CPT 98008 Description, Billing Rules, & Use Cases

CPT 98008 is used to bill for a synchronous audio-only evaluation and management (E/M) visit with a new patient, requiring a medically appropriate history and/or examination and straightforward medical decision making (MDM).

This code is part of the new 2025 telemedicine E/M series (98008–98015), which replaced the previous telephone E/M codes (99441–99443 and 99421–99423). CPT 98008 captures audio-only encounters that do not use video but still meet the standards of a clinically appropriate E/M service.

The visit typically includes:

Collecting a problem-focused history through a phone call or equivalent audio connection
Performing an assessment and making a straightforward medical decision
Counseling the patient on next steps, prescriptions, or monitoring instructions
Coordinating follow-up or documenting clinical recommendations

Billing Notes:

Applies only to audio-only encounters — not video-enabled telehealth.
The provider must spend at least 15 minutes on the call when coding by time.
Used for new patients only (those not seen within the past three years).
Must meet all documentation standards for E/M services, including consent, identity verification, and time or MDM justification.

What is CPT Code 98008?

CPT 98008 is an evaluation and management (E/M) code used to report audio-only telemedicine visits with new patients, when the provider conducts a medically appropriate history and/or examination and makes a straightforward medical decision.

Introduced in 2025, this code reflects the continued recognition of audio-only visits as valid telehealth encounters, particularly for patients who cannot access video platforms due to connectivity, device, or privacy limitations.

Key points about CPT 98008:

It applies to new patient encounters (not seen by the same provider group within the last three years).
The provider must spend at least 15 minutes on the date of the encounter when coding by time.
The encounter must involve synchronous (real-time) audio communication — asynchronous messaging or store-and-forward systems do not qualify.
The provider must document all required elements of an E/M visit, including patient consent, medical necessity, and assessment or plan.
If the visit extends beyond 15 minutes, a higher-level audio-only code (such as 98009 or 98010) should be used.

In summary: CPT 98008 is designed for clinically significant audio-only visits with new patients where the provider spends at least 15 minutes and performs straightforward MDM, aligning telemedicine billing with the E/M framework used for in-person care.

CPT 98008 Time Thresholds and Code Combinations

CPT 98008 represents a synchronous audio-only evaluation and management (E/M) encounter for a new patient that requires more than 10 minutes of medical discussion and at least 15 minutes of total provider time when time-based coding is used.

This code may be selected based on either total time on the date of the encounter or medical decision making (MDM). Providers should ensure documentation supports both time and MDM to justify the level of service.

When total time exceeds the 15-minute threshold for CPT 98008, the next code in the audio-only series (e.g., CPT 98009, 98010) should be used to reflect the higher level of E/M service.

Important to Note:

Audio-only E/M services must include real-time verbal communication — asynchronous methods (e.g., portal messages, store-and-forward data) do not qualify.
Time spent setting up technology or making the connection cannot be counted.
Audio-only encounters cannot be reported on the same day as an in-person or audio-video E/M visit.
Prolonged service time beyond the highest-level audio-only E/M (e.g., 98011) may be reported using +99417, once the minimum required time has been exceeded by 15 minutes.

Time-based table for audio-only new-patient E/M codes: 98008 for 15–29 min, 98009 for 30–44 min, 98010 for 45–59 min, 98011 for 60–74 min; add 99417 for 75+ minutes. Includes a row noting that ≤10 minutes is not billable for new-patient audio-only.

When to Use CPT 98008: Common Scenarios and Use Cases

CPT 98008 is appropriate when a physician, nurse practitioner (NP), or physician assistant (PA) provides an audio-only telemedicine visit with a new patient that involves straightforward medical decision making (MDM) or at least 15 minutes of total provider time. These visits occur when a video connection is unavailable or unnecessary but the encounter still meets the requirements of a billable E/M service.

Here are examples of how CPT 98008 is used in practice:

Initial Evaluation for Seasonal Allergies

Triage and Counseling for Minor Urinary Tract Infection

New-Patient Evaluation for Mild Anxiety

Initial Evaluation for Seasonal Allergies

A family medicine physician allocates time to:

Review the patient’s history of seasonal allergy symptoms
Discuss over-the-counter and prescription medication options
Provide education on environmental control and follow-up needs

Total time: 16 minutes
Billing: 98008

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

Triage and Counseling for Minor Urinary Tract Infection

A nurse practitioner allocates time to:

Review presenting symptoms and medication allergies
Assess need for antibiotics and provide prescription
Counsel on hydration, warning signs, and follow-up if symptoms worsen

Total time: 18 minutes
Billing: 98008

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

New-Patient Evaluation for Mild Anxiety (Audio Only)

A psychiatric physician assistant allocates time to:

Obtain a focused behavioral health history
Review lifestyle factors and initiate non-pharmacologic interventions
Provide coping guidance and plan follow-up for medication consideration

Total time: 20 minutes
Billing: 98008

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 98008 Billing Requirements and Eligibility

CPT 98008 is used to report a synchronous audio-only telemedicine visit with a new patient, requiring a medically appropriate history and/or examination and straightforward medical decision making (MDM). When selecting by time, the provider must spend at least 15 minutes in real-time medical discussion on the date of service.

