Which Telehealth CPT Codes Are Covered for Naturopathic Services?

Telehealth has completely changed how naturopathic doctors connect with patients. Patients value the convenience of virtual visits. But here’s the problem: Billing telehealth visits as a naturopathic physician can be confusing. Insurance rules change from state to state. Medicare has different policies from private insurance companies. And the codes keep getting updated, with new ones added in 2025 that some payers accept and others reject.

Getting paid correctly for your telehealth services isn’t just about the money. It’s about building a practice that works in the digital world. Let’s break down which telehealth CPT codes are covered for naturopathic services, how to bill them right, and the key documentation to keep claims from getting denied.

Why Telehealth Billing Matters for Naturopathic Doctors

The COVID-19 pandemic forced everyone to adopt telehealth quickly. Now, even though life has returned to normal, patients still want virtual options. The Centers for Medicare & Medicaid Services extended telehealth flexibilities through January 30, 2026, indicating that virtual care is here to stay.

Right now, 26 jurisdictions in the United States license naturopathic physicians. Each state has different rules about what naturopathic doctors can do. Insurance coverage varies even more.

Can Naturopathic physicians bill the same Codes as Medical Doctors?

Yes. Naturopathic physicians use the same CPT codes as MDs and DOs. The codes don’t change based on your specialty.

However, getting insurance to pay for those codes is a different story. It depends on:

• Your state’s insurance mandates
• Whether you’re credentialed with the payer
• The specific insurance company’s policies
• What services are you providing

The Main Telehealth Codes Naturopathic Physicians Use

When people ask which telehealth CPT codes are covered for naturopathic services, they’re usually talking about evaluation and management codes. These are the same codes you use for regular office visits, just with special markers to show it was virtual.

New Patient Codes (99202-99205)

These codes are for patients you haven’t seen in three years or longer:

• 99202: 15-29 minutes
• 99203: 30-44 minutes
• 99204: 45-59 minutes
• 99205: 60-74 minutes

Established Patient Codes (99212-99215)

Use these for follow-up visits with existing patients:

• 99212: 10-19 minutes
• 99213: 20-29 minutes
• 99214: 30-39 minutes
• 99215: 40-54 minutes

Research examining over 300,000 naturopathic visits found that 75% involved chronic conditions, 20% acute problems, and 5% wellness visits. This pattern means that most naturopathic visits qualify for higher-level codes, such as 99214, 99215, 99204, or 99205, for new patients.

While you can bill these codes, not every insurance company covers naturopathic services. Medicare generally doesn’t pay naturopathic physicians for routine care, whether in person or via telehealth. Private insurance depends on state laws and individual company policies.

What Changed in 2025: New Telehealth Codes

The American Medical Association added brand new telehealth codes in 2025: 98000 through 98007. These were built specifically for virtual visits and don’t need extra modifiers.

But here’s the important part: Medicare doesn’t accept these new codes. Medicare still wants you to use the regular office visit codes (99202-99215) with the right place-of-service markers. Many private insurance companies haven’t started accepting them either.

Before you use codes 98000-98007, call the insurance company to confirm they accept them. For Medicare patients, stick with the traditional codes.

Place of Service Codes

This is one of the most important parts of telehealth billing. The place-of-service (POS) code tells insurance where the patient was during the visit. It affects how much you get paid.

Two Main POS Codes for Telehealth

• POS 10: Patient at home during telehealth visit
• POS 02: Patient NOT at home (like at a clinic or facility)

These codes change Medicare payment rates. Facility rates apply to POS 02. Non-facility rates apply to POS 10.

Common Mistakes to Avoid

Never use POS 11 for telehealth visits. That code is only for regular in-person office visits. Using POS 11 for a telehealth claim will result in immediate denial.

