Introduction
The Centers for Medicare & Medicaid Services (CMS) has released the 2025 Medicare Telehealth Changes. Released on November 1, 2024, the 2025 Medicare Telehealth Changes are part of the Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule and include pivotal updates to telehealth policies, aiming to address the impending expiration of temporary waivers while laying the groundwork for future flexibility. These changes directly impact how healthcare providers deliver services and manage billing in a rapidly evolving regulatory environment.
Detailed Overview of Key Updates
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Audio-Only Services Now Permanent
CMS has updated the definition of an “interactive telecommunication system” to include audio-only communication for telehealth services. This ensures providers can offer telehealth services even if patients lack access to video technology. Key details include:
- Audio-only is allowed when video capability isn’t feasible for the patient.
- This change primarily benefits mental health and substance use disorder treatments, alongside monthly ESRD-related clinical assessments.
- Practitioners must use specific modifiers, such as “93” or “FQ”, for billing.
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Eligible Telehealth Services: Code Updates
CMS evaluated proposed service codes for the telehealth eligible services list, maintaining provisional status for several codes and adding new ones. Highlights include:
- Provisional Codes:
- Caregiver training codes (97550, 97552, 96202) for facilitating home-based patient care.
- Behavioral management codes for group sessions and caregiver education.
- Permanent Codes:
- Pre-exposure prophylaxis (PrEP) counseling for HIV prevention, designated as G0011 and G0013.
- Safety planning interventions for mental health crises (G0560).
CMS plans to conduct a comprehensive review to determine the permanency of additional provisional codes in the future.
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Flexibilities for FQHCs and RHCs
To ensure continuity of care, FQHCs and RHCs can provide non-mental health services via telehealth through 2025 using the code G2025. This policy supports rural and underserved areas where access to in-person care may be limited.
Additionally:
- CMS delayed the in-person visit requirement for mental health services until January 1, 2026, acknowledging the ongoing reliance on telecommunication technology.
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Extended Direct Supervision via Video
Through December 31, 2025, CMS will allow the use of live video for direct supervision requirements in specific cases, such as:
- Teaching physicians supervising residents.
- Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) using video to meet the “immediately available” supervision standard.
This extension ensures continuity in training and care delivery.
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Addressing Expiring Waivers
The final rule extends key COVID-era waivers, such as:
- Frequency limits for inpatient, nursing facility, and critical care consultations (codes 99231–99310 and G0508–G0509).
- CMS clarified that telehealth services billed under POS 10 (home telehealth) will continue to be reimbursed at the non-facility rate.
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Impacts on Opioid Treatment Programs (OTPs)
CMS aligned its policies with SAMHSA regulations, allowing periodic assessments via audio-only when video isn’t available. The OTP intake add-on code (G2076) for methadone treatment can also be furnished using live video.
Takeaway The 2025 Medicare Physician Fee Schedule demonstrates CMS’s commitment to preserving access to telehealth while balancing regulatory limits. Providers must adapt to these changes to continue offering compliant and efficient care.