As of October 1, 2025, many pandemic-era Medicare telehealth flexibilities have expired unless Congress acts. This means pre-PHE restrictions such as geographic/originating site limits, provider types, and some audio-only allowances are now back in effect.
- Many pandemic-era Medicare telehealth flexibilities extended through 9/30/2025 have lapsed as of 10/1/2025 unless Congress acts. That means the statutory limits that applied before the PHE are largely back in effect for most Medicare telehealth services (geographic/originating site limits, provider types, location rules, some audio-only allowances, etc.). Centers for Medicare & Medicaid Services+1
- The lapse has immediate operational and revenue consequences: some telehealth services may no longer be reimbursed by Medicare or require different billing rules; some programs (e.g., Hospital-at-Home expansions, certain home-originating rules) are affected. Many providers are pausing or reconfiguring telehealth offerings while payers and CMS clarify next steps. Healthcare Dive+1
- Some flexibility remains for behavioral health specifically (a portion of behavioral health telehealth policy had been made permanent earlier), but state/payer details vary confirm with your MAC and commercial payers. telehealth.hhs.gov+1
Immediate (Day-0 to Day-7) Action Items Stop, Triage, Communicate
- Pause automatic telehealth billing changes instruct billing to hold telehealth claims that haven been validated for payers until review. (Avoid mass denials.)
- Identify high-risk services generate a list of the top 20 CPTs your clinic bills via telehealth (behavioral health, chronic care, hospital-at-home, RPM, DME consults) and flag which are Medicare-sensitive.
- Confirm payer rules contact your Medicare Administrative Contractor (MAC) and the top 3 commercial payers / Medicare Advantage plans you work with to confirm:
- Which telehealth services remain payable
- Any required modifiers/POS or in-person requirements
- Policies for audio-only visits and originating site rules
(Do this today payer responses are the source of truth.) Centers for Medicare & Medicaid Services+1
- Communicate to clinical teams issue a short memo: suspend scheduling new Medicare telehealth visits for services now in question until confirmed; continue clinically necessary care (in person if required).
- Notify patients proactively prioritize vulnerable populations (mental health, mobility-limited, home-hospital patients) and tell them how their telehealth appointment may change (see sample patient message below).
Documentation & Clinical Chart Checklist (what you must add or verify to support telehealth billing)
For any telehealth visit you intend to bill (Medicare or commercial), ensure the chart contains:
A. Core visit elements (E/M or behavioral health):
- Chief complaint / reason for visit.
- History (HPI) and problem-focused review or ROS as applicable.
- Exam (when applicable) or focused observations appropriate to telehealth.
- Medical Decision Making (MDM) documentation or total time if billing time-based E/M.
B. Telehealth-specific elements (add to chart):
- Mode of service: Video (real-time audiovisual) vs audio-only record explicitly.
- Location of patient (originating site): Document the exact place where the patient is located at time of encounter (home, skilled nursing, rural clinic, etc.) Medicare rules hinge on originating site. Centers for Medicare & Medicaid Services
- Location of provider (distant site): Document provider physical location.
- Patient consent for telehealth (documented): who gave consent, when, and that risks/limitations were discussed.
- Time on telehealth portion of visit if any time-based code is billed (e.g., 99497, time for psychotherapy add-ons).
- If audio-only used: document why video was not used (patient lacks technology, impairment, choice) and that audio-only was clinically appropriate.
- For behavioral health: document the additional psychotherapy elements (technique, focus, duration) if claiming add-on psychotherapy codes. Centers for Medicare & Medicaid Services+1
C. Administrative flags for billing staff:
- CPT/Modifier to use, POS (place of service) required by payer (POS 02 vs office), and whether the MAC requires a modifier (e.g., 95 or GT) or a specific POS for telehealth. Do not assume verify payer rules.
Billing & Coding Practical Notes
- Medicare: Many telehealth flexibilities expired as of 10/1/2025 geographic/originating site restrictions and provider type rules that existed pre-PHE may again apply. Check the CMS MLN guidance and your MAC. Centers for Medicare & Medicaid Services
- Audio-only: Some audio-only allowances had been made permanent for select services; others were temporary confirm which specific CPTs your practice uses are allowed audio-only by Medicare and by your commercial plans. Centers for Medicare & Medicaid Services+1
- Modifiers / POS: Use payer instructions. Historically Medicare required modifier 95 (synchronous telemedicine) and POS 02 was used by some providers BUT payer preferences vary; follow MAC and payer guidance to avoid denials. Centers for Medicare & Medicaid Services
- Medicare Advantage and Medicaid: Many MA plans and state Medicaid programs set their own telehealth rules they may be more flexible than CMS or more restrictive. Confirm individually.
