It is important for the health care providers, beneficiaries, and stakeholders to be aware of Medicare’s shifting telehealth policy landscape as we move through Calendar Year (CY) 2025. The COVID-19 pandemic has hastened the uptake of telehealth services and has brought some changes that have contributed to temporary broadening of the access and coverage for telehealth policies. Many of these provisions will soon end, making it quite urgent to take proactive measures to ensure access to telehealth services post CYC 2025.
Upcoming Key Changes in Medicare Telehealth Policies
1. Expiring Temporary Waivers:
A bunch of telehealth flexibilities that were brought into place during the pandemic are going to expire on March 31, 2025. They include:
o Geographic and Location Restrictions: Currently, a Medicare beneficiary can access telehealth services from anywhere in the world, including his or her home. After this date of March 31st, 2025, patients will need to be located in an office of a medical facility situated in a rural area for most telehealth services to be applicable.
Medicare
Provider eligibility: As a general rule, all eligible Medicare providers can offer telehealth services up until March 31st, 2025. After this date, some of the provider flexibilities may change, affecting the delivery of telehealth services.
Audio-Only Services: Allowance for the delivery of audio-only, non-behavioral/mental telehealth services will terminate on March 31, 2025.
2. Behavioral and Mental Health Services: Several flexibilities for behavioral and mental health telehealth services were extended beyond March 31, 2025:
In-Person Visit Requirements: The requirement of an in-person visit within six months of the first behavioral or mental therapy via telehealth and annually thereafter is waived until March 31, 2025. For FQHC/RHC services, this requirement is extended to January 1, 2026.
telehealth.hhs.gov
Service Delivery: Medicare patients will always receive behavioral/mental health telehealth services at their residences, without any geographic restrictions for access. In addition, it can also be provided through audio-only communication systems.
With the aforementioned expected changes in policy, there will be a direct effect on the mode in which telehealth services can be accessed and delivered.
• Access Restrictions: After March 31, 2025, patients in non-rural areas will have even less access to telehealth services for all non-behavioral health reasons.
• Provider Modifications: Healthcare providers may need to adjust their practices to the re-established geographic and location restrictions to which telehealth services may be subject.
• Mode of Service Delivery: The blocking of audio-only telehealth for other areas than behavioral health is expected to affect such patients who do not have access to devices with video conferencing capabilities or good internet.
Call to Action
In preparation for the impending changes, it is incumbent upon you to do the following:
1. Keep Yourself Updated:
Keep on reading; CMS and HHS are prime sources for anything regarding telehealth policies.
2. Support Policy Extension Efforts:
Together with professional organizations and advocacy groups, consider joining in support of legislative efforts to extend or make permanent those telehealth flexibilities that have served well during the pandemic.
3. Patient Education:
Share with your patients the upcoming changes and the potential consequences regarding their access to telehealth services. If applicable, provide them with information about other care alternatives.
4. Assess Technical Capabilities:
Your practice should be ready with all the technology that may be required to meet the newest telehealth requirements, especially with respect to audio-only services that may no longer be allowable for certain consultations.
5. Integrate Other Care Models:
Consider a mixed approach for all new care agreements that offer both in-person and telehealth services as options for dealing with variable patient needs and preferences.
By taking proactive steps, some degree of accessibility to and efficiency of care can continue through these changes by providers, with minimal disturbance to patients.
