Included in this article:
- Telehealth and Continuing Resolution – Nov, 2025
- Telehealth Codes for 2025
- Telehealth Update – March 19, 2025
- Place of Service Update from MLN Matters
- CPT® Changes in 2025
- CMS Telehealth FAQ Calendar Year 2025
Continuing resolution passed Nov. 2025
Congress passed a Continuing Resolution to keep the government open in November, 2025. The bill extended telehealth flexibilities that we have from the pandemic until January 30, 2026.
The flexibilities that are extended until January 30, 2026:
Geographic: The patient doesn’t need to be in an underserved area and can receive telehealth in their home.
Expanded eligible practitioners: Physical Therapists, Occupational Therapists, and Speech Language Pathologists can continue to perform services via telehealth.
FQHCs and RHCs: May continue to perform services including mental health services via telehealth.
In person requirement for mental health services: Delayed.
Audio only: Continues to be allowed if the practitioner has the capability for audio/visual real time communication but the patient does not or prefers not to use it. Use modifier 93 for audio only, modifier 95 for audio/visual.
GPCI floor: GPCI index floor of 1.00 extended.
Behavioral health
Behavioral health via two way, real time audio/visual communication and audio only communication is permanent, based on a law Congress passed in 2023 and isn’t effected by this, except for the delay in inperson requirement, listed below. For audio only services, the practitioner must have the capability for audio/visual but the patient either doesn’t or prefers to do audio only. Behavioral health telehealth services may continue to be billed by physicians, behavioral health practitioners and practitioners in RHCs and FQHCs. Why is behavioral health excepted?
CMS discusses the requirement for an inperson visit for audio only behavioral health.
- In-person behavioral health visit requirement. An in-person visit within six months of an initial Medicare behavioral/mental telehealth service, and annually thereafter, is not required through September 30, 2025. For FQHCs and RHCs, the in-person visit requirement for mental health services furnished via communication technology to beneficiaries in their homes is not required until January 1, 2026.
- The above quote notes the difference for RHCs and FQHCs, which aren’t required to have the in person visit within 6 months of initiating telehealth for behavioral health. This is not for established patients receiving behavioral health via telehealth; notice CMS says “of an initial Medicare behavioral/mental telehealth service.”
Still allowed are telehealth services that weren’t put into effect as a result of the pandemic, including home dialysis, acute stroke, substance use disorders in SUD programs.
CMS MLN Connects Newsletter_October 2025
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New telehealth codes for 2025 have an invalid status indicator from Medicare
- See the telemedicine section of CPT Coding Changes for 2025 for details.
- CPT® telephone codes 99441–99443 are deleted in the 2025 CPT book.
Telehealth Update – March 19, 2025
The “keep the government open” bill passed on March 14, 2025 extended telehealth flexibilities for another six months. (Why not nine months, I ask you?) The act is called “Full-Year Continuing Appropriations and Extensions Act, 2025” and Section 2207 describes Extension of Telehealth Flexibilities.
What are telehealth flexibilities? Five years ago, before the public health emergency, telehealth was only allowed for patients in geographically underserved areas provided to patients in an “originating” site, which was a health facility. For historical perspective, here’s quote from the January 2019 MLN Matters article telehealth required:
“An originating site is the location where a Medicare beneficiary gets physician or practitioner medical services through a telecommunications system. The beneficiary must go to the originating site for the services located in either:
- A county outside a Metropolitan Statistical Area (MSA)
- A rural Health Professional Shortage Area (HPSA) in a rural census tract”
After the declaration of the PHE, patients could receive telehealth services in their home in any place in the country.
Business as usual, per the ACT passed on 3/14/2025 and CMS FAQ posted 1/8/2025
Home still allowed: Medical practices can continue to provide telehealth to services in their home
Geography: Medical practices can continue to provide telehealth services to patients anywhere in the country
Use these POS codes:
POS 02 for Telehealth Provided Other than in Patient’s Home
POS 10 for Telehealth Provided in Patient’s Home (which is a location other than a hospital or other facility where the patient receives care in a private residence). CMS defines this broadly to include work, a hotel room, a car if the patient needs privacy. This will be paid at the non-facility rate (same as office).
Delay in in-person requirement for behavioral health:
The requirement for an in-person visit for behavioral health is delayed until October 1, 2025
PTs, OTs, SLP:
These practitioners may continue to provide telehealth services until October 1, 2025
Audio only services:
These are allowed for patients in their home if the practitioner has the capability for real-time, audio/visual telecommunication services but the patient does not.
CMS never got around to telling us exactly how to bill these now that the telephone only codes are deleted and Medicare isn’t recognizing the new CPT telehealth audio only codes. Office visits with modifier -93 seems accurate, but check with your MAC.
FQHCs and RHCs:
In the Final Rule, CMS said that these entities could continue to perform telehealth until Dec. 31, 2025. The Act says until the end of September, 2025.
Place of Service:
The MLN Matters article updated April 2024 (MLN901705) provides this information about POS:
“Professional billing
Starting January 1, 2024, use:
- POS 02: Telehealth Provided Other than in Patient’s Home
Descriptor: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
- POS 10: Telehealth Provided in Patient’s Home
Descriptor: The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.
Starting January 1, 2024, we pay for telehealth services you provide to patients in their homes at the non-facility PFS rate.”
CPT® Changes in 2025:
CPT® is adding 17 new CPT codes for audio only, audio/visual visits, in code range 98000–98016. These are divided into new and established patient visits and with either time or MDM definitions. The bad news: CMS assigned 16 of these an invalid status indicator. That means, CMS will not recognize or pay for the new CPT telehealth codes. One, 98016, would replace G2012 brief communications technology check in and CMS will accept that code and delete G2012 in 2025.
In the Final Rule released in November 2024, CMS again stated that it does not have the statutory authority to continue to allow telehealth using the flexibilities that were implemented during the pandemic. During the pandemic, CMS removed the requirement that the patient be located in an underserved area and that the patient go to a facility (originating site) to receive telehealth. Patients in all parts of the country could receive telehealth at home. CMS also added other therapists to the list of approved providers, including PT/OT, SLP, and audiologists. In plain English: patients may no longer receive telelehealth in their homes. Patients may only receive telehealth in a geographically underserved area.
Congress extended the flexibilities and telehealth continues to be allowed for patient’s at home, and may be provided by the professionals listed above until March 31, 2025.
The exception is behavioral health. For behavioral health, due to an act of Congress patients may continue to receive telehealth via real time audio/visual communication and audio only.
Citations:
[1] https://www.ssa.gov/OP_Home/ssact/title18/1834.htm
[2] While CMS waived the state licensure requirement for Medicare, they did not have the authority to waive broader state laws related to licensure.
[3] https://data.cms.gov/sites/default/files/2022-09/Medicare%20Telehealth%20Trends%20Snapshot%2020220906.pdf
[4] Please note that through December 31, 2024, this in-person visit is permitted to be conducted via telehealth.
[5] CMS has also added marriage and family therapists and mental health counselors to the list of eligible telehealth practitioners.
[6] As noted previously, the CAA of 2021 permanently eliminated geographic and location requirements for tele-behavioral health services subject to certain requirements and provided coverage for those services furnished by Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs).
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