CPT® Code 99441

Last Updated: February 2026 | Verified for 2025–2026 AMA, CPT & CMS Guidelines

⚠ CRITICAL NOTICE: CPT 99441 Was Deleted Effective January 1, 2025

The AMA CPT Editorial Panel deleted CPT codes 99441, 99442, and 99443 from the CPT code set effective January 1, 2025. Claims submitted with these codes for dates of service on or after January 1, 2025 will be denied by most payers. This article covers the historical context of CPT 99441, its critical role during the COVID-19 Public Health Emergency, the reason for its deletion, and — most importantly — the correct codes to use now for audio-only telephone E&M services.

Quick Reference: CPT 99441 (Historical)

• Definition (Pre-2025): Telephone evaluation and management service provided by a physician to an established patient, parent, or guardian; 5–10 minutes of medical discussion.

• Status: DELETED — Effective January 1, 2025 (CPT 2025 Edition)

• Replaced By (Commercial/Most Payers): CPT 98012 (established patient, straightforward MDM, 10+ min) or 98013–98015 depending on MDM complexity or time.

• Medicare Billing Now: Use standard office E/M codes (99202–99215) with Modifier 93 (audio-only) and POS 10 (patient at home) or POS 02 (patient not at home). Medicare does NOT recognize CPT 98000–98015.

• Patient Eligibility (Historical): Established patients only. Must not originate from a related E/M within the previous 7 days, and must not lead to an E/M or procedure within the next 24 hours or soonest available appointment.

• Who Could Bill (Historical): Physicians and other qualified health care professionals (QHPs) who may report E/M codes. Non-physician QHPs used the parallel codes 98966–98968 (those codes remain active).

• Companion Codes (Historical): 99442 (11–20 min) and 99443 (21–30 min) — all three deleted simultaneously.

CPT 99441 was the lowest-level telephone evaluation and management (E/M) code in a family of three codes (99441–99443), covering 5 to 10 minutes of real-time medical discussion between a physician and an established patient via telephone.

First introduced in the CPT code set decades before the pandemic, these codes saw negligible usage until the COVID-19 Public Health Emergency (PHE), when the Centers for Medicare & Medicaid Services (CMS) temporarily added them to the Medicare telehealth list with reimbursement parity to office visit codes. Their deletion in 2025 marks the end of that era and ushers in a completely restructured telehealth coding framework.

1. Historical Definition & Code Family

Prior to its deletion, CPT 99441 was officially described as:

“Telephone evaluation and management service provided by a physician to an established patient, parent, or guardian not originating from a related E/M service provided within the previous 7 days nor leading to an E/M service or procedure within the next 24 hours or soonest available appointment; 5–10 minutes of medical discussion.”

Three critical qualifying conditions governed the use of 99441:

Condition 1 — Established Patients Only. Unlike office visit codes that expanded to new patients, 99441 was restricted to established patients, or the parent or guardian of a minor established patient. A patient was “established” if they had received a professional service within the prior 3 years from the same physician or QHP, or from another in the same group specialty.

Condition 2 — The 7-Day Look-Back Rule. The call could not originate from a related E/M service provided within the previous 7 days. If the patient was calling about the same problem that was addressed in a recent in-person or telehealth visit, the telephone service was considered bundled into the prior E/M — it was not separately billable.

Condition 3 — The 24-Hour (or Next Available) Look-Forward Rule. If the telephone call resulted in the physician deciding to schedule the patient for a face-to-face visit within 24 hours or the patient’s soonest available appointment, the telephone service was bundled into that subsequent visit and could not be billed separately.

The Full 99441–99443 Code Family

Key Distinction: The 99441–99443 series (now deleted) was reserved for physicians and QHPs who already have the authority to report E/M codes — physicians, nurse practitioners, physician assistants, and clinical nurse specialists. The parallel series 98966–98968 served non-physician clinicians such as licensed clinical social workers, clinical psychologists, physical therapists, and others who provide telephone assessment and management. The 98966–98968 codes remain active and unchanged for 2025–2026.

2. COVID-Era Reimbursement: The Full Story

Understanding the deletion of CPT 99441 requires understanding its rise during the COVID-19 pandemic.

