Upcoming Medicare Telehealth Changes: What You Need to Know

Recent confusion has spread on social media about Medicare’s telehealth coverage, with some falsely claiming that all coverage will end on April 1, 2025. While it is true that Medicare’s expanded telehealth waivers—put in place since March 2020—are set to expire on March 31, 2025, telehealth coverage will not disappear entirely. Additionally, there is a chance that Congress passes a bill to further extend the telehealth waivers before the March 31, 2025 deadline. In fact, the draft Continuing Resolution released on March 8 includes an extension of the telehealth flexibilities through September 30, 2025. 

However passage of the continuing resolution is not guaranteed so it is important for providers to be aware of the policy landscape they may face should the telehealth waivers not be extended. Without Congressional action to extend these waivers, stricter geographic and site restrictions will return, meaning only patients in rural areas and certain medical facilities will qualify for Medicare-covered telehealth. Additionally, while mental health telehealth services will continue beyond April 1, 2025, providers must meet new in-person visit requirements. Below is a breakdown of the key changes and what they mean for providers and patients, should the telehealth waivers expire, and the Medicare policies default to what is currently in permanent statute.

Key Points About Medicare Telehealth Changes Starting April 1, 2025 (assuming there is NO new legislation that extends or modifies the telehealth waivers):

• Medicare-specific restrictions: The upcoming changes only affect Medicare reimbursement. If Medicare is not the payer, these restrictions do not apply.
• Geographic and site restrictions: Beginning April 1, Medicare will only reimburse telehealth for patients in designated rural areas and certain medical facilities. To check if a location qualifies as rural, use the HRSA Medicare Telehealth Payment Eligibility Analyzer tool. Patients receiving telehealth at home will no longer be covered under standard Medicare rules. Certain exceptions from these site requirements do exist, including for mental health services (see last two bullet points).
• Distant site provider limitations: Certain professionals, including physical therapists, occupational therapists, speech-language pathologists, and audiologists, will no longer be able to bill Medicare for telehealth services.
• Hospital restrictions: Hospitals are not eligible distant site providers, and Medicare’s hospital-at-home allowances are expected to end.
• Mental health telehealth exceptions: Mental health services will remain covered for patients outside rural areas and medical facilities. However, providers must conduct an in-person visit within six months of the initial telehealth appointment and once every 12 months after that. An exception exists for the subsequent visit requirement if the patient and provider agree that an in-person visit’s risks and burdens outweigh the benefits.
• Special case exceptions: Some services will continue to be reimbursed under Medicare telehealth without the geographic/site restrictions, including:
• Substance use disorder treatment and co-occurring mental health conditions
• End-stage renal disease treatment
• Acute stroke care

While these restrictions could change if Congress passes an extension, providers and patients should prepare for the possibility that expanded Medicare telehealth coverage will narrow significantly starting April 1, 2025. 

Adding to the uncertainty of the current state of telehealth reimbursement, specifically for audio-only coverage, in November 2024, before Congress extended the Medicare telehealth waivers in December 2024, the Centers for Medicare and Medicaid Services (CMS) finalized its 2025 Physician Fee Schedule (PFS). While Congress allowed audio-only telehealth services to be reimbursed through March 31, 2025, CMS attempted to make some audio-only options permanent within their own authority—but with limitations. CMS updated the definition of “interactive telecommunication system” to allow audio-only telehealth in certain cases, but only when the patient is at home and the provider has video capabilities, but the patient cannot, or does not, consent to using video. This change expands some audio-only services but remains limited by existing Medicare rules (such as the geographic and site restrictions) discussed in the bullets above. Additionally, CMS removed codes 99441-99443, which some providers previously used, and did not clearly indicate which services could still be provided via audio-only (previously, there was a column in their eligible telehealth services list that specifically defined codes eligible for audio-only). When asked for clarification, CMS confirmed that providers could bill audio-only visits using codes 99202-99215 with appropriate modifiers (Modifier 93 for non-FQHC/RHC providers and Modifier FQ for FQHC/RHC providers). However, CMS did not clarify if other codes could be used for audio-only services.

