2025 telehealth flexibilities and policy updates
Although the COVID-19 Public Health Emergency (PHE) officially ended on May 11, 2023, the Consolidated Appropriations Act (CAA) of 2023 extended many telehealth flexibilities and waivers through Dec. 31, 2024. Furthermore, the 2025 Medicare Physician Fee Schedule (MPFS) affirmed that CMS will continue to permit certain policy adjustments and extensions related to telehealth services through 2025. Please see below for the telehealth updates.
Telehealth flexibilities extended through 2025
Medicare enrollment address
CMS will continue to allow clinicians providing telehealth services from home to list their practice address instead of their home address on their Medicare enrollment through 2025.
Teaching physicians
CMS will continue to allow teaching physicians to use real-time audiovisual telecommunications when the resident furnishes Medicare telehealth services in all residency training locations through the end of 2025; the teaching physician and resident do not have to be co-located.
Virtual direct supervision
In a permanent change, CMS will allow virtual direct supervision for a subset of services. Specifically, a supervising clinician may use real-time audiovisual telecommunications, for services furnished “incident to” a dermatologist’s or non-physician clinician’s (NPC) professional services. This policy includes services with a PC/TC indicator of “5” (e.g., 96900-96912) and the service described by CPT® code 99211, as well as other office or outpatient E/M visits for established patients who may not require the dermatologist’s or NPC’s physical presence.
For all other services provided “incident to” that require direct supervision, CMS will only allow use of real-time audiovisual telecommunications through Dec. 31, 2025.
Audio-only telehealth
Starting in 2025, CMS finalized that the definition of “interactive telecommunications system” will include two-way, real-time, audio-only communication for telehealth services. This applies when the dermatologist or NPC located at the distant location has the capability to use video technology, but the patient is either unable or does not consent to video technology. CMS clarified that no additional documentation, other than the appropriate modifier, is required for audio-only services.
Note, these telehealth flexibilities do not apply to private payers. We encourage practices to check with private payers before providing the service to ensure appropriate reimbursement expectations.
Telehealth flexibilities through March 31
Geographic and location restrictions
The telehealth flexibilities on geographic and location restrictions were set to expire at the end of 2024 but have been extended by Congress. These waivers will remain in effect only until March 31, 2025. After that, without further congressional action, telehealth services will generally be limited to Medicare beneficiaries in rural areas and specific medical settings, with most patients no longer able to receive telehealth services from home.
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