Pre-COVID Status: Bundled and Essentially Worthless

Before March 2020, CPT codes 99441–99443 existed in the CPT manual but were assigned a “bundled” payment status by Medicare — meaning they were not separately reimbursable. Telephone calls were considered part of the overall care relationship and were expected to be subsumed in the global service period of office visits. Many commercial payers followed Medicare’s lead and similarly denied or bundled these codes. For most practices, submitting a claim for 99441 pre-pandemic resulted in zero payment.

March 2020: CMS Opens the Floodgates

When the COVID-19 Public Health Emergency was declared, CMS exercised extraordinary flexibility under Section 1135 of the Social Security Act and added codes 99441–99443 to the Medicare Telehealth Services List, making them separately reimbursable for the duration of the PHE. The rationale was simple: patients needed access to physician services without risking in-person exposure, and many patients — particularly the elderly — did not have access to or the technical capability to use video.

April 2020: Reimbursement Parity

CMS went one step further in April 2020 by increasing reimbursement for 99441–99443 to approximate mid-level established patient office visit payments. Telephone calls that previously generated $0 were now reimbursed at rates comparable to 99212–99214:

Post-PHE Extensions and the Path to Deletion

The PHE officially ended in May 2023. However, Congress and CMS extended telehealth flexibilities — including coverage of 99441–99443 — through the Consolidated Appropriations Act provisions, ultimately through December 31, 2024. This gave payers and providers a transition window. During this period, the AMA CPT Editorial Panel was simultaneously developing a more robust telehealth coding infrastructure that would properly distinguish audio-only from audio-video services, apply MDM-based or time-based selection consistent with the 2023 E/M framework, and differentiate between new and established patients. That work culminated in the 2025 deletion of 99441–99443 and introduction of codes 98000–98016.

3. Why CPT 99441 Was Deleted in 2025

The AMA CPT Editorial Panel’s decision to delete 99441, 99442, and 99443 was driven by several substantive policy and structural reasons:

Reason 1 — The Codes Were Time-Only, Not MDM-Compatible. The entire post-2023 E/M framework moved to a “MDM or Time” selection method. Codes 99441–99443 were purely time-based — they had no MDM pathway, no distinction between low and high complexity, and no separation between new and established patients. This made them structurally incompatible with the modern E/M framework and prevented accurate complexity capture.

Reason 2 — No New Patient Recognition. The old codes were limited to established patients. As telehealth has become a mainstream care delivery channel, it became clinically inappropriate to deny new patients access to billable audio-only services. The new 98000-series resolves this by creating separate new-patient codes (98008–98011).

Reason 3 — Data Collection Deficits. Because 99441–99443 shared the same modifier requirements as audio-video telehealth codes during much of the PHE (Modifier 95 was often required by MACs), the GAO and CMS identified significant data deficiencies distinguishing telephone visits from video visits. This impaired the ability to study the clinical outcomes of audio-only care.

Reason 4 — Parity with New Telehealth Infrastructure. The new 98000–98016 series created a parallel, symmetrical framework for telehealth that mirrors the in-person office visit code structure, ensuring that selection criteria are consistent, auditable, and parity-appropriate across visit types.

4. What Replaced CPT 99441: The New 2025 Coding Framework

Effective January 1, 2025, the AMA introduced 17 new telehealth E/M codes in the 98000–98016 range. These codes cover both audio-video (98000–98007) and audio-only (98008–98015) synchronous E/M visits, for both new and established patients, selected by MDM complexity or total time — exactly mirroring the in-person E/M framework.

Critical Caveat — Medicare Does NOT Recognize 98000–98015: CMS has determined that CPT codes 98000–98015 are, in effect, duplicative of existing codes with appropriate modifiers. Medicare will not reimburse claims using 98000–98015 (status indicator “I” — invalid). Medicare providers must continue using standard office E/M codes (99202–99215) with telehealth modifiers. CMS will, however, reimburse 98016 as the replacement for the now-deleted HCPCS code G2012.

New Audio-Only Codes: Direct Replacements for 99441–99443

Key Structural Differences: Old Codes vs. New Codes

MDM Now Required (or Time Threshold). Unlike 99441, which selected the code level based purely on the number of minutes on the call, the new codes require the provider to either document MDM complexity at the applicable level OR meet the minimum time threshold for total time on the date of the encounter.