Another point of contention is around what to expect in terms of reimbursement for federally qualified health centers (FQHCs) and rural health clinics (RHCs) once the waivers expire. In the 2025 PFS, CMS stated that FQHCs and RHCs could continue billing for non-behavioral health telehealth services using code G2025 through 2025. However, a CMS FAQ released in January 2025 suggests G2025 may only be billed by FQHCs and RHCs for non-behavioral health services until March 31, 2025, creating confusion around the actual timeline for payment and how billing guidance may shift beginning April 1, 2025.

Given the fast-changing information from CMS, providers should remain diligent in keeping abreast of potential changes to telehealth reimbursement policies. For more information regarding the mental health in-person visit requirements and permanent exceptions to the potentially returning geographic/site requirements, please review CCHP’s recent FAQ newsletter (dated Feb. 4, 2025). Please also stay tuned to CCHP newsletters for any updates before the March 31 deadline.

AI in Healthcare 2025: Trends, Adoption, and the Evolving Regulatory Landscape

As artificial intelligence (AI) continues to evolve, healthcare organizations are increasingly exploring its potential to enhance both clinical and administrative workflows. In an article published in January 2025 in HealthTech Magazine, the authors give an overview of 2025 AI trends they expect to see in healthcare over the coming year. The article suggests AI adoption will grow, with a focus on tools that deliver tangible value, such as ambient listening technology for clinical documentation and machine vision (adding cameras, sensors and microphones) for patient monitoring. Generative AI solutions (AI that creates new content such as images and text), particularly those utilizing retrieval-augmented generation (RAG), are gaining traction as organizations seek to use chatbots that can access an organization’s information more accurately than in the past. Additionally, the article emphasizes the importance of data governance and IT infrastructure so that they can understand its own data and make it easier for IT teams to know how a solution will work in the organization’s environment. While AI presents transformative opportunities, its successful implementation depends on balancing innovation with regulatory compliance and strategic investment in technologies that address real-world challenges in patient care and operational efficiency.

With increased adoption comes greater scrutiny, prompting a rise in AI-related regulations. The healthcare sector is already seeing regulatory developments such as the Office of the National Coordinator for Health Information Technology’s HTI-1 Final Rule, which governs health data and interoperability. Additionally, organizations are seeking guidance on AI governance to mitigate risks and ensure responsible use. These concerns have driven recent legislative efforts at both the federal and state levels to regulate AI in healthcare. Legislation we have already seen on the federal level include S. 501, which would require the Department of Health and Human Services to develop strategies to address AI-related public health threats, while H.R. 193 directs guidance on Medicare payments for AI-powered devices like continuous glucose monitors. State legislatures are also taking action. Examples include Connecticut’s SB 10 and Montana’s HB 556 ensuring AI cannot replace clinical judgment in insurance determinations, and Maryland’s HB 1240 prohibiting AI tools that prioritize cost savings over patient care quality. These measures reflect a growing push to balance AI’s potential benefits with safeguards that maintain ethical and patient-centered healthcare. For more information, read the full HealthTech Magazine article.

Telehealth’s Evolution in California: Progress, Challenges, and Opportunities

A recent report titled “Telehealth Evolution in California Progress, Challenges, and Opportunities” by the California Health Care Foundation (CHCF) highlights the transformative growth of telehealth services in California, particularly since the onset of the COVID-19 pandemic in 2020. Using a method which included a document and literature review as well as interviews with 27 individuals, the researchers found that average monthly telehealth visits surged during the pandemic and have remained significantly higher than pre-pandemic levels. Notably, audio-only consultations have become more prevalent than video visits, offering a critical solution for patients facing digital access challenges. CHCF attributes this expansion to policy reforms that removed location restrictions and established payment parity between telehealth and in-person services, thereby enhancing accessibility and consumer demand across the state’s healthcare system.

Despite these advancements, the study identifies persistent challenges, particularly within the Medi-Cal (California’s Medicaid) program. Providers encounter regulatory complexities, such as limitations on asynchronous care and stringent consent requirements, which can deter the adoption of telehealth services. Additionally, disparities in telehealth utilization persist among different demographic groups. For instance, Medi-Cal enrollees and individuals over 65 are less likely to use telehealth services compared to those with private insurance or younger age groups. To address these issues, CHCF recommends streamlining telehealth regulations, incentivizing the use of effective telehealth modalities like video visits and electronic consultations (eConsults), and implementing targeted strategies to bridge utilization gaps among underserved populations. For more information, read the full CHCF report.

