We recently noticed this change during the inclement weather in Dallas, when many of our clients performed telehealth visits. As a billing service provider, we think it might help our clients to understand this latest CMS document without having to spend at least 2 hours to read it. Most importantly to answer the questions:
- Can we offer Telehealth visits to Medicare patients as of January 1st 2025?
- If so, do we have to do anything differently, for providers, schedulers and billers, now to get Medicare payment for Telehealth visits?
2024 CMS Changes and Their Impact on Medical Billing
Medicare’s telehealth policy changed for 2025. Key temporary expansions from the American Relief Act of 2025, such as relaxed geographic restrictions and broadened provider eligibility, are set to expire on March 31st, 2025, potentially reverting to pre-pandemic limitations unless Congress acts. This matter is urgent as after this date, pre-pandemic restrictions may be reinstated, and 85% of telehealth visits may not be covered.
The CMS document clarifies billing procedures, specifying the use of existing Evaluation and Management (E/M) codes with modifiers for audio-video and audio-only visits, and the rejection of newly proposed CPT codes (98000-98015) except for 98016. Furthermore, it outlines updates to originating site facility fees, supervision requirements for therapy assistants, and newly covered telehealth services, including caregiver training and PrEP counseling. Finally, it highlights the significant potential impact of reinstating pre-pandemic geographic restrictions on telehealth coverage.
What are the key changes to Medicare telehealth policies in 2025?
The American Relief Act of 2025 extends several key Medicare telehealth policies through March 31, 2025, including the removal of geographic restrictions, broadened telehealth eligibility for practitioners, continued telehealth services for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), delayed in-person requirements for mental health services, and the Acute Care Hospital at Home program. However, after March 31st, pre-pandemic restrictions may be reinstated if Congress does not act.
Does this mean the end of Telehealth visit?
No, the document does not mean that telehealth visits cannot be done anymore, but it does indicate significant changes to how telehealth services are covered and coded under Medicare in 2025.
Telehealth is still allowed, but with modifications: The sources confirm that telehealth services will continue to be available, but there are changes in the rules governing how these services are provided and reimbursed. The American Relief Act of 2025 extends key telehealth policies through March 31, 2025, indicating continued support for telehealth services.
Here’s a breakdown of main changes:
- Geographic Restrictions Reinstated: One of the most significant changes is the reinstatement of pre-pandemic geographic restrictions. Unless Congress intervenes, after March 31st, telehealth coverage will likely be limited to patients in specific locations, such as health professional shortage areas, rural census tracts, or counties outside of metropolitan statistical areas. This means that if a patient does not meet these criteria, their telehealth visit may not be covered.
- Coding and Billing Changes: The way telehealth visits are coded and billed is changing. CMS will not adopt most of the new CPT telemedicine codes (98000-98015), but instead requires the use of in-person Evaluation and Management (E/M) codes (e.g., 99202-99215) with specific modifiers, such as Modifier 95 for audio-video visits and Modifier 93 for audio-only visits.
- Audio-Only Visits: While audio-visual technology is expected, audio-only visits are allowed when patients lack video capability or decline its use. These visits must exceed 10 minutes and be properly documented. To clarify this “10 minute”, it should be included in the documentation. Note that CMS expects audio-visual technology to be used, unless the patient lacks the capability or declines its use. Modifier 93 should be appended for audio-only services
- Specific Services Expanded: Certain services, such as caregiver training services, Pre-Exposure Prophylaxis (PrEP) counseling, and safety planning interventions, are being added to the Medicare Telehealth Services List. There are also new codes for digital mental health treatment devices and advanced primary care management services.
Telehealth services are not ending, but the rules are becoming more restrictive, particularly regarding geographic limitations. Providers will need to adapt to the new coding and billing guidelines and ensure they are following the updated regulations. The changes emphasize that telehealth will continue to play a role in healthcare, but it may not be as universally accessible as it was during the public health emergency. It’s important for providers to stay updated on any Congressional actions that might impact these policies, and for patients to understand that they may not be eligible for telehealth services based on their location.
We have included the direct link to the CMS Telehealth Services List for easy reference: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
Here is the caveat: As of 1/17/2025, the CMS website haven’t updated any of their information as it pertains to the American Relief Act President Biden signed on 12/21/24. (The above link is part of this document). We will keep on checking the CMS website for any potential updates pertaining to telehealth services and provide an update around the current deadline of 3/31/2025. (Set yourself a reminder to come to revisit us again).
If you have further questions on this new change, please contact us through the website(or email us at contact@solutions4billing.com) for customized consultation on its impact on your practice and training your team need to avoid loss of reimbursements.