CPT 98011 Description, Billing Rules, & Use Cases

CPT 98011 is used to bill for a synchronous audio-only evaluation and management (E/M) service with a new patient that involves high-complexity medical decision making (MDM) or at least 60 minutes of total provider time on the date of the encounter.

This code was introduced in 2025 as part of the new audio-only telehealth E/M series (98008–98011), which replaced the deleted telephone codes (99441–99443). CPT 98011 represents the highest level of complexity and duration for new-patient, audio-only encounters and applies when the visit requires extensive review, coordination, and risk assessment.

The service typically includes:

Comprehensive medical history obtained through audio-only communication
Assessment and management of multiple or unstable conditions
Extensive counseling or care coordination related to serious or worsening health problems
Review of labs, imaging, and specialist reports
Medication management or initiation of complex treatment plans
Documentation of findings, risk assessment, and next steps

Billing Notes:

Use for new-patient audio-only E/M visits involving high MDM or ≥60 minutes of provider time.
The provider must personally perform the service using real-time, audio-only communication.
The visit may not overlap with or duplicate an in-person or audiovisual E/M service on the same day.
Documentation must clearly identify the communication method (audio-only), patient consent, and total time or MDM level.
Encounters shorter than 60 minutes may qualify for CPT 98010 (45–59 minutes).
Time beyond 74 minutes should be billed with CPT 99417 (prolonged services).

What is CPT Code 98011?

CPT 98011 is an evaluation and management (E/M) code for audio-only telemedicine visits with new patients that require high-complexity medical decision making (MDM) or 60–74 minutes of total provider time on the date of service.

Introduced in 2025, CPT 98011 represents the most advanced level in the new audio-only E/M code series (98008–98011) for new-patient encounters. It is used when a telehealth visit—conducted entirely by phone or another synchronous audio format—requires an extensive review of medical data, complex clinical reasoning, and significant management risk.

Key points about CPT 98011:

Used for new patient audio-only visits requiring high MDM or ≥60 minutes of provider time.
The encounter must include a medically appropriate history and/or exam, with complex care decisions documented.
The communication must be real-time and synchronous (not prerecorded or message-based).
Includes multiple problem management, data interpretation, and risk assessment activities.
The visit must be personally performed by a qualified healthcare provider (physician, NP, or PA).
The service cannot occur on the same day as an in-person or audio-video E/M encounter.

In summary: CPT 98011 captures high-complexity audio-only E/M visits for new patients that require extensive medical evaluation, coordination, and clinical judgment over a prolonged time period (typically 60–74 minutes).

CPT 98011 Time Thresholds and Code Combinations

CPT 98011 represents a synchronous audio-only evaluation and management (E/M) service for a new patient that involves high-complexity medical decision making (MDM) or at least 60 minutes of total provider time on the date of service.

Understanding the Time Component

When billing by time, a minimum of 60 minutes must be personally spent by the provider performing the encounter and associated medical work on the same date.
Included time may involve:

Reviewing medical records, test results, or specialist notes before or during the call
Conducting a detailed, structured audio-only evaluation
Discussing complex care decisions or multiple treatment options with the patient
Coordinating with other providers and arranging follow-up plans
Documenting the encounter in the patient’s medical record

If total time exceeds 74 minutes, report CPT 99417 (prolonged services) in addition to 98011.
Encounters shorter than 60 minutes may meet criteria for CPT 98010 (45–59 minutes).

Understanding the MDM Component

When selecting by medical decision making, documentation must demonstrate high complexity, including:
Multiple chronic or serious conditions requiring active management
Review and integration of extensive data or test results
High risk of morbidity, mortality, or treatment complications

CPT 98011 time threshold table for audio-only new-patient E/M visits. Highlights that CPT 98011 covers 60–74 minutes of total provider time or high-complexity medical decision making. Also lists CPT 98008 for 15–29 minutes, 98009 for 30–44 minutes, 98010 for 45–59 minutes, and 98011 plus 99417 for prolonged services beyond 75 minutes.

When to Use CPT 98011: Common Scenarios and Use Cases

CPT 98011 is appropriate when a physician, nurse practitioner (NP), or physician assistant (PA) provides a synchronous audio-only evaluation and management (E/M) visit with a new patient that involves high-complexity medical decision making (MDM) or 60–74 minutes of total provider time.

Here are examples of how CPT 98011 is used in practice:

Multimorbidity Evaluation for CHF and Diabetes

Oncology Review and Planning

Psychiatric Intake With Medication Overhaul

Multimorbidity Evaluation for Complex Heart Failure and Diabetes

A cardiologist allocates time to:

Review detailed records from multiple specialists and recent hospitalizations
Reconcile conflicting medication lists and adjust heart failure therapy
Counsel on advanced disease management and coordinate follow-up with endocrinology

Total time: 67 minutes
Billing: 98011

Smiling nurse on phone call while working on laptop in medical office, representing patient outreach, care coordination, and proactive clinical communication

Oncology Treatment Review and Care Transition Planning

An oncology nurse practitioner (NP) allocates time to:

Review imaging results, pathology reports, and laboratory data
Discuss disease progression, side effects, and potential treatment adjustments
Provide emotional support and arrange palliative care coordination

Total time: 70 minutes
Billing: 98011

Female physician using smartphone and laptop in clinical office, illustrating digital health management, secure communication, and EHR workflow optimization

Psychiatric Intake for Severe Bipolar Disorder With Medication Overhaul

A psychiatric physician assistant (PA) allocates time to:

Conduct a comprehensive psychiatric history and safety assessment
Evaluate prior medication response and adjust polypharmacy regimen
Coordinate care with a therapist and establish a follow-up crisis plan

Total time: 73 minutes
Billing: 98011 (+99417 for prolonged service if total time exceeds 74 minutes)

Nurse wearing scrubs and a stethoscope, speaking through a headset while working at a computer for monthly time tracking and documentation in Chronic Care Management (CCM).