Latest Developments in CCHP’s Telehealth Policy Finder and Policy Trend Map

CCHP’s Telehealth Policy Finder look-up tool and Policy Trend Maps were updated throughout the past month based on the latest information from our ongoing state telehealth policy tracking. The latest states to be updated include Arizona, Arkansas, Connecticut, Delaware, Florida, Illinois, Idaho, Indiana, Louisiana, Maine, Montana, New Mexico, North Dakota, Ohio, Rhode Island, and Wyoming.

Over the past month, multiple states made changes to their telehealth policies in an array of policy areas, including their Medicaid programs, professional regulations, and cross-state licensing. Highlighted changes from this group of states include:

• ARIZONA: The Arizona Health Care Cost Containment System (AHCCCS) updated their list of codes that are reimbursable in the Medicaid program to include the telehealth codes recently created by the American Medicaid Association (AMA), 98000-98106.
• ARKANSAS: The Arkansas Department of Human Services updated their Applied Behavioral Analysis (ABA) Therapy and Autism Waiver manuals to specify the types of services that can be delivered via telehealth. For autism, it specifies that an initial evaluation by an Interventionist may not be conducted through telemedicine and must be performed through traditional in-person methods. Additionally, in regards to ABA, the new manual update states that adaptive behavior treatment with protocol modification services and family adaptive behavior treatment services can be provided via telemedicine but all other applied behavioral analysis (ABA) services must be conducted in person. Parent/guardian consent is required for both ABA and Autism Waiver Services. See the aforementioned manuals for more details. Arkansas also adopted new rules for licensed counselors and marriage and family therapists related to the proper establishment of a client patient relationship. The new rules specify that a proper licensed counselor or marriage and family therapist/client relationship, at a minimum requires the licensed counselor or marriage and family therapist to perform an “in person” psychosocial assessment of the client adequate to establish a diagnosis and develop a treatment plan, OR the licensed counselor or marriage and family therapist performs a face-to-face psychosocial assessment using real time audio and visual telemedicine technology that provides information at least equal to such information as would have been obtained by an in-person psychosocial assessment, OR the licensed counselor or marriage and family therapist knows the client and the client’s general psychosocial issues through a previously established professional relationship; AND appropriate follow-up be provided or arranged, when necessary. See regulation for exceptions. 
• CONNECTICUT: The Connecticut Medical Assistance Program (CMAP) released a bulletin updating their CPT code list for services they will reimburse when delivered via telehealth effective January 2025, and confirmed they will continue to cover telehealth beyond 2024. The list also includes the new AMA audio only and telemedicine procedure codes. In a separate bulletin CMAP announced that they will reimburse for electronic consultations (eConsults) as well. CMAP also adjusted reimbursement rates and parameters of inpatient and outpatient hospital services, for border and out-of-state hospitals. Additionally, CMAP updated their Telehealth FAQs with information regarding the proper use of place of service codes and updated audio-only billing requirements.
• DELAWARE: Enacted Senate Bill 223 which integrates mobile-integrated healthcare and community paramedicine programs into existing regulatory structures by authorizing the establishment of mobile-integrated healthcare and community paramedicine programs through the Office of Emergency Medical Services in the Department of Health and Social Service’s Division of Public Health. Also, Delaware passed Senate Bill 331 which provides that out-of-state practitioners who wish to prescribe controlled substances in Delaware pursuant to a practice privilege, interstate compact license, telehealth registration, or military registration, must obtain a Delaware controlled substance registration. Finally, Senate Bill 301 was passed requiring public universities to provide access to medication for the termination of pregnancy and emergency contraception, or in the case they are not equipped for such a procedure, are able to refer to other providers, which may include telehealth providers.
• LOUISIANA: Adopted new regulations for Behavior Analysts that establishes practice standards for telehealth. They require that a licensee be licensed in Louisiana and must also be licensed in the state where the client is located, if licensing is required. It also requires that at the onset to telehealth the licensee must obtain written informed consent and document the consent in the client’s record. See regulation for provisions required in the informed consent.
• MAINE

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