These services were introduced in 2025 to replace the discontinued telephone E/M codes (99441–99443) and reflect the permanent recognition of audio-only encounters as valid E/M visits when clinically appropriate.

Patient Eligibility

The patient must:

Be a new patient (not seen by the same provider or group within the past three years).
Provide verbal consent to receive care through audio-only telemedicine.
Have a condition that can be safely evaluated without a video or in-person visit.
Participate in real-time (synchronous) communication; asynchronous messages do not qualify.

Provider Eligibility

The service must be personally performed by a physician, nurse practitioner (NP), or physician assistant (PA) who can bill for E/M visits.
- The provider must directly engage in the call and make clinical decisions.
- Clinical staff time cannot be counted toward the total duration.
- Providers must document the method of communication (e.g., audio-only phone call) and confirm patient identity.

Service Requirements

Minimum duration: Must exceed 10 minutes of medical discussion; total time ≥15 minutes is required if billing by time.
Cannot be reported the same day as an in-person or audio-video E/M service.
Time must include only provider activities (discussion, counseling, documentation, coordination).
Encounters may be selected by time or MDM — both must align with a straightforward level of decision making.
Follow-up arrangements should be documented (in-person, telehealth, or referral).

Documentation Standards

Record start and end time of the encounter.
Note total time spent, mode of communication, and patient consent.
Document chief complaint, history, assessment, and plan consistent with E/M standards.
Include a brief summary of the discussion and clinical rationale for decisions made.
If using time-based selection, note total provider time only — exclude scheduling, setup, or administrative tasks.

Medicare and Payer Coverage Notes

Medicare: Currently designated as Status “I” (invalid for Medicare use); no payment assigned under the Physician Fee Schedule.
Commercial payers: Many may follow CPT valuation for reimbursement using the RBRVS framework.
Providers should confirm payer-specific telehealth coverage and documentation policies for audio-only encounters.

CPT 98008 Billing Documentation Checklist

To ensure compliant billing for CPT 98008, documentation must clearly support both the audio-only format and the E/M service level.

Your encounter record should include:

Patient consent for the audio-only visit, documented at the start of the encounter.
Verification of patient identity and confirmation that the visit was conducted via synchronous audio-only communication (e.g., telephone).
Reason for the encounter (chief complaint or presenting problem).
Provider details, including name, credentials, and role (physician, NP, or PA).
Duration of the call:
- Record exact start and end times, or
- Document total provider time if selecting by time.
Summary of the medical discussion, including:
- Relevant history or focused review of systems
- Clinical findings or assessment from the discussion
- Diagnosis or differential diagnosis
- Plan for treatment, medication, or follow-up care
MDM elements, if coding by complexity:
- Problem(s) addressed: straightforward or self-limited condition
- Data reviewed or ordered: minimal or none
- Risk: low (minimal risk of morbidity or treatment side effects)
Provider attestation confirming the visit was performed personally and documented accurately.
Statement of modality specifying audio-only communication (no video used).
Non-duplication statement confirming the service was not part of an in-person or video telehealth encounter on the same day.

Common CPT 98008 Billing Mistakes (and How to Avoid Them)

❌ Billing for Less Than 10 Minutes of Audio Communication

CPT 98008 requires more than 10 minutes of real-time medical discussion. Calls shorter than 10 minutes do not qualify as billable encounters.

❌ Failing to Document Audio-Only Format

Providers must clearly state that the visit was audio-only and not video-enabled. Missing this detail may lead to payer denials or reclassification as a non-billable interaction.

❌ Using 98008 for Established Patients

This code applies only to new patients. Established patient audio-only visits should use codes 98012–98015 instead.

❌ Omitting Patient Consent

Patient consent to receive care through telemedicine — including acknowledgment that the service is audio-only — must be documented before or at the start of the encounter.

❌ Counting Administrative or Setup Time

Only time spent on medical discussion or decision making counts toward the billable total. Time spent on scheduling, technology setup, or documentation outside the encounter cannot be included.

❌ Reporting 98008 on the Same Day as a Video or In-Person Visit

Audio-only services may not be billed in conjunction with in-person or audio-video E/M codes for the same patient on the same day.

❌ Missing Follow-Up Documentation

Even for straightforward MDM, the record must include a clinical plan, next steps, and any follow-up arrangements — especially if escalation to in-person care is recommended.