Telehealth Coding in 2026: Audio-Only Codes and the 98000-Series

Telehealth billing in 2026 is more settled than the emergency-rules era — but it’s settled into something genuinely awkward: a dual-track system where Medicare and commercial payers want the same virtual visit reported two different ways. Here’s how to keep it straight.

The 98000-series, briefly

The AMA introduced a dedicated telehealth E/M family, CPT 98000–98016, structured to mirror office-visit logic:

98000–98007: synchronous audio-video E/M visits, new and established patients
98008–98015: audio-only E/M visits, new and established patients
98016: brief virtual check-in (5–10 minutes, established patients), which replaced G2012

Code selection follows familiar E/M rules — medical decision-making or total time on the date of the encounter. The old telephone codes 99441–99443 are gone; claims submitted with them deny automatically. Note that e-visits (99421–99423) were not replaced — those asynchronous portal codes remain active.

The Medicare split

Here’s the complication that generates most 2026 telehealth denials: CMS declined to adopt most of the new family, assigning 98000–98015 a status indicator of “I” (not valid for Medicare purposes). Bill those codes to Medicare fee-for-service and you’ll be denied.

For Medicare telehealth, continue using the standard office E/M codes 99202–99215 with the correct place-of-service code (POS 02 for telehealth outside the home, POS 10 for the patient’s home) and modifier 93 for audio-only encounters. Medicare identifies telehealth through POS and modifier — not through a telehealth-specific CPT code. The exceptions: 98016 is accepted by Medicare for brief virtual check-ins, and 99421–99423 remain payable for e-visits.

The commercial and Medicaid track

Many commercial payers and some state Medicaid programs have adopted the 98000-series — sometimes in full, sometimes selectively, and sometimes at different reimbursement rates than the parallel office codes. When billing 98000–98015 to payers that accept them, you generally do not append modifier 95 or 93; the telehealth modality is built into the descriptor.

The operational consequence: your billing system needs payer-level logic. The same audio-only established-patient visit might go out as 98013 to one payer and 99213-93 with POS 10 to another.

Building a clean workflow

Map every contracted payer’s position on the 98000-series — accepted codes, rates, and modifier expectations — and keep the grid updated. Policies are still shifting.
Configure claim scrubber edits that flag 98000–98015 on Medicare claims and flag deleted codes 99441–99443 everywhere.
Train providers on time documentation. Both tracks lean on total time or MDM; audio-only visits especially need the record to state the modality and why audio-only was appropriate.
Watch POS accuracy. POS 02 versus POS 10 affects payment under Medicare; telehealth from the patient’s home is POS 10.
Monitor policy news. Medicare telehealth flexibilities have lived on a series of legislative extensions, and coverage terms can change with little runway. Assign someone to check CMS and MAC updates quarterly.

The bottom line

Telehealth coding in 2026 isn’t hard because any single rule is complex — it’s hard because two rulebooks apply simultaneously. Practices that internalize the split (Medicare: legacy E/M plus POS and modifiers; adopting commercial payers: the 98000-series as written) and encode it into their systems see clean claims. Practices that pick one approach for everyone donate revenue to their denial queue.

Payer policies vary and change frequently. Verify current coverage with each payer and consult the official CPT code set and CMS guidance before billing.

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Originally Published On: Medical Coding News

Photo courtesy of: Getty Images

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