Minimum Medical Discussion Requirement. For all audio-only codes (98008–98015), at least 10 minutes of the service must consist of synchronous (real-time) verbal medical discussion with the patient — even if MDM is used to select the level. This minimum discussion requirement ensures the service is substantively interactive rather than administrative.

New Patients Now Covered. A major structural improvement: codes 98008–98011 cover audio-only services for new patients. This did not exist under the old 99441–99443 framework.

No Modifier 95 Required on New Codes. The code descriptors for 98000–98016 already specify the telehealth modality, so Modifier 95 is not required when using these codes with payers that accept them (unlike the old framework where Modifier 95 was often required by MACs).

Brief Communication Technology-Based Service: Code 98016

CPT 98016 is a separate, new code replacing HCPCS G2012. It covers a brief 5–10 minute virtual check-in (audio or video) for established patients only, where the service is patient-initiated and does not follow from a related E/M within the previous 7 days, nor lead to an appointment within the next 24 hours. Unlike 98012–98015, this code does not require MDM documentation. CMS will reimburse 98016, making it the only new code in the 98000–98016 series covered by Medicare.

Audio-Only Billing Decision Tree (2025-2026)

flowchart TD
    A[Audio-Only Telephone<br/>E/M Service] --> B{Who is the payer?}
    B -->|Medicare| C{Patient location?}
    B -->|Commercial| D{Payer accepts<br/>98000-series?}
    C -->|Home| E[POS 10]
    C -->|Not home| F[POS 02]
    E --> G[Bill 99202-99215<br/>+ Modifier 93]
    F --> G
    D -->|Yes| H{New or established<br/>patient?}
    D -->|No| I[Check payer-specific rules]
    H -->|New| J[98008-98011<br/>by MDM or time]
    H -->|Established| K[98012-98015<br/>by MDM or time]
    A --> L{Call under 5 min<br/>or purely administrative?}
    L -->|Yes| M[Not billable]
    L -->|No - brief 5-10 min<br/>check-in| N{Patient-initiated?<br/>No related E/M in 7 days?}
    N -->|Yes| O[98016 Brief check-in]
    N -->|No| P[Use full E/M<br/>pathway above]

    style G fill:#2563eb,color:#fff,stroke:#1e40af
    style J fill:#2563eb,color:#fff,stroke:#1e40af
    style K fill:#2563eb,color:#fff,stroke:#1e40af
    style O fill:#16a34a,color:#fff,stroke:#15803d
    style M fill:#dc2626,color:#fff,stroke:#991b1b

5. Medicare-Specific Rules for 2025–2026

Medicare Audio-Only Billing in 2025–2026: Do NOT use CPT 98008–98015 for Medicare claims. Use standard office E/M codes (99202–99215) with the appropriate telehealth modifier and Place of Service code.

The Correct Medicare Billing Pathway for Audio-Only Services

For Medicare beneficiaries receiving audio-only telephone E/M services in 2025–2026, the billing method is as follows:

Select the appropriate standard office E/M code (99212–99215 for established patients; 99202–99205 for new patients) based on MDM complexity or total time, exactly as you would for an in-person or audio-video visit. Then append the audio-only modifier and Place of Service code:

Medicare Audio-Only Conditions (2025)

The 2025 Medicare Physician Fee Schedule established permanent conditions for audio-only telehealth. Both conditions must be met:

Condition A. The patient must be in their home (POS 10) during the audio-only interaction.

Condition B. The provider at the distant site must be technically capable of using live video, but the patient is either not capable of using video or does not wish to. The documentation should reflect that audio-video technology was available but not used due to patient limitations or preference.

Mental Health Carve-Out

CMS has permanently approved audio-only for mental health services. Behavioral health providers using audio-only must also comply with the in-person visit requirement — patients must have an in-person mental health visit with the provider at least once within six months before or after the telehealth service (with limited exceptions for patients in rural or medically underserved areas, or where in-person care would be clinically inappropriate).

Medicare Advantage Plans

Medicare Advantage (Part C) plans have discretion in their telehealth coverage policies and may diverge from Traditional Medicare. Some Medicare Advantage plans have adopted the new 98000-series codes. Always verify the specific plan’s telehealth billing policy before submitting claims.

6. Commercial & Medicaid Payer Guidance

The most confusing aspect of the 2025 telehealth coding transition is the stark divide between how Medicare handles audio-only E/M services and how other payers do. There is no single standard — providers must verify each payer’s policy individually.

