Understanding Medicare Telehealth Policy

  • The Center for Connected Health Policy (CCHP) has created this video primer explaining how Medicare policy gets created, who has authority to make changes and the difference between "telehealth" and "communications technology based services (CTBS)".

Essential Billing Resources:

Additional Billing Resources

  • California Telehealth Resource Center:  Digital Health Services Payment Guide (covers eConsults, RPM, RTM, Asychronous Store-and-Forward, AI-enabled modalities and HIPAA-compliant texting)

Medicare Telehealth Flexibilities and Public Health Emergency (PHE) Waivers

During the COVID-19 Public Health Emergency (PHE), CMS implemented temporary waivers to expand telehealth access.  While some waivers expired with the PHE's end on May 11, 2023, others were extended or made permandent.

In March 2025, Congress extended key Medicare telehealth flexibilities until September 30, 2025, including:

  • Patient Location. Medicare patients may continue to receive telehealth services with no geographic or site restrictions, including while they are in their home.
  • Eligible Providers. All Medicare-eligible providers (e.g., OTs, PTs, SLPs) may continue to deliver telehealth. Additionally, FQHCs and RHCs may continue to serve as distant site providers for telehealth.
  • Audio-Only Services.  Medicare will continue to allow audio-only telehealth for non-behavioral/mental health services when the patient is at home and video is not feasible or consented to.
  • Behavioral Health In-Person Visit Requirement.  Medicare will continue to put on hold the implementation of the requirement of in-person visit within six months (the prior 6 months) of an initial behavioral/mental telehealth services and annually thereafter. The requirement for FQHCs/RHCs has been postponed until January 1, 2026.
  • Hospice Recertification: Medicare will continue to allow telehealth to be used to conduct face-to-face recertification for beneficiaries eligible for hospice care.
  • Hospital at Home Program Model:  Medicare will continue to allow this program model to be an eligible service, thus permitting acute care delivery in patients' homes..

What Happens After September 30, 2025? 

Since Congress has not yet extended or made these flexibilities permanent, significant changes are now in effect.  Read more about the impact of the cliff on:

To prepare for these changes, the Telehealth Resource Centers (TRCs) have put together a series providing insights and contingency planning tips for the waivers that expired on September 30, 2025.

Resources during this period where the waivers have expired:

  • To determine if an eligible facility is located within an eligible geographic area, use the Medicare Telehealth Payment Eligibility Analyzer
  • If you elect to continue to provide telehealth services, the recommendation is to hold claims for telehealth services that depend on the flexibilities until coverage is formally reinstated. While most people anticipate that coverage will be applied retroactively, there is no absolute guarantee of that outcome. We also acknowledge that some smaller practices may not have the financial capacity to delay claim submission for an extended period, so each practice will need to weigh the risks and benefits carefully.
    • CMS has directed all Medicare Administrative Contractors (MACs) to implement a temporary claims hold for up to 10 business days to avoid having to reprocess large volumes of claims should Congress act after the statutory expiration date.  Read more here:

 

 

 

 

 

 

 

 

How Will This Impact FQHCs and RHCs?

For FQHCs and RHCs, the March 31 end date conflicts with the 2025 PFS, in which the CMS noted that they will allow FQHCs and RHCs to continue to use telehealth to provide non-mental health services and be reimbursed through 2025.  Additionally, in the 2025 PFS, CMS delayed the in-person visit requirements for mental health services furnished via communication technology by RHCs and FQHCs to beneficiaries in their homes until January 1, 2026.)

So which end date do we follow?  CMS issued the following update on March 20: Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update that explicitly provides the following clarifications:

“RHCs and FQHCs can continue to provide on a temporary basis, for non-behavioral health visits furnished via telecommunication technology under the methodology that has been in place for these services during and after the COVID-19 PHE through December 31, 2024. Specifically, RHCs and FQHCs can continue to bill for RHC and FQHC services furnished using telecommunication technology by reporting HCPCS code G2025 on the claim, including services furnished using audio-only communications technology through December 31, 2025. For payment for non-behavioral health visits furnished via telecommunication technology in CY 2025, the payment amount is based on the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS.”

“Beginning January 1, 2026, there must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an inperson mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12- month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.”.

Acute Hospital at Home Waiver Program: Launched in November 2020, this waiver program was created to address hospital bed shortages by allowing hospital-level care in patients' homes. As of March 1, 2024, 315 hospitals across 131 health systems in 37 states participate.  Visit the Hospital at Home Users Group Website to learn more!

In addition, view past MATRC Summit sessions to learn more:

The Acute Hospital Care at Home Waiver expired on September 30, 2025.  Click Here to Learn More

Frequently Asked Questions

  • Do Medicare Advantage plans cover telehealth services?   Yes.  Coverage varies by plan and may include services beyond what is covered under Medicare Fee-For-Services (FFS).  Check with your plan provider for details as the types of services offered are contingent upon each plan's contractual agreement.  Additionally, some Accountable Care Organizations (ACOs) may offer telehealth services that allow primary care doctors to care for patients without an in-person visit, no matter where they live. If your health care provider participates in an ACO, check with them to see what telehealth services may be available.
  • Are Accountable Care Organizations able to provide telehealth services?  Yes, in fact, CMS has provided expanded telehealth flexibilities for ACOs, removing geographic limitations imposed under normal FFS Medicare rules and allowing beneficiaries to receive many telehealth services from their home. Click Here to Learn More
  • Can I still be reimbursed for audio-only services? 
    • Behavioral/mental telehealth services:  May be delivered using audio-only communication platforms, though some of these services may be subject to in-person visit requirements once the PHE waivers expire.
    • For all other (non-behavioral/mental health) telehealth services:
      • The 2025 Physician Fee Schedule permanently changed the regulatory definition of an interactive telecommunications system to include audio-only for delivery of any telehealth service. However, in order to be able to use audio-only certain conditions must be met. Those conditions are:
        • The patient is in their home during the audio-only interaction (this would no longer be allowable should the PHE waivers expire) and
        • The distant site provider must be technically capable of using live video, but the patient isn’t capable or does not wish to use live video.
      • For these services:
        • Billing codes 99441-99443 have been eliminated for 2025.
        • Codes 99202-99215 should be used with the following modifiers to signify that the service was provided via audio-only:
          • Modifier 93 for non-FQHC/RHC distant site providers
          • Modifier FQ when the service is provided by an FQHC/RHC