CMS Telehealth 2025 Policy Changes: Navigating the New Landscape
CMS Telehealth 2025 Policy Changes: Navigating the New Landscape
As we approach 2025, healthcare providers must prepare for significant changes to Medicare telehealth services. The Centers for Medicare & Medicaid Services (CMS) has issued new regulations that will reshape telehealth coverage, marking a critical transition from the pandemic-era expansions.
Title II covers the Medicare-specific provisions and contains 10 sections. Most of the provisions extend the end date to either March 31, 2025, or April 1, 2025.
This legislation did not include in-home cardiology rehabilitation flexibilities, nor virtual diabetes prevention program suppliers in the Medicare Diabetes Prevention Program (MDPP).
Section 3207 discusses the extension of certain telehealth flexibilities through March 31, 2025, for professional reporting. A few of the flexibilities addressed include removing geographic requirements, expanding originating sites for telehealth services, and expanding practitioners eligible to furnish telehealth services.
Section 3208 discusses the extension of the Acute Hospital Care at Home initiative, which includes facility telehealth flexibilities to include the patient’s home or temporary residence.
Be sure to check with your local Medicare Administrative Contractors (MACs) for any additional guidance.
Key Rollback Provisions
Restrictions Returning
Initially, most telehealth services were going to revert to pre-pandemic limitations:
- Geographic restrictions reinstated
- Limitations on which practitioners can provide telehealth services will be reimposed
However, these limitations were addressed, and CMS removed the geographic restrictions and expanded the types of originating sites and practitioners who could perform telehealth services.
Expanded Telehealth Services
Despite the rollbacks, CMS is making some positive additions:
- Caregiver training services added (provisionally)
- Pre-Exposure Prophylaxis (PrEP) counseling permanently included
- Safety planning interventions permanently added to telehealth services
Understanding Geographic and Practitioner Restrictions
Geographic Restrictions: What Do They Mean?
Before the COVID-19 pandemic, Medicare telehealth services were heavily constrained by location requirements. These geographic restrictions essentially meant that:
- Patients must be located in a specific type of approved “originating site.”
- These sites typically included:
- Physician offices
- Hospitals
- Critical access hospitals
- Rural health clinics
- Federally qualified health centers
- Skilled nursing facilities
- Dialysis facilities
The key limitation was that patients could not receive telehealth services from their own homes in most circumstances, especially if they lived in urban or more densely populated areas. Rural patients had some exceptions, but these were still quite limited.
Practitioner Limitations
The rollback will reinstate strict rules about which healthcare professionals can provide telehealth services. During the pandemic, the list of eligible practitioners was significantly expanded. Now, the restrictions will return to pre-pandemic guidelines, which typically include:
- Physicians
- Physician assistants
- Nurse practitioners
- Clinical nurse specialists
- Certified registered nurse anesthetists
- Clinical psychologists
- Clinical social workers
- Registered dietitians or nutrition professionals
Some specialists and providers who were temporarily allowed to provide telehealth services during the pandemic will now be removed from the eligible list. This means some patients may need to return to in-person consultations or find alternative care providers who meet the Medicare telehealth criteria.
Key Expansions
Virtual Supervision Continues
CMS is maintaining some flexibility in professional supervision:
- Physicians can continue to provide virtual direct supervision through 2025
- Specific services can be supervised using real-time audio and visual telecommunications
- Teaching physicians can maintain virtual presence for resident-involved services through December 31, 2025
Audio-Only Telehealth Expanded
A notable provision allows audio-only telehealth when:
- The distant site physician can use interactive telecommunications
- The patient cannot or does not consent to video technology
- The service is provided in the patient’s home
Telehealth Originating Site Facility Fee
The facility fee for telehealth services will increase:
- 3.5% increase for 2025
- New payment rate of $31.01 for HCPCS code Q3014
Advocacy for Telehealth Expansion
In response to these restrictive changes, a significant coalition of healthcare and technology organizations has taken action. The Healthcare Information and Management Systems Society (HIMSS) and several other prominent associations have submitted a critical letter to Congressional leaders. This letter urgently requests the following:
- Extension of telehealth flexibilities for a full year or more
- Creating certainty in telehealth access for 2025
The coalition includes:
- Alliance for Connected Care
- American Telemedicine Association
- ATA Action
- Connected Health Initiative
- Consumer Technology Association
- Healthcare Information and Management Systems Society
- Health Innovation Alliance
- Partnership to Advance Virtual Care
Their core message emphasizes that enhanced telehealth access is a “lifeline to patients across the country.” The letter argues that the proposed restrictions could significantly impact patient care, especially for those in rural or underserved areas who rely on telehealth services.
Practical Implications for Healthcare Providers
Here are some actionable next steps for providers to ensure their telehealth services are in line with CMS’ new regulations:
- Reassess Telehealth Infrastructure: Review current telehealth programs to ensure compliance with 2025 regulations.
- Update Patient Communication: Inform patients about potential changes in telehealth service availability.
- Training and Adaptation: Prepare staff for returning geographic and practitioner restrictions.
- Technology Evaluation: Ensure telecommunications systems meet the new virtual supervision and communication requirements.
Staying Informed on the 2025 Telehealth Regulations
For the most up-to-date information, providers should:
- Regularly check CMS updates
- Contact MedicarePhysicianFeeSchedule@cms.hhs.gov for specific inquiries
- Review the complete list of telehealth codes at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
- Monitor the ongoing advocacy efforts to extend telehealth flexibilities
While the 2025 telehealth landscape looks different from the pandemic years, these changes demonstrate the ongoing dialogue between healthcare providers, technology advocates, and regulatory bodies.
Note: Always consult with your healthcare legal and compliance teams to ensure complete understanding and implementation of these regulations.
Does your organization need assistance navigating the new CMS telehealth policies and guidelines for 2025? Our consulting team provides comprehensive support to help healthcare providers understand and implement the latest telehealth regulations. Contact our Telehealth Policy Support Team for expert guidance on interpreting the new CMS telehealth coding system rules and implementation strategies.
