Telemedicine – Back to Pre-COVID Requirements
Last night, the government officially shut down. What does that mean for telehealth? It means that the extended waivers through September 30, 2025, have now officially expired.
CMS responded this morning.
“Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown
When certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements.
The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact on providers due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.”
Things that changed overnight:
- Geographic Restrictions Reinstated
- Telehealth is now only covered for patients in rural areas.
- Patients in urban or suburban settings must travel to an approved originating site (e.g., clinic, hospital) to receive covered telehealth services.
- Home as an originating site is no longer covered
- Medicare will no longer reimburse most telehealth services delivered to patients in their homes, except for certain behavioral health, ESRD-related services, and mobile stroke care.
- Payment
- (POS 02) Reimbursement rate will be at the facility rate when the patient is anywhere but their home.
- (POS 1o) Reimbursement rate will be at the non-facility rate when the patient is in their home (Behavioral or ESRD-related services)
- Severely limited audio-only telehealth
- Audio-only visits will only be reimbursed for specific behavioral health services, and only if the patient cannot use or declines video technology.
- In-Person Visit Requirements for Mental Health
- Patients must have had an in-person visit within 6 months before initiating tele-mental health care, and annually thereafter.
- Hospital-at-Home Program Ends
- The Acute Hospital Care at Home waiver will expire, disrupting care models that rely on remote monitoring and home-based acute care.
- Licensure Waivers Expire
- Providers must comply with state-specific licensure laws for telehealth. Temporary cross-state licensure waivers will end, requiring multistate licensure or participation in the Interstate Medical Licensure Compact (IMLC).
- Loss of Eligibility (Providers)
- Occupational therapists
- Physical therapists
- Speech-language pathologists
- Audiologists
What Remains Covered
Some telehealth services continue to be covered under Medicare:
- Mental and behavioral health services, including substance use disorder treatment.
- Audio-only behavioral health visits.
- Telehealth services from Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) for behavioral health.
- Certain ESRD and stroke-related services.
Here are a few things you may consider getting you through the next two weeks. Reschedule if you can to in-person visits. If the patient wants telehealth from home, you can always use an ABN.
Lastly, there are still some COVID-era waivers in place until December 1, 2025. Let’s hope they get this figured out before then.
RESOURCES:
Latest CCHP Telehealth FAQ (while we WAIT!) FAQs-Medicare-Telehealth-Flexibility-End-FINAL.pdf
TMA: Pre-PHE Telehealth Requirements
CMS: Pre-PHE Waivers