Visit Type	CPT Code	Time Required	POS Code	Common Use
New patient telehealth	99204	45-59 minutes	02 or 10	Initial consultation with complex health history
Established patient telehealth	99214	30-39 minutes	02 or 10	Follow-up for chronic condition management
Virtual check-in	98016	5-10 minutes	02 or 10	Brief patient-initiated questions
E-visit	99421-99423	Varies	02 or 10	Patient portal messages over 7 days

When Patients Can’t Use Video: Audio-Only Rules

Not everyone has good internet or a smartphone with video. Some patients prefer phone calls for privacy reasons. CMS now allows audio-only calls to count as telehealth for patients at home.

Requirements for Audio-Only Billing

You can only bill phone-only visits when:

• You have video capability available
• The patient can’t use the video OR doesn’t want to use the video
• You document why the video wasn’t used

For Medicare patients, audio-only is mainly limited to mental health and substance abuse treatment right now. If you provide mental health counseling as part of your naturopathic practice, this might apply to you.

When you bill audio-only services, add modifier 93 to the E/M code. In your notes, write something like: “Provider had video available. The patient declined the video due to privacy concerns in the shared home.”

Quick Virtual Services: Check-Ins and Portal Messages

Besides regular telehealth visits, there are codes for shorter interactions.

Virtual Check-Ins (CPT 98016)

This code covers brief 5-10 minute conversations with established patients. The patient starts the contact; you don’t schedule it.

Rules for billing 98016:

• Patient must be established (you’ve seen them before)
• Patient initiates the contact
• Can’t be related to a visit in the last 7 days
• Can’t lead to a visit in the next 24 hours
• Can use phone or video

Patient Portal Messages (CPT 99421-99423)

These codes cover back-and-forth messages through your patient portal over 7 days:

• 99421: 5-10 minutes total time
• 99422: 11-20 minutes total time
• 99423: 21+ minutes total time

The patient starts the conversation by asking a question or raising a concern. You respond when you can. No real-time interaction needed.

Both virtual check-ins and portal messages need patient consent. You can get it before or during the service, but you must document it.

State Laws Make a Big Difference

The answer to which telehealth CPT codes are covered for naturopathic services depends heavily on where you practice.

States That Require Coverage

Some states have laws requiring insurance companies to cover naturopathic services:

• Vermont: State law specifically requires coverage for naturopathic physicians
• Alaska: Has coverage requirements for naturopathic doctors
• Connecticut: Mandates coverage for licensed naturopaths
• Montana: Requires insurers to cover naturopathic services
• Washington: Has strong coverage mandates and specific telehealth rules

These mandates usually apply to telehealth as well. But you still need to check with each insurance company.

What About Other States?

In states without coverage mandates, it’s hit-or-miss. Some insurance companies credential naturopathic physicians and pay for their services. Others don’t cover naturopathic care at all, no matter how it’s delivered.

This is why you must verify benefits before every visit.

Documentation That Prevents Denials

Your medical records need to be just as complete for telehealth as they are for in-person visits. Poor documentation is one of the top reasons claims get denied.

What to Include in Every Telehealth Note

Technology information:

• What platform did you use (Zoom, Doxy.me, phone, etc)
• Whether it was video or audio-only
• Where the patient was located
• Where were you located

Clinical documentation:

• Chief complaint (why they contacted you)
• History of present illness
• Review of systems
• Your assessment
• Treatment plan
• Medical decision-making complexity

Time documentation:

• Start and end times, OR
• Total time spent on the date of service
• What activities did you include (talking with the patient, reviewing labs, ordering tests, etc)

Extra Documentation for Audio-Only

If you did a phone-only visit, you need to explain why:

“Provider had video capability available through [platform name]. The patient declined video because [specific reason, no smartphone, privacy concern, internet issues, etc.].”

Without this documentation, the claim might get denied.

Common Billing Mistakes Naturopathic Doctors Make

Even experienced billers make errors with telehealth codes. Here are the most frequent problems.

