CPT Code 98016: Brief Virtual Check-Ins Billing Guide

CPT 98016 is a code defined by the American Medical Association for a brief, patient-initiated virtual check-in lasting 5 to 10 minutes between an established patient and a physician or other qualified healthcare professional who is eligible to report evaluation and management (E/M) services.

This communication technology–based service may be conducted via audio-only or audio/video and is used to assess a patient’s concern without requiring an in-person visit.

Effective January 1, 2025, the Centers for Medicare & Medicaid Services began reimbursing CPT 98016, replacing HCPCS code G2012.

The code is part of the broader telemedicine E/M code set (98000–98016), developed to standardize remote care coding after the COVID-19 public health emergency. However, Medicare currently recognizes and reimburses only CPT code 98016 from this series.

This guide covers the CPT 98016 definition, billing rules, time requirements, eligibility criteria, documentation standards, reimbursement details, common mistakes, and denial management.

98016 CPT Code Description

The American Medical Association(AMA) describes CPT 98016 as

‘’A brief synchronous communication technology-based service, commonly known as a virtual check-in, conducted using real-time audio-only or audio-video communication. The interaction lasts 5 to 10 minutes and is intended for short clinical discussions that do not require a full evaluation and management visit.’’

The service must be initiated by an established patient and must stand alone. It cannot be related to an evaluation and management service provided within the previous 7 days, nor can it result in an evaluation and management service or procedure within the next 24 hours or the soonest available appointment. This ensures the code is used strictly for brief, independent clinical check-ins rather than bundled or follow-up care.

Key Elements of CPT 98016

Below are the key elements of CPT 98016

• Effective date: January 1, 2025, marking when this code became active for billing and reporting.
• Replaced: HCPCS G2012, consolidating brief virtual check-in services under a single updated code.
• Time window: 5 to 10 minutes of medical discussion, intended for short, focused patient interactions.
• Patient type: Established patients only, meaning a prior provider–patient relationship must already exist.
• Modality: Audio-only or audio/video, allowing flexibility between phone and video communication.
• Initiated by: Patient, requiring the interaction to be started by the patient rather than the provider.
• Medicare payable: Yes, reimbursable when all Medicare criteria and documentation requirements are met.
• Work RVU: 0.30 (CY 2025 final rule), reflecting the relative provider effort for this brief service.

Who Can Bill CPT 98016?

Only physicians and other qualified healthcare professionals who can independently report E/M services may bill 98016. This rules out clinical staff, medical assistants, and most therapy providers.

• Physicians (MD, DO)
• Nurse practitioners
• Physician assistants
• Certified nurse-midwives
• Clinical nurse specialists
• Other professionals authorized to report E/M services under their state’s scope of practice

Primary care, internal medicine, cardiology, behavioral health, endocrinology, and chronic care specialties bill this code most often. Any specialty that manages established patients between visits can use it for medication questions, post-test discussions, or symptom triage.

Speech-language pathologists, occupational therapists, physical therapists, and other professionals whose scope does not include E/M services cannot bill 98016. They report virtual check-ins under HCPCS G2251 instead.

When Should You Use CPT 98016?

Use 98016 when an established patient calls with a quick clinical question that requires 5 to 10 minutes of medical discussion and is not related to a recent or upcoming office visit. The service helps decide if a fuller visit is needed.

Patient eligibility requirements

Three rules apply to every 98016 claim:

1. Established patient rule. The patient must have had a prior in-person or telehealth E/M visit with the provider or another provider in the same group and same specialty within the past three years.
2. Patient-initiated communication. The patient or caregiver must start the contact. Provider outreach calls do not qualify.
3. Verbal consent. The patient must agree to the virtual check-in, and the medical record must show consent. This protects against denials tied to cost-sharing rules.

Common clinical scenarios

• A diabetic patient calls about a blood sugar reading two weeks after a medication change.
• A hypertensive patient asks whether to keep taking a new pill after mild side effects.
• A patient calls to discuss a normal lab result and asks whether they need to come in.
• A post-surgical patient calls about minor wound care between scheduled follow-ups.

When Not To Use CPT 98016

The code does not apply if any of the following are true:

• The discussion ties to an E/M service from the previous 7 days.
• The check-in leads to an E/M service or procedure within the next 24 hours or the next available appointment.
• The patient is new to the practice.
• The discussion lasts under 5 minutes or over 10 minutes.
• The clinical staff (not the provider) handled the call.

Time requirements for CPT Code 98016

The 5-to-10-minute window is strict. Calls under 5 minutes are not billable. Calls over 10 minutes belong to a higher-level audio-only or audio/video E/M code.

What time counts

• Direct medical discussion with the patient
• Brief record review during the call
• Documentation completed during the conversation

What time does NOT count

• Hold time
• Scheduling the appointment
• Setting up the audio or video connection
• Front-desk intake or triage by clinical staff
• Documentation was completed long after the call

CPT 98016 vs. G2012: What changed?

CMS deleted HCPCS G2012 effective January 1, 2025, and replaced it with CPT 98016. The clinical service is the same, but the code is now part of CPT instead of HCPCS Level II.

Practices needed to update charge masters, EHR templates, and superbills for January 1, 2025. Claims with G2012 dates of service on or after that date are denied. Outstanding G2012 claims for 2024 dates of service can still be paid under the old code.

How Does CPT 98016 Compare to Other Virtual Care Codes?