Three-Tier Payer Landscape

Tier 1 — Payers Adopting 98000–98015 (New AMA Codes). Some commercial insurers and state Medicaid programs have adopted the new CPT codes and will accept claims using 98012–98015 for established patient audio-only visits. These payers will deny claims using the deleted 99441–99443 codes. When billing these payers, no telehealth modifier is required on the code itself, as the code descriptor already specifies the modality.

Tier 2 — Payers Following Medicare (Standard E/M + Modifier 93). Many commercial payers and Medicare Advantage plans have aligned with the Medicare approach: use standard office E/M codes (99202–99215) with Modifier 93 for audio-only and Modifier 95 for audio-video. This was already the pattern for audio-video telehealth for in-person E/M, so this tier requires the least operational change for billing teams.

Tier 3 — Payers with Custom Policies. Some large commercial payers, notably UnitedHealthcare, have published their own audio-only code lists that may not align with either the AMA framework or Medicare. For example, UHC has stated it does not allow Modifier 93 on 99200-series codes in some plans and may only allow audio-only for specific service categories like behavioral health. Providers must consult each payer’s published telehealth policy.

Medicaid: State-by-State Variation

Medicaid telehealth coverage is regulated at the state level. As of 2025–2026, state Medicaid programs vary significantly on audio-only: some permanently cover audio-only across all E/M services, others restrict it to behavioral health, and a few have not extended telehealth coverage post-PHE. Providers must check with their state Medicaid agency or managed care organization for current policy.

Practical Action Step: Create a payer matrix in your practice management system that maps each payer to its current telehealth billing requirement: (1) AMA new codes 98008–98015, (2) standard E/M + Modifier 93, or (3) payer-specific custom codes. Review and update this matrix quarterly.

7. Audit-Proof Documentation Standards

Whether you are billing under the new 98012-series codes or using the Medicare pathway (standard E/M + Modifier 93), documentation requirements have become more rigorous than they were under the old 99441–99443 framework. The following elements are essential:

Required Documentation Elements for Audio-Only Telephone E/M Services

1. Confirmation of Modality. Explicitly state in the note that the service was provided via telephone (audio-only). For Medicare claims, document that audio-video technology was available but that the patient was unable or unwilling to use it. Example: “Patient was contacted via telephone (audio-only). Patient does not have video capability on their device. Provider is equipped with video capability.”

2. Medical Necessity. The telephone service must be medically necessary. Routine callbacks to share normal lab results, appointment reminders, or prescription refills without medical evaluation do not meet the threshold for an E/M service. Document the clinical reason the call was necessary. Example: “Patient called with complaint of worsening shortness of breath. Evaluation for potential exacerbation of CHF required.”

3. Time Documentation. For time-based code selection, document the total time on the date of the encounter spent on physician work related to that patient. Note: for the new 98012–98015 codes, time includes preparation, medical discussion, and documentation work performed on the encounter date — unlike the old 99441–99443 codes, where only the time on the phone counted. State specific minutes. Example: “Total encounter time: 22 minutes (3 min chart review, 15 min medical discussion with patient, 4 min documentation).”

4. MDM Documentation (if using MDM pathway). Under the new framework, code selection can be based on MDM — document the number and complexity of problems, the amount and complexity of data reviewed, and the risk of complications or treatment. This is a significant improvement over the old time-only framework.

5. The 7-Day and 24-Hour Attestation. Document that the call was not related to an E/M provided in the prior 7 days and did not result in scheduling a same-day or next-available appointment. This is a critical compliance element for both the old and new code sets. Example: “Patient was last seen for a separate condition 21 days ago. Today’s call addresses a new, unrelated symptom. No face-to-face visit is being scheduled at this time.”

6. Established vs. New Patient Documentation. For new patient codes (98008–98011), confirm that the patient has not received a professional service from the same group specialty within the past 3 years.

7. Minimum Medical Discussion Statement. For codes 98008–98015, confirm in the note that more than 10 minutes was spent in real-time interactive verbal medical discussion (not setup time, not documentation time). Example: “Medical discussion with patient lasted 18 minutes.”

8. Modifier Reference Guide

Do Not Double-Append Modifiers 93 and 95: Modifier 93 is for audio-only. Modifier 95 is for audio-video. They are mutually exclusive. Appending both on the same claim line will likely trigger a denial or an audit flag.

