California’s New Telehealth Billing Requirements for 2025: What Medical Providers Need to Know

As part of the 2025 updates to the Official Medical Fee Schedule (OMFS), the California Division of Workers’ Compensation (DWC) has introduced significant changes to telehealth billing for workers’ compensation claims. Effective February 1, 2025, these updates align with Medicare’s telehealth payment rules and impact how providers bill for remote medical services.

The new telehealth billing requirements include:

• Updated billing code modifiers (Modifier 93 & Modifier 95)
• Approval of audio-only services for all telehealth treatments
• Elimination of three telehealth billing codes
• Designation of certain telehealth codes as non-payable

With accurate billing being critical to timely reimbursements, providers must understand these changes to avoid payment delays or denials. Below, we break down the latest telehealth regulations and what they mean for California workers’ compensation providers.

Key Changes to Telehealth Billing in 2025

The new billing requirements impact how telehealth services are reported, processed, and reimbursed under the CA OMFS. These changes focus on:

1. New Telehealth Billing Code Modifiers

The CA DWC has adopted two mandatory telehealth billing modifiers to indicate the technology used during patient interactions:

• Modifier 93 – Applied when telehealth services are delivered using real-time, audio-only communication (e.g., phone calls).
• Modifier 95 – Applied when telehealth services involve real-time, interactive audio-video communication (e.g., video consultations).

Important: These modifiers do not change the reimbursement amount for telehealth services but ensure compliance with documentation requirements.

2. Audio-Only Telehealth Now Allowed for All Services

Previously, many telehealth services required video communication for reimbursement under workers’ compensation. However, starting February 1, 2025, all telehealth services may be provided using audio-only technology, provided that:

• The provider is capable of using video but the patient is not or declines video.
• The service meets the same medical necessity and documentation standards as video-based telehealth.

What This Means for Providers:

• Audio-only visits will be reimbursed at the same rate as video consultations.
• Providers must use Modifier 93 when billing for audio-only telehealth encounters.
• This update expands telehealth access, particularly for patients with limited technology resources.

3. Removal of Three Key Telehealth Billing Codes

The DWC update also eliminates three telehealth CPT codes, effective February 1, 2025. These codes are no longer reimbursable under the California OMFS:

Action Needed:

• Providers must use alternative Evaluation & Management (E/M) codes to bill for these services.
• If a claim includes one of the removed codes, it will be denied for payment.

4. Non-Payable Telehealth Codes (Status Indicator ‘I’)

Certain telehealth procedure codes now have a Status Indicator ‘I,’ meaning they are non-payable under the CA OMFS. Instead, providers must bill using an alternative payable CPT code.

Impact on Billing:

• If a telehealth service falls under a non-payable code, it must be reported using the corresponding alternative E/M code.
• Claims using non-payable telehealth codes will be denied if not corrected before submission.

For a complete list of non-payable telehealth codes, refer to the CA DWC’s official fee schedule update or consult MLM’s billing specialists.

How MLM Helps You Stay Compliant

With new telehealth regulations in place, providers must ensure accurate billing to avoid claim denials and payment delays. At Medical Lien Management (MLM), we specialize in workers’ compensation billing and lien management, ensuring that:

Final Thoughts

With the new telehealth billing updates in place, California workers’ compensation providers must stay informed to avoid reimbursement issues. The introduction of audio-only telehealth approval, new billing modifiers, and code eliminations marks a significant shift in how remote medical services are billed.

At MLM, we take care of the complexities so you can focus on providing quality care to injured workers. Let us handle your billing, appeals, and collections while ensuring compliance with the latest CA DWC telehealth regulations.