I provided the NAMAS links, but I do agree that from CMS directly is the best reference. NAMAS is a reputable company in my opinion, but anyone can make an error. I was able to find
this from CMS regarding post PHE which was updated 7/20/2023. Specifically at the bottom of page 8:
When clinicians have furnished an evaluation and management (E/M) service that otherwise would have been reported as an in-person or telehealth visit, using audio-only technology, practitioners have been able to bill using these telephone E/M codes provided that it is appropriate to furnish the service using audio-only technology and all of the required elements in the applicable telephone E/M code (99441-99443) description are met.
Since the descriptor of 99441-99443 states established patient, I interpret a new patient would not meet "all of the required elements".