Commercial payors are increasingly adopting the new CPT telehealth code set (98000–98015), signaling a potential shift away from using standard office/outpatient E/M codes (99202–99215) for virtual care. This shift can have payment implications, as plans use these codes to vary payment. While approaches differ by plan, several Blue plans and national carriers have begun requiring the new codes, particularly for audio/video visits, with some also adopting the audio only code series. In some markets, this transition is phased, while others are moving more aggressively toward full replacement of E/M coding for telehealth services. In 2024, the AOA urged CMS to adopt the new telehealth codeset expressing concern for a bifurcated approach to telehealth billing across payors and varied payment. While the agency chose to continue paying for telehealth services at the same rate as in-person, they did not choose to utilize the new codeset.
Blue Cross Blue Shield of Michigan has implemented one of the more comprehensive approaches, requiring telehealth visits be billed with the new codes and no longer recognizing standard E/M codes for virtual services as of July 2025. Additionally, BCBSM is applying differentiated reimbursement, raising concerns about payment rates that do not recognize the costs of delivering virtual care among physician practices. AOA is actively monitoring these developments and their impact on physician payment, and engaging with plans as appropriate. Physicians and affiliate executives in states where similar policies are emerging are encouraged to report payer practices, particularly where telehealth reimbursement varies, by contacting payoradvocacy@osteopathic.org to support ongoing advocacy efforts.
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