The 98016 code occupies a narrow space, sitting between digital messaging and full audio-only E/M visits. The table below shows where it fits.

Documentation requirements for CPT 98016

Documentation must demonstrate that the service complied with all billing rules. Missing any element raises a risk on audit. Below are the required elements in the medical record for billing CPT code 98016

• Date and start/end time of the call
• Total minutes of medical discussion (between 5 and 10)
• Modality used (audio-only or audio/video)
• Patient-initiated language (e.g., “patient called regarding…”)
• Verbal consent statement
• Confirmation that no related E/M service occurred in the prior 7 days
• Confirmation that the call did not lead to an E/M service within 24 hours
• Reason for the call (chief concern)
• Clinical discussion summary
• Provider name, credentials, and signature

Reimbursement Rate Of CPT Code 98016

Medicare pays $17.37 (Facility) and $13.03 (Non-Facility) for CPT 98016. Commercial payers such as UnitedHealthcare, Cigna, Aetna, and Anthem typically pay a median rate of $15.58 for CPT 98016. Reimbursement varies by Medicare Administrative Contractor (MAC), geographic location, provider specialty, and contract terms, so always confirm rates using your local fee schedule or payer agreement.

Modifiers used with CPT 98016

The 98016 descriptor already identifies the service as technology-based, so most payers do not require a telehealth modifier. Some payers and audit programs still expect one, so check the policy before claim submission.

• Modifier 95: Modifier 95 indicates synchronous audio/video telehealth. CMS and most payers do not require modifier 95 with 98016 because the modality is built into the descriptor.
• Modifier 93: Modifier 93 marks audio-only services. Some commercial payers want it appended to 98016 for audio-only check-ins, even though the code descriptor allows audio-only. Medicare does not require modifier 93 on 98016.

Common CPT Code 98016 Billing Mistakes (and how to avoid them)

The most damaging errors come from misunderstanding the time, patient-initiation, and 7-day/24-hour rules. These mistakes drive most denials and audit findings.

1. Mistake 1: Billing without 5 minutes of documented time: The minimum threshold is 5 minutes. Calls under 5 minutes are non-billable. Track time with start and stop entries in the EHR.
2. Mistake 2: Using 98016 for calls exceeding 10 minutes: Calls over 10 minutes shift to higher codes, 98012–98015 for audio-only E/M, or G2252 for an extended virtual check-in. Billing 98016 for a 14-minute call is incorrect coding.
3. Mistake 3: Applying the code to new patients: The descriptor limits 98016 to established patients. New-patient calls cannot use this code. The visit must wait for an in-person or video E/M encounter that establishes the patient relationship.
4. Mistake 4: Missing patient-initiated documentation: The chart must show that the patient or caregiver started the contact. A note like “called patient to follow up” disqualifies the encounter.
5. Mistake 5: Omitting modality statement: The note must say whether the service was audio-only or audio/video. Audits flag claims with no modality statement.
6. Mistake 6: Billing within the 7-day or 24-hour exclusion window: If the patient had an E/M service within 7 days before the call, or has one scheduled within 24 hours after, the check-in is bundled into that E/M service. It cannot be billed separately.
7. Mistake 7: Counting non-clinical time: Setup time, hold time, and administrative scheduling do not count toward the 5–10 minute threshold. Only direct medical discussion counts.
8. Mistake 8: Incomplete consent documentation: Verbal consent must be in the chart. A blanket consent on the practice intake form is not enough; best-practice guidance from MAC contractors recommends per-encounter consent because cost-sharing applies.

How to Handle CPT 98016 Denials

Most denials trace back to documentation gaps or rule violations. A clear appeal process recovers many of these claims.

Top reasons claims get denied

1. Service billed within the 7-day exclusion window
2. Patient not established
3. Time under 5 minutes documented
4. Missing modality or consent statement
5. Wrong POS code
6. Provider type not eligible
7. Same-day E/M billed (the check-in bundles into the E/M)

Step-by-step appeal process

1. Pull the denial reason code from the EOB or remit advice.
2. Match the denial to a specific 98016 rule.
3. Pull the chart note and confirm whether the documentation meets the rule.
4. If documentation supports the claim, file a redetermination with the MAC within 120 days, attaching the chart note and consent.
5. If documentation gaps caused the denial, write off the claim and update internal templates to prevent repeat errors.

Documentation to strengthen appeals

• Full chart note with start/end times
• Verbal consent statement
• Patient-initiated note
• Confirmation that no related E/M occurred in the prior 7 days
• Modality statement
• Provider attestation

When to write off vs. resubmit

Resubmit when documentation supports the service and the denial was a payer error or POS mismatch. Write off when the time, patient status, or 7-day rule was not met. Resubmitting unsupported claims raises audit risk.

Billing Checklist For CPT Code 98016

You can use this checklist for every 98016 claim to keep clean-claim rates high.

Final words

CPT 98016 gives practices a clean way to bill brief, patient-initiated check-ins between full visits. The code rewards careful documentation: patient-initiated language, time tracking inside the 5-to-10-minute window, modality statements, consent, and confirmation that the call falls outside the 7-day and 24-hour windows. Practices that train billing staff on the differences between 98016, G2252, 99421–99423, and the audio-only E/M codes (98012–98015) hold higher clean-claim rates and lower audit risk. Stay current with annual CMS Physician Fee Schedule updates, since rates, modifier policy, and POS rules change every January 1.