- Hospital-at-home / FQHC/RHC changes: Program rules changed for these services when flexibilities expired; check program-specific guidance. Home Health Care News+1
Risk-Mitigation & Business Continuity (what to do this month)
- Operational playbook: Create 3 operational tracks per payer: (A) Telehealth allowed as before; (B) Telehealth allowed but with restrictions; (C) Telehealth not covered must be converted to in-person or deferred.
- Schedule conversion process: For patients in track C, call and offer in-person appointments or reschedule; track no-shows/transportation assistance.
- Finance impact run: Run a 90-day revenue sensitivity analysis modeling telemetry volumes that may be denied; brief finance/leadership.
- Contracts & Credentialing: Check MA contracts, telehealth agreements, and remote prescribing privileges; prepare to renegotiate if necessary.
- Telemetry & RPM: Remote patient monitoring (RPM) rules are distinct confirm which RPM codes remain payable via telehealth channels.
- Legal & compliance: Update consent forms and privacy notices; consult counsel for state licensure implications (interstate licensure waivers may also have expired). National Law Review
Sample Emails / Messages
1) Short Provider Memo (use in clinic Slack / email)
Subject: URGENT Telehealth policy changes effective 10/1/2025 immediate actions
Team due to recent changes in Medicare telehealth policy effective 10/1/2025, do not schedule new Medicare telehealth visits until payer confirmation. Clinical care continues; if telehealth is not payable, we ll convert to in-person or use alternative payer. Billing will flag claims for review. Clinical staff: document patient location, consent, modality (video vs audio). Admin will notify patients. Contact [billing lead name] for payer questions.
2) Patient Notification (script)
Hello [Patient name], this is [clinic] about your upcoming appointment on [date]. Due to recent federal changes, there are temporary changes in Medicare telehealth coverage. We are confirming whether your telehealth visit will be covered. If not, we will offer an in-person visit or alternatives. We will call you by [date] with options. If you have difficulty traveling to clinic, please tell us so we can explore resources.
Sample Chart Language You Can Paste (EMR friendly)
- Mode: Telehealth real-time audiovisual. Patient location: Home (1105 Railroad St., Silsbee, TX). Provider location: Office. Patient consent for telehealth documented 07/17/2025 at 09:00. Reason: med management. Telehealth limitation discussed and patient agreed. Time spent on psychotherapy: 25 minutes (in addition to E/M).
- If audio-only: Mode: Audio-only; patient declined video due to lack of device. Audio-only used for clinical appropriateness; patient consent documented.
Who to Contact Now (prioritized)
- Your Medicare Administrative Contractor (MAC) confirm which services remain reimbursable and any required modifiers/POS. Centers for Medicare & Medicaid Services
- Top 3 commercial payers/MA plans obtain written confirmation of their telehealth policy.
- State licensing board confirm interstate telepractice waivers and provider scope.
- Legal/compliance and risk for consent, privacy, and policies.
- IT/Telehealth vendor to ensure platform logging and documentation capture for audits.
Key References (most important / load-bearing)
- CMS MLN Matters / Telehealth & Remote Patient Monitoring guidance (explains statutory limitations retaking effect Oct 1, 2025). Centers for Medicare & Medicaid Services
- CMS Telehealth FAQ (April 2025) summarizes temporary policy extensions and behavioral health specifics. Centers for Medicare & Medicaid Services
- Telehealth Resource Center “The Telehealth Policy Cliff: Preparing for October 1, 2025 contingency guidance and checklists. Telehealth Resource Centers
- Healthcare Dive / Health policy reporting immediate news on flexibilities expiring and provider impacts (coverage/financial implications). Healthcare Dive
- American Psychiatric Association / Psychiatry.org notes specific behavioral health disruptions and recommended clinical actions. American Psychiatric Association
One-Page Checklist (printable) Do these now
- Generate report of telehealth CPTs and volumes (last 6 months).
- Email MAC & top payers for written telehealth coverage confirmation.
- Instruct billing to hold telehealth claims pending payer confirmation.
- Update scheduling rules for Medicare beneficiaries (hold new telehealth bookings unless confirmed).
- Update EMR templates to capture: patient location, provider location, modality, consent, psychotherapy time, reason for audio-only.
- Draft patient notification messages (priority to high-risk).
- Run quick revenue risk estimate and notify leadership.