheck CMS updates annually and revisit commercial payer policies when contracts, code sets, or claim edits change. Keep an owner and review date for each workflow so updates do not depend on informal memory.

Before reviewing the questions below, confirm the current payer policy and documentation requirements for the service under review.

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Frequently Asked Questions

Are the new 98000 series CPT codes accepted by Medicare?

Do not assume they are. CMS has not adopted the 98000-98016 series for Medicare, describing the relevant codes as duplicative of established evaluation and management services. Confirm current Medicare guidance before submitting a claim. CMS and HHS telehealth billing guidance should be part of that review.

What are the new telehealth CPT codes for 2026?

The 2026 CPT code set includes the 98000-98016 family for synchronous audio-video and audio-only evaluation and management services, along with brief communication services. The new Category I codes became effective January 1, 2026, but a code’s existence does not establish coverage or payment by every payer. The AMA’s CPT 2026 announcement provides the effective-date context.

What should I use instead of the new CPT codes for Medicare billing?

For Medicare telehealth billing, standard office visit evaluation and management codes, generally 99202-99215 when applicable, may be used with the appropriate place-of-service indicator and required modifier. Validate the selection against the service, patient location, documentation, and current Medicare rules.

What is the difference between POS 02 and POS 10?

POS 10 indicates that the patient was located in their home during the telehealth service. POS 02 indicates that the patient was at a telehealth location other than home, such as a clinic. Capture the patient’s actual service location and apply the payer’s current reporting requirements.

Are modifier 93 and 95 required for all telehealth services?

No. Modifier 93 is associated with audio-only telehealth, while modifier 95 is associated with synchronous audio-video telehealth. Requirements can differ by payer, service, and program, so treat them as workflow checks rather than universal rules. Verify payer instructions and retain documentation supporting the modality reported. HHS billing guidance notes that Medicare requirements may vary.

Schedule a Demo for a More Connected Workflow

Updating telehealth billing workflows is easier when coding, documentation, and virtual care operations are considered together. Teleray can help your team explore a unified workflow for secure virtual care while keeping payer rules, organizational policies, and clinical judgment in view. Schedule a demo to discuss your operational needs and evaluate whether the platform fits your current process.