The telephone E/M codes practices used for years are gone. Here's the 2026 landscape: which codes replaced them, the 10-minute rule, what Medicare actually pays, and the documentation an after-hours call needs to be billable.
What changed
Effective with CPT 2025, the AMA removed the time-tiered telephone codes (99441: 5-10 minutes, 99442: 11-20, 99443: 21-30) and folded audio-only visits into a new telemedicine section. Claims on the old codes now deny automatically. The replacements:
| Code(s) | What it covers | Key requirement |
|---|---|---|
| 98008-98011 | Audio-only E/M, new patient (four levels) | Level by MDM or total time, plus more than 10 minutes of medical discussion |
| 98012-98015 | Audio-only E/M, established patient (four levels) | Same: MDM or time, with the 10-minute discussion floor |
| 98016 | Brief virtual check-in, established patient, 5-10 minutes | Replaced G2012; the one new code Medicare pays |
Medicare note: CMS declined to adopt most of the 98000 series for payment. For Medicare patients, audio-only visits generally route through standard E/M codes under current telehealth rules, while 98016 covers the brief check-in. Commercial payer adoption of 98008-98015 is broad but not universal. The practical rule: confirm each payer's policy before standardizing a workflow.
Documentation
Time-based selection needs documented start/end or total minutes of medical discussion. "About 10 minutes" invites a downcode; 11:38 does not.
The provider who conducted the call, the date of service in your practice's timezone, and the patient's identity and consent to a telephone visit.
The reason for the call, the assessment, and the plan. For urgent after-hours calls this is often brief; it still has to exist.
Payers commonly bundle calls tied to a recent or imminent in-person visit. Note the relationship (or its absence) so your biller can apply the payer's rule.
When Hello AI escalates an urgent after-hours call to your on-call provider, it records the provider-to-patient talk time from the moment they accept to the end of the call, alongside a timestamped log of every provider contacted. The billing CSV hands your biller the date of service in your timezone, the callback number, the provider reached, and talk time in both m:ss and decimal minutes. Your biller picks the code; the documentation is already there.
FAQ
No. The AMA deleted 99441-99443 from CPT effective 2025, and claims submitted with them are denied. Telephone (audio-only) E/M visits are now reported with the 98000-series telemedicine codes: 98008-98011 for new patients and 98012-98015 for established patients, or 98016 for a brief virtual check-in.
The new audio-only codes (98008-98015) are leveled like office E/M: you select the level by medical decision making or total time, with one extra floor: the encounter must include more than 10 minutes of real-time medical discussion. For a short call that doesn't meet that threshold, 98016 (brief communication technology-based service, 5-10 minutes) is the closest fit for established patients.
Only partially. CMS did not adopt the full 98000-series for Medicare payment; 98016 is the one new code Medicare covers, and Medicare otherwise directs audio-only visits to standard E/M codes with the appropriate telehealth rules. Commercial payers vary widely, and many do accept 98008-98015. Always confirm with each payer before you build billing workflows around a code.
At minimum: patient identity and consent to a telephone visit, the date and start/end times (or total minutes of medical discussion), who conducted the call, the reason for the call, the assessment and plan, and any bundling checks your payer requires, such as whether the call relates to a recent or upcoming in-person visit. Time-based selection lives or dies on documented minutes.
When Hello AI escalates an urgent after-hours call, it records who was reached and the provider-to-patient talk time, measured from the moment your provider accepts to the end of the call, with every attempt timestamped. The billing CSV export gives your biller the date in your practice's timezone, the callback number, the provider reached, and talk time in both m:ss and decimal minutes. Hello AI documents the encounter; your biller selects the code.
Further reading: SMFM on the 2025 telehealth CPT codes · MedCentral on the CPT 2025 telemedicine overhaul