9. Comparison Tables: Old Codes vs. New Framework

Direct Code Comparison: What Changed

Approximate Level Crosswalk: Old vs. New

10. Clinical Coding Scenarios (2025–2026)

Scenario 1: Established Patient, Diabetes Medication Adjustment — Commercial Payer Accepting 98000-Series

Patient: Established patient with Type 2 Diabetes calls to discuss elevated blood glucose readings over the past week. No in-person visit in past 7 days. No in-person visit scheduled.

Call: 18-minute medical discussion. Physician reviews prior lab results, adjusts metformin dosage, discusses dietary modifications, and orders HbA1c. No video technology used; patient does not have smartphone.

MDM: Prescription drug management (metformin adjustment) = Moderate risk. One chronic illness with exacerbation = Moderate problem complexity.

Correct Coding: 98014 (Established patient, audio-only, Moderate MDM, 18 min of medical discussion — exceeds 10-min minimum).

Note: If the payer does not accept 98014, use 99214 + Modifier 93 + POS 10.

Scenario 2: Medicare Patient, Anxiety Follow-Up — Mental Health Audio-Only

Patient: Medicare beneficiary with generalized anxiety disorder. Cannot use video due to limited internet access in rural setting. Calls for telephone follow-up. Provider is equipped for video but patient cannot access it.

Call: 20-minute medical discussion. Provider adjusts SSRI dosage, reviews symptom checklist, documents patient preference for audio-only and provider’s video capability.

Correct Coding (Medicare): 99213 + Modifier 93 + POS 10.

Do NOT use 98013 for Medicare. Document: “Service provided via telephone (audio-only). Patient unable to use video due to lack of broadband access. Provider is capable of audio-video. Patient is in their home.”

Scenario 3: New Patient, Commercial Insurance Accepting 98000-Series

Patient: New patient to the practice (no prior visit in 3 years from same group) calls requesting telephone E/M for hypertension management after relocating. Commercial payer accepts 98000-series.

Call: 32-minute total encounter (chart review from prior provider, 22-min medical discussion, documentation). MDM: Low complexity (one chronic illness, stable, medication refill with monitoring).

Correct Coding: 98009 (New patient, audio-only, Low MDM, 30+ min total time threshold met).

This scenario was NOT billable under the old 99441–99443 codes, as those were limited to established patients. The new 98008–98011 series fills this gap.

Scenario 4: Brief Virtual Check-In — Code 98016 (Replaces G2012)

Patient: Established Medicare patient with URI calls asking if they need to come in. No E/M in prior 7 days. Call lasts 7 minutes. Physician reviews symptoms and advises supportive care — no appointment scheduled.

Correct Coding: 98016 (Brief communication technology-based service, 5–10 minutes, patient-initiated, established patient). This is the only new telehealth code that CMS covers for Medicare — it replaced G2012 effective January 1, 2025.

Note: 98016 does not require MDM documentation. Document that the call was patient-initiated and did not result from a related E/M within 7 days, and will not lead to an appointment within 24 hours.

Scenario 5: Call That Cannot Be Billed (Common Compliance Pitfall)

Patient: Established patient calls to receive normal lab results. No new problems discussed. Physician confirms “everything looks good” and ends the call in 4 minutes.

Correct Coding: NOT BILLABLE.

Sharing test results without medical evaluation or management does not constitute an E/M service. The minimum threshold for 98016 (5–10 min) is also not met. This is a common audit finding — do not bill for purely administrative or results-relay calls.

11. Non-Physician QHPs: Codes 98966–98968 (Still Active)

While the physician/QHP telephone E/M codes (99441–99443) were deleted, their non-physician counterparts — CPT 98966, 98967, and 98968 — remain active in 2025–2026 and are unchanged. These codes apply to telephone assessment and management services provided by qualified non-physician health care professionals (such as licensed clinical social workers, occupational therapists, physical therapists, and clinical psychologists) who are not authorized to independently report E/M services.

Note that while CMS has assigned an active payment status to 98966–98968 (aligned with telehealth-related flexibilities extended via the Consolidated Appropriations Act), coverage and reimbursement for these codes remain payer-specific. Providers should verify coverage with each payer.