Telehealth became a mainstay during the pandemic, allowing providers and patients to stay connected when socialization restrictions were in place. In 2025, Medicare’s pandemic-era telehealth flexibilities have been extended and will stay in place unless changes are made. Medicare telehealth permanent extensions represent an important improvement in healthcare delivery, ensuring wider access for Medicare beneficiaries, rural populations, and behavioral health patients. Outsourcing healthcare revenue cycle management is a viable strategy to accurately code telehealth, audio-only, and virtual-digital visits, comply with telemedicine regulations and get paid for these services.
For most telemedicine services, providers must continue to use standard E/M codes (99202–99215) along with the appropriate modifier (e.g., 95 for audio-visual, or 93 for audio-only) and place of service.
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Medicare Telehealth Coverage 2025 – Key Policy Highlights
Physicians, physician assistants, nurse practitioners, clinical nurse specialists, nurse-midwives, clinical psychologists, clinical social workers, registered dietitians or nutrition professionals, certified registered nurse anesthetists, marriage and family therapists, and mental health counselors can permanently serve as Medicare distant site providers.
Medicare’s 2025 policy changes include:
- Telehealth services are limited to patients located in rural or health professional shortage areas.
- Patients must be at an originating site for all telehealth services except those for the diagnosis, evaluation or treatment of a mental health or substance use disorder. Patients can continue to receive behavioral and mental telehealth services from their home.
- Distant site practitioners may use their currently enrolled practice location instead of their home address when providing telehealth services from their home through December 31, 2025.
- Interactive telecommunications systems can include a two-way, real-time, audio-only communication for patients in their homes. Audio-only telehealth is limited to services for the diagnosis, evaluation or treatment of a mental health or substance use disorder.
- Both patient and any approved telehealth provider must be in the U.S. (including U.S. territories) when the services are performed. The telehealth provider must be licensed in the state they are in and the state the patient is in at the time the telehealth service is rendered. Medicare does not cover out of country (U.S.) medical services via telehealth or otherwise.
- Several services have been added to the CMS telehealth services List, including caregiver training services on a provisional basis and PrEP counseling and safety planning interventions on a permanent basis.
- Telehealth frequency limits are suspended on subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations through December 31, 2025.
- Teaching physicians may continue to maintain a virtual presence in all teaching settings, only for Medicare telehealth services through Dec. 31, 2025.
- According to the telehealth originating site waiver 2025, Medicare patients can permanently receive telehealth services for behavioral/mental health care in their home. There are no geographic restrictions for originating site for Medicare behavioral/mental telehealth services on a permanent basis.
Audiovisual Services
- Medicare has not adopted CPT’s new audiovisual E/M codes (98000-98007) and will deny claims reported with them. Eligible audiovisual telehealth services for traditional Medicare patients should be billed using in-person E/M codes with:
- Modifier 95 to confirm that services were conducted using audio-video technology.
- POS 10 when the patient is at home and POS 02 when the patient is anywhere else.
Audio-only services
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- Medicare allows physicians to report any code on the eligible telehealth services list performed via two-way interactive audio-only technology (i.e., telephone) to patients in their home in cases when the physician is technically capable of using audio-video technology, but the patient lacks video capability or declines video use. In such cases:
- The documentation must reflect both the reason for using audio-only as well as that the physician has audio-video technical capabilities.
- Modifier 93 should be appended to indicate the service was provided audio-only and report the appropriate office visit E/M (99202-99215) with modifier 93.
- Use POS 10 to denote that the patient is at home.
- Federally qualified health centers and rural health clinics should also append the FQ modifier for services provided via audio-only.
- Medicare allows physicians to report any code on the eligible telehealth services list performed via two-way interactive audio-only technology (i.e., telephone) to patients in their home in cases when the physician is technically capable of using audio-video technology, but the patient lacks video capability or declines video use. In such cases:
Communication Technology-based Services (CTBS)
Advanced Primary Care Management Services (APCM) incorporate elements of several existing care management and communication technology-based services (CTBS) into a bundle of services that reflects the essential elements of the delivery of advanced primary care, including Principal Care Management, Transitional Care Management, and Chronic Care Management.
For most part, Medicare will continue to pay for telehealth services through March 31, 2025. Telehealth services continue to evolve in 2025, with updated telehealth billing codes for synchronous (real-time) audio-visual and audio-only consultations. Partnering with an experienced third-party medical billing companies can help practices remain updated on these changes and Medicare reimbursement rules to accurately document and bill remote patient monitoring in 2025, ensuring proper payment for their time and expertise.
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