The American Relief Act of 2025 has brought critical updates to Medicare telehealth policies, reinforcing telemedicine as a viable healthcare solution. With the dust now settled, let’s revisit the changes to Medicare telehealth policies and examine what lies ahead.
Key Telehealth Policies Extended Through 2025
The Centers for Medicare & Medicaid Services (CMS) has maintained several telehealth provisions from 2024 through December 31, 2025. These include:
- Place of Service (POS) Options:
- POS 02: Patient not in their home.
- POS 10: Patient in their home, reimbursed at the non-facility rate.
- Provider Address Flexibility: Physicians can list their practice address when delivering telehealth services from home.
- Supervision via Telehealth: Certain services can continue to be supervised remotely using real-time audio-visual communication, with limitations for direct supervision ending December 31, 2025.
- U.S.-Based Service Requirement: Both patients and providers must be located within the U.S. or its territories during telehealth service delivery.
- Frequency Limits Suspended: Restrictions on subsequent inpatient and facility visits and critical care consultations remain lifted through the end of 2025.
- Teaching Physicians: Virtual presence remains allowed for billing services provided by residents in specific teaching settings through December 31, 2025.
New Medicare Telehealth Services in 2025
CMS has expanded the Medicare Telehealth Services List to include:
- Caregiver training services.
- Pre-exposure prophylaxis (PrEP) counseling and safety planning interventions.
Audio-Only Services: Current Guidance
CMS has acknowledged the need for audio-only services under certain circumstances, such as limited broadband access, lack of technical proficiency, or privacy concerns. For 2025, Medicare telehealth policies permit audio-only telehealth services if:
- The provider can offer audio-video telehealth but the patient cannot or opts out of video use.
- Modifier 93 (or FQ for rural and federally qualified health centers) is used on claims to indicate compliance.
The CMS Medicare Telehealth Services List specifies which CPT® and HCPCS Level II codes are reimbursable for audio-only services under the Medicare Physician Fee Schedule (MPFS).
Potential Congressional Impacts on Telehealth
Unless Congress acts by March 31, 2025, statutory limitations will return on April 1, including:
- Geographic Restrictions: Limits based on patient location.
- Location Restrictions: Limits on service delivery settings.
- Scope of Practice Restrictions: Limitations on eligible services.
These changes would not apply to end-stage renal disease assessments or behavioral health services, which are already covered under permanent policies finalized in the CY 2025 MPFS.
A Changing Landscape for Telehealth
The new administration, with HHS Secretary and CMS Director, may bring significant changes to telehealth policy and reimbursement. Stakeholders are advised to monitor developments closely to stay informed about potential shifts in telehealth regulations.
Telemedicine remains a cornerstone of accessible healthcare, but its future will depend heavily on legislative and administrative actions, particularly updates to Medicare telehealth policies. Stay updated to ensure compliance and maximize the benefits of telehealth for your practice.
How Useful Are Medicare Telehealth Policies in Revenue Cycle Management (RCM) Companies?
Medicare telehealth policies play a crucial role in optimizing Revenue Cycle Management (RCM) processes for healthcare organizations. By expanding telehealth coverage and streamlining reimbursement processes, these policies help RCM companies adapt to the evolving needs of healthcare providers and patients.
The American Relief Act of 2025 introduced significant changes to Medicare telehealth policies, including extended payment parity for audio and video consultations and increased flexibility for remote patient monitoring. These updates enable RCM companies to help providers capture revenue more effectively while maintaining compliance with Medicare regulations.
One key benefit is the reduction of claim denials. With clear guidelines on Place of Service (POS) codes (e.g., POS 02 for patients outside their home and POS 10 for those at home), RCM companies ensure accurate coding and billing, which minimizes errors and enhances reimbursement rates.
Additionally, these policies promote healthcare access in underserved areas, increasing the volume of telehealth services. RCM companies leverage this demand by integrating advanced technology like AI to manage claims and ensure quicker payments.
In summary, Medicare telehealth policies empower RCM companies to enhance operational efficiency, improve cash flow, and support providers in delivering accessible, quality care.