Telehealth Policies for 2025
Let’s begin by summarizing the key updates to telehealth policies introduced in the 2025 Physician Fee Schedule (PFS) final rule:
- CPT® Code Updates: The CPT® Editorial Panel has decided to eliminate audio-only telephone service codes 99441-99443 in 2025. However, Medicare will not adopt 16 of the 17 new telehealth CPT® codes (98000-98016) for reimbursement. Specifically, codes 98000-98015 will have an “Invalid” status under Medicare. Only CPT® code 98016 will be reimbursed as a substitute for HCPCS Level II code G2012, which has been removed due to duplication.
- Supervision Requirements: Real-time audio-visual telecommunications (excluding audio-only) will remain acceptable for services requiring direct supervision.
- Behavioral and Mental Health Services: Starting January 1, 2025, certain behavioral and mental health services will be permanently available via telehealth for Medicare beneficiaries. Updated details will be included in CMS’s Telehealth Services List once released.
- Place of Service (POS) Codes: The following POS designations for telehealth will remain in effect:
- 02: When the patient is located outside their home.
- 10: When the patient is in their home during the telehealth service. POS 10 will continue to receive reimbursement at the non-facility rate.
- Practice Address Policy: Physicians can continue using their practice address, rather than their home address, when delivering telehealth services from home for Medicare patients.
- Geographic Restrictions: Pre-pandemic location and geographic limitations are being reinstated. Telehealth services will not be reimbursed unless the Medicare patient is located in a rural census tract, a county outside a metropolitan statistical area, or a designated health professional shortage area during the service.
- Teaching Physician Flexibility: Teaching physicians may maintain a virtual presence for telehealth services across all teaching settings through December 31, 2025. However, this policy applies exclusively to Medicare telehealth services.
For additional details, CMS resources will provide updated references once available.
Congressional Impact on Telehealth Policies
While the current rules are set to take effect in 2025, Congress has the opportunity to address the geographic location restrictions before the end of 2024. If no action is taken, over 85% of telehealth visits for Medicare beneficiaries could become ineligible for reimbursement starting January 1, 2025.
The Telehealth Modernization Act of 2024 remains stalled in Committee as of September 18, 2024. Without movement on this legislation, both Medicare patients and healthcare providers face uncertainty regarding telehealth coverage for the upcoming year. I strongly encourage you to contact your local representatives to advocate for action on this issue.