Navigating the 2025 Changes in Telehealth and Their Impact on Mental Health Services Coding

The COVID-19 pandemic significantly impacted global mental health, leading to increased awareness and demand for mental health services. With the ongoing evolution of healthcare delivery, the Centers for Medicare and Medicaid Services (CMS) has issued pivotal updates in the 2025 Final Rule for Telehealth, reshaping how mental health services are delivered and coded.

The 2025 Telehealth Landscape: Major Policy Updates and Their Implications

As the healthcare industry adapts to post-pandemic realities, CMS's updates to telehealth policies for 2025 carry profound implications for mental health services, affecting coding practices and reimbursement processes:

CMS Policy Updates:

• CPT Codes: The majority of the new telehealth CPT codes (98000-98015) introduced for 2025 are not recognized by CMS, except for CPT code 98016, which replaces HCPCS Level II code G2012 for brief virtual check-ins to eliminate redundancy. CMS recommends the use of Office and Other Outpatient Visit Evaluation and Management codes with modifiers –93 or –95 appended to report telehealth services.

Direct Supervision and Telecommunications:

• The requirement for direct supervision via real-time audio and visual telecommunications will continue, crucial for mental health services where continuous interaction is vital.

Permanent Telehealth Services for Behavioral and Mental Health:

• Certain behavioral and mental health services will be offered permanently under telehealth for Medicare patients from January 1, 2025. These services include:
  • Psychiatric evaluations
  • Psychotherapy sessions
  • Crisis intervention
  • Substance use disorder treatments
• This permanency necessitates coders to stay updated with CMS’s List of Telehealth Services to ensure accurate coding.

Place of Service Codes:

• The continued use of specific Place of Service (POS) codes affects billing rates correct application is vital for coders:
  • 02: Telehealth services rendered when the patient is located outside their home.
  • 10: Telehealth services rendered when the patient is in their home.
  • 11: Office visit.
  • 19: Off-campus outpatient hospital.
  • 22: On-campus outpatient hospital.
  • 23: Emergency room hospital.
• These codes are crucial for distinguishing where services are provided, as they directly impact reimbursement rates.

Geographic and Location Restrictions:

• Pre-pandemic geographic and location restrictions are reinstated, meaning telehealth services must be provided in designated areas like health professional shortage areas to be covered by Medicare.

Legislative Uncertainty:

• The ongoing uncertainty with the Telehealth Modernization Act 2024 poses potential changes that could affect telehealth service coverage, impacting how services are coded and billed.

Telehealth Coding Nuances for Mental Health Post-Pandemic

The expansion in mental health services necessitates a nuanced understanding of coding, particularly with the increased use of telehealth:

Telehealth and Virtual Services:

• With the changes introduced in 2025, coders must adapt to new CPT and HCPCS codes specifically designed for telehealth services.
  • For example, CPT code 98016 has been introduced for brief virtual check-ins as a replacement for the previously used HCPCS Level II code G2012, reflecting the need for streamlined virtual patient interactions.
  • Additionally, modifiers such as GT (via interactive audio and video telecommunications systems) continue to be crucial for indicating that a service was delivered via telehealth.
• Complexity of Services: Mental health services encompass a broad range of treatments, each requiring precise coding to capture the scope of care provided. For instance:
  • Psychiatric Evaluation: Coded with CPT 90791 (without medical services) or 90792 (with medical services), these codes are used for diagnostic assessments that include a medical evaluation.
  • Psychotherapy: Ranges from CPT 90832 for a 30-minute session to 90837 for a 60-minute session, allowing for detailed billing based on the time spent with the patient.
  • Group Psychotherapy: Coded with CPT 90853, reflecting a session where multiple patients participate in therapeutic activities.
• Co-Occurring Conditions: When patients present with both mental and physical health conditions, coders must use a combination of codes to accurately reflect the complexity of each case.
  • For example, a patient with depression and diabetes might be coded with F32.9 (Major depressive disorder, unspecified) from the ICD-10-CM for the mental health condition and E11.9 (Type 2 diabetes mellitus without complications) for the physical condition. This ensures that all aspects of the patient’s health are considered in the billing and documentation process.
• Updates in Coding Standards: Staying updated with revisions to coding standards is critical, especially as new treatments and modalities are developed. Coders must be aware of the annual updates to the ICD-10-CM and CPT codes. Regular training and consultation of official coding guidelines are essential to maintain accuracy and compliance.

Key Takeaways

Specific Changes in Telehealth Coding:

• CPT® Code Adjustments: The introduction of CPT® code 98016 for brief virtual check-ins, replacing HCPCS Level II code G2012, to streamline virtual patient interactions.
• Direct Supervision Requirements: Continuous need for direct supervision via real-time audio and visual telecommunications, especially crucial for mental health services.
• Permanent Telehealth Services: Specific behavioral and mental health services, such as psychiatric evaluations, psychotherapy sessions, crisis intervention, and substance use disorder treatments, are now permanently included under telehealth for Medicare from January 1, 2025.

The information contained in this blog post is valid at the time of posting. Viewers are encouraged to research subsequent official guidance in the areas associated with the topic as they can change rapidly.