In 2025, the telemedicine audio-video codes are just like the office visit codes, report them based either on total time or MDM. For example, the established patient visit that would require 10 minutes total time may be more frequently selected based on MDM. These codes have no requirement for a specific number of minutes spent in medical discussion.
The audio-only codes do have a requirement for more than 10 minute of medical discussion (distinctly required time for medical discussion) in addition to the options of code selection based on total time (ie, time of medical discussion plus other physician or QHP time on the date of service or on MDM. The audio-only telemedicine service to a new patient that does not include more than 10 minutes of medical discussion would not be reported. If the patient is established, and all other requirements for 98016 are met (eg, service is patient-initiated and for purposes of determining if a more extensive visit is indicated), an audio-only service of at least 5 minutes and not more than 10 minutes would be reported with 98016.
Be sure to review payer policies, especially for payers that generally adopt Medicare policies, as they may require use of codes other than the telemedicine codes (eg, office visit codes with modifier 93 or 95) despite CPT instructions.
I hope that helps.
Cindy