Navigating telehealth rules can feel like threading a needle—especially when it comes to billing for services like pain management consultations or pre-op assessments. With federal flexibilities winding down and states setting their own paces, 2025 brings a mix of opportunities and hurdles for virtual care in your field. Anesthesiology isn't typically a heavy telehealth player since most work is hands-on, but areas like chronic pain evaluations or follow-ups can qualify under E/M codes if they meet criteria. We'll break down the federal baseline from CMS, highlight state variations based on the latest reports, and share tips to keep your claims clean. Remember, these are general guidelines—always verify with payers and state boards for your specific setup.

Federal CMS Guidelines for Medicare Telehealth in Anesthesiology

On the Medicare side, CMS extended many pandemic-era flexibilities through September 30, 2025, but things tighten up after that. For anesthesiology billing, telehealth is mostly limited to non-procedural services like consultations using E/M codes (e.g., 99202-99215). Anesthesia-specific codes (00100-01999) aren't on the Medicare telehealth services list, as they're tied to in-person procedures. However, pain management add-ons or virtual check-ins might apply if documented properly.

Key points for 2025:

• Through September 30, no geographic restrictions—patients can be anywhere, including home (POS 10 for non-facility rate).
• Audio-video is preferred, but audio-only (modifier 93) is okay for certain E/M services if video isn't feasible.
• For FQHCs/RHCs, bill non-behavioral telehealth with G2025 through year-end.
• The anesthesia conversion factor drops to $20.3340, a 2.1% cut, impacting overall reimbursements.
• Post-September 30, revert to pre-PHE rules: Rural-only for most, in-person requirements for mental health (which could overlap with pain), and no home as originating site except for behavioral.

If you're billing for pain management via telehealth, use modifier 95 for synchronous video and ensure medical necessity is clear—no shortcuts here.

State Variations in Telehealth Reimbursement for Anesthesiology

States handle Medicaid and private payers differently, and while few call out anesthesiology specifically, rules for specialties like pain management often fall under general telehealth policies. The Center for Connected Health Policy (CCHP) tracks this, and as of fall 2024 (carrying into 2025 unless updated), here's a snapshot of key trends that could affect your billing for virtual pain consults or related services.

• Payment Parity States: 22 states require private payers to reimburse telehealth at the same rate as in-person (e.g., California, New York, Washington). This boosts viability for pain management E/M codes. Six more have parity with caveats, like time limits or specific modalities. Check if your state mandates this—it can mean better returns on virtual follow-ups.
• Medicaid Modality Coverage: 31 states cover all four telehealth types (live video, store-and-forward, RPM, audio-only) in Medicaid, including Alaska, California, New York, Texas, and Washington. For pain management, this opens doors for audio-only check-ins (e.g., post-procedure pain assessments) in states like Missouri, which recently expanded to include audio-only explicitly.
• Notable State Examples:
  
  • California: Medicaid reimburses virtual check-ins (CPT 98016) via phone for established patients—handy for ongoing pain management.
  • New York: Expanded RPM for outpatient settings and allows billable phone consults (99452) for certain specialties, including psych overlaps with pain. Surprise billing laws protect patients from out-of-network anesthesiology charges, even in telehealth scenarios.
  • Texas: Evaluating RPM for chronic conditions like end-stage renal disease; requires data sharing with physicians. New laws cover out-of-state telehealth if the patient is in Texas.
  • Washington: Added audio-only codes and allows telemedicine for doula services; no in-person first visit for community health workers.
  • States like South Dakota streamlined policies, expanding eligible providers and adding audio-only limits.

For private payers, 44 states plus DC have laws addressing reimbursement, but not all require parity. Prescribing rules for controlled substances (common in pain management) vary—many require a telehealth exam meeting in-person standards, with federal waivers ending December 31, 2024. Interstate compacts (e.g., Physician Assistant) in states like Iowa could ease cross-border billing.

If your state isn't listed, head to CCHP's policy finder for details—policies evolve, so check quarterly updates.

Tips to Avoid Denials and Optimize Billing

To make telehealth work for anesthesiology in 2025:

• Use the right modifiers: 95 for video, 93 for audio-only on eligible codes.
• Document consent, modality, and necessity thoroughly—payers scrutinize this.
• Verify payer policies upfront; Medicare changes hit October 1, so adjust schedules.
• For pain management, leverage new telemedicine codes if applicable, but stick to E/M for most.

Tools like automated claim scrubbers can flag issues early. At Athelas, we help anesthesiology groups simplify telehealth billing with compliance checks and real-time updates. If you're dealing with state-specific headaches, reach out—we're here to ease the load.