CPT 98011 Billing Requirements and Eligibility

CPT 98011 is used to report a synchronous audio-only evaluation and management (E/M) visit with a new patient that involves high-complexity medical decision making (MDM) or at least 60 minutes of total provider time.

This code reflects the most complex and extended level of new-patient audio-only telehealth services introduced in 2025, replacing the upper tier of the discontinued telephone codes (99443).

Patient Eligibility

To qualify for CPT 98011:

The patient must be a new patient (not seen by the same provider or group within the past three years).
The encounter must be conducted via audio-only technology, with real-time, two-way verbal communication.
The patient must provide verbal consent for telehealth delivery and agree to an audio-only format.
The condition(s) discussed must require high-complexity MDM or ≥60 minutes of total provider time.
The service must not occur on the same day as an in-person or audio-video telehealth encounter.

Provider Eligibility

The encounter must be personally performed by a physician, nurse practitioner (NP), or physician assistant (PA) qualified to report E/M services.

The provider must:

Conduct the entire discussion and decision-making process personally.
Document the time spent, MDM complexity, and mode of communication (audio-only).
Provide a clinical assessment and plan consistent with high-level E/M standards.

Service Requirements

Minimum provider time: 60 minutes on the date of service.
Countable time includes reviewing prior data, conducting the clinical discussion, care coordination, and same-day documentation.
Non-countable time includes administrative tasks, scheduling, and unrelated communication outside the encounter.
May be selected by time or MDM, but documentation must support the higher criterion.
Follow-up arrangements and referrals must be recorded.

Documentation Requirements

The visit note must clearly include:

Start and end time, or total provider time (≥60 minutes).
Consent for audio-only telehealth care.
Statement of modality (e.g., “audio-only telehealth encounter, no video used”).
Reason for the encounter (chief complaint).
High-complexity MDM elements, including:
- Problems: Multiple or serious conditions requiring significant clinical judgment.
- Data: Extensive data or test review, with multiple sources consulted.
- Risk: High risk of morbidity, mortality, or treatment complications.
Comprehensive clinical summary, including findings, decisions made, and treatment plan.
Provider attestation verifying personal performance and accuracy of the record.
Non-duplication statement confirming the service was not combined with other same-day E/M encounters.

Medicare and Payer Coverage Notes

Medicare: CPT 98011 currently holds a status indicator “I” (invalid for Medicare billing).
Commercial payers: May adopt CPT 98011 for reimbursement using the RBRVS framework.
Providers should confirm payer telehealth policies, as rules for audio-only coverage vary by state and insurer.

CPT 98011 Billing Documentation Checklist

To support compliant billing for CPT 98011, documentation must verify that the encounter was a real-time, audio-only telehealth visit with a new patient, requiring high-complexity medical decision making (MDM) or at least 60 minutes of total provider time.

Your encounter record should include:

Patient consent for the use of audio-only telehealth, documented at the start of the encounter.
Verification of patient identity using at least two identifiers (e.g., name and date of birth).
Provider credentials and role (physician, NP, or PA) clearly listed.
Statement of modality indicating “audio-only synchronous communication” (no video used).
Chief complaint or reason for visit describing the presenting issue(s).
Total provider time documented as ≥60 minutes, including:
- Exact start and end times, or
- Total duration on the date of the service.
High-complexity MDM documentation, showing:
- Problems: Multiple or unstable chronic conditions, or new issues requiring in-depth evaluation.
- Data: Extensive review of labs, imaging, and external records.
- Risk: High risk of morbidity, mortality, or treatment complications.
Summary of clinical discussion, including:
- Patient-reported symptoms and findings gathered via audio discussion.
- Assessment, care decisions, and treatment plan.
- Referrals or follow-up arrangements.
Provider attestation confirming that the service was personally performed and accurately documented.
Non-overlap statement verifying that no other E/M (in-person or video) was billed on the same day.
Documentation of follow-up plan, including in-person or telehealth revisit schedule.

Common CPT 98011 Billing Mistakes (and How to Avoid Them)

❌ Billing Without 60 Minutes of Documented Time

When coding by time, providers must clearly record at least 60 minutes of total provider time on the date of service. Encounters under this threshold should be billed with CPT 98010 (45–59 minutes).

❌ Missing High-Complexity MDM Justification

If selecting the code based on medical decision making, documentation must show high complexity — multiple serious or unstable conditions, extensive data review, and high risk of treatment complications.

❌ Failing to Specify Audio-Only Modality

Each note must explicitly state that the encounter was conducted via audio-only synchronous communication. Payers often deny claims when this is not documented.

❌ Omitting Patient Consent or Identity Verification

Patient consent to receive telehealth care — and identity confirmation — must be documented at the beginning of the encounter.

❌ Using CPT 98011 for Established Patients

This code applies only to new-patient encounters. Established patient audio-only services should use CPT 98015 or the corresponding code (98012–98015).

❌ Counting Non-Billable Time

Administrative or setup activities, scheduling, or documentation completed outside the date of service cannot be counted toward total time. Only provider-performed, medically necessary work qualifies.

❌ Reporting 98011 With Same-Day E/M Codes

Audio-only E/M codes (98008–98011) cannot be billed in conjunction with in-person or video-based E/M services for the same patient on the same day.

❌ Incomplete Clinical Summary

Even though the encounter is audio-only, the provider must include a clear clinical narrative covering the history, assessment, plan, and follow-up — missing this detail can lead to payer audits or denials.