Using the Wrong Place of Service

This is the number one mistake. Remember:

• POS 11 = in-person visits only
• POS 10 or 02 = telehealth visits only

If you put POS 11 on a telehealth claim, it will be rejected.

Billing the New Codes to Medicare

If you bill codes 98000-98007 to Medicare, you’ll get an automatic denial. Medicare doesn’t recognize these codes yet. Always use the traditional E/M codes for Medicare patients.

Missing Required Modifiers

Audio-only visits need modifier 93. Some insurance companies also require modifier 95 for telehealth, though Medicare no longer requires it. Check each payer’s requirements.

Not Verifying Coverage First

The most expensive mistake is billing insurance when you know they don’t cover naturopathic services. If your state doesn’t mandate coverage and the patient’s insurance doesn’t include you, tell the patient upfront and collect payment directly.

How to Get Paid What You Deserve

Many naturopathic physicians undercode their services. If you spend 45 minutes with an established patient managing diabetes, high blood pressure, and digestive issues, while reviewing lab results and creating a comprehensive treatment plan, that’s probably a 99215, not a 99213.

Time-Based Coding Works Well for Naturopathic Care

Naturopathic visits typically take longer than conventional medical appointments. You spend time on:

• Detailed health histories
• Lifestyle and diet counseling
• Explaining supplement protocols
• Discussing test results in depth
• Coordinating with other providers

All of this counts toward your total visit time. Document it and code for it.

Credentialing Is Essential

You can’t bill most insurance companies without being in their network. The credentialing process takes months, so start early.

Many private insurance companies credential naturopathic physicians, especially in states with licensing and coverage mandates. Medicare generally doesn’t credential naturopaths for routine care.

A Simple Workflow That Works

Here’s how to handle telehealth billing step by step.

Before the Visit

• Verify the patient’s insurance is active
• Check if naturopathic services are covered
• Confirm telehealth is a covered benefit
• Document this verification in the chart

During the Visit

• Note the technology platform you’re using
• Record the patient’s location
• Track your time (or note start/end times)
• Document all clinical information
• If audio-only, write down why the video wasn’t used

After the Visit

• Choose the right code based on complexity and time
• Use POS 02 or 10 (never 11)
• Add any required modifiers
• Link diagnosis codes that support medical necessity
• Submit the claim with complete documentation

If You Get a Denial

• Read the denial reason carefully
• Gather supporting documentation
• Write a clear appeal letter
• Submit before the deadline
• Follow up regularly

Many denials can be overturned with proper documentation or clarification.

Get Expert Help With Your Naturopathic Billing

Billing for telehealth as a naturopathic doctor can be confusing and time-consuming. Between choosing the right codes, documenting properly, and handling denials, it’s easy to lose revenue. At West Virginia Medical Billing, we specialize in naturopathic and integrative practices and know the unique challenges you face. We help with credentialing, eligibility checks, coding, documentation, and appeals, so you get paid correctly and stay compliant. Let us handle billing while you focus on patient care and growing your practice.

Frequently Asked Questions

Can naturopathic doctors bill Medicare for telehealth?

Generally, no, Medicare does not cover naturopathic services, in person or via telehealth. Always verify coverage; if not covered, obtain patient consent and collect payment directly.

What’s the difference between POS 02 and POS 10?

POS 10 is used when the patient is at home, and POS 02 is for patients at a healthcare facility. Using the wrong POS can lead to payment errors or claim denials.

Do I need special notes for audio-only visits?

Yes, you must document that the video was available but not used, and why. Add modifier 93 and include all details to avoid claim denials.

Which states require insurance to cover naturopathic services?

Vermont, Alaska, Connecticut, Montana, and Washington have laws supporting naturopathic coverage. Always check each patient’s plan, because coverage can vary by insurer.

Should I use the new 2025 codes or the old E/M codes?

It depends on the insurer, as Medicare still requires traditional E/M codes (99202-99215). When in doubt, use the old codes to ensure your claims are accepted.