CMS Telehealth Update (3/14/25)
On March 14, 2025, the Continuing Resolution (CR) approved significant extensions for telehealth flexibilities and reimbursement policies that were set to expire on March 31, 2025. This Continuing Resolution (CR) allows for the Extension of telehealth waivers and the hospital-at-home program through September 30, 2025. This provision will allow telehealth services to allow for the pandemic-era telehealth flexibilities that were set to expire on March 31, 2025, to continue until September 30, 2025.
The Continuing Resolution may be found at:
The provision for the extension of telehealth is in Section 2207. Some of the Provisions that are included in the bill are:
Geographic and Originating Site Restrictions
This provision extends the waiver of geographic requirements and expands originating sites for telehealth services until September 30, 2025. This means that for Medicare a patient may continue to receive telehealth services regardless of their location and are not restricted to designated healthcare facilities
Expanded Practitioner Eligibility
This expands the list of practitioners eligible to furnish telehealth services through September 30, 2025.
FQHC and RHC Telehealth Services
This provision extends telehealth services for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) that rely on these facilities for healthcare access.
Mental Health Services
Several provisions specifically address telehealth for mental health services which includes postponing the requirement for a face-to-face visit before mental health services can be provided. This provision also continues to allow FQHCs and RHCs to provide mental health services via telehealth.
Audio-Only Telehealth Services
These services have been extended until September 30, 2025. However, with the deletion of CPT codes 99441-99443 practitioners will use CPT codes 99202-99215 when reporting audio-only telehealth services. This is beneficial for patients without access to video, access with limited broadband and patients who may struggle with technology. Medicare does not recognize the CPT codes 98000-98015 for telehealth services. This will remain the case until CMS, under the Medicare Physician Fee Schedule, removes the status (non-covered) indicator tied to the new CPT telehealth codes (98000-98015). For audio-only CMS requires either modifier “93” and/or Medicare modifier “FQ” for Federally Qualified Health Centers and Rural Health Clinics.
Place of Service Codes
There are two place of service codes that should be used for Telehealth Services
POS 02: Telehealth provided in other than the patient’s home
POS 10: Telehealth is provided in the patient’s home.
There are currently more than 250 codes on the Medicare telehealth services list that are eligible for reimbursement. These codes can be accessed at:
https://www.cms.gov/medicare/coverage/telehealth/list-services
Note: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunication System no longer requires Modifier 95 for Medicare.
What does this mean for Healthcare Practitioners?
Medicare reimbursement for telehealth services will continue until September 30, 2025
Flexibility in practitioner eligibility is maintained
Continued ability to serve patients remotely using audio/visual or audio-only technology
Reduced administrative burden with delayed in-person visit requirements for mental health
KZA recommends reviewing commercial payor policies on the appropriate reporting of the AMA-updated CPT codes 98008-98016.