Since March 2020, it seems the rules regarding Medicare coverage for telehealth services have been changing constantly. The following summarizes the current state of coverage, at least through March 31, 2025.
Geographic and Originating Site Restrictions. Section 1834(m) of the Social Security Act restricts Medicare coverage to telehealth services furnished to beneficiaries physically present in specified facilities located in rural areas at the time of service. Since March 2020, Congress has temporarily waived the geographic and originating site restrictions, thus expanding Medicare coverage to services regardless of the beneficiary’s location. As part of the Consolidated Appropriations Act, 2021 (CAA), Congress amended Section 1834(m) to permanently waive these restrictions for tele-behavioral health services but require an in-person visit within six months of initiating such services. The in-person visit requirement, however, will not take effect until the geographic and originating site waivers terminate.
In the American Relief Act, 2025, Congress extended the waiver of the restrictions for medical telehealth services (and the in-person visit requirement for tele-behavioral health services) through March 31, 2025. Absent further congressional action, beginning April 1, 2025, coverage for medical telehealth services will be limited by the pre-pandemic restrictions (and a prior in-person visit will be required for newly initiated tele-behavioral health services).
Telehealth Providers. Section 1834(m) limits Medicare coverage to telehealth services furnished by physicians and non-physician practitioners. Congress expanded this list of providers to include any provider who can bill for services under the Medicare Physician Fee Schedule (MPFS) (e.g., physical and occupational therapists, clinical psychologists). Again, absent congressional action, the list of telehealth providers will revert to only physicians and non-physicians on April 1, 2025.
List of Telehealth Services. Section 1834(m) also restricts coverage to a list of approved telehealth services to be maintained by the Centers for Medicare & Medicaid Services (CMS). Prior to the pandemic, the list of approved telehealth services included approximately 100 services. CMS more than doubled the number of approved services on the list during the pandemic. Following the end of the COVID-19 public health emergency, CMS maintained the expanded list of approved telehealth services and added more services to the list in 2024 and 2025. For each service on the list, CMS identified it as permanent or provisional. Those services listed as provisional are subject to removal if CMS determines at some later date the service cannot be provided safely or effectively via telehealth.
Audio-Only Telehealth Services. Effective January 1, 2025, Medicare no longer reimburses for audio-only E/M codes, CPT 99441-99443. Also, on the list of approved telehealth services, CMS no longer identifies certain services as eligible for audio-only interaction. In the 2025 MPFS final rule, CMS amended the regulatory definition of “interactive telecommunications system” in 42 CFR 410.78 to specify the circumstances in which a service may be furnished via audio only: (1) the beneficiary is physically present in their home at the time the service is delivered; (2) the provider is technically capable of using audio-visual technology in providing telehealth services; and (3) the beneficiary is not capable of or does not consent to the use of video technology. The provider must append modifier -93 [or FQ for rural health clinics (RHCs) and federally qualified health centers (FQHCs)] to claims for audio-only telehealth services. Providers should document in the medical record the circumstances leading to the application of modifier -93.
Telehealth Services Furnished by RHCs and FQHCs. In addition to temporarily expanding the list of telehealth providers to include any provider who can bill for services under the MPFS, Congress also temporarily authorized Medicare coverage for telehealth services furnished by RHCs and FQHCs. In the CAA, Congress made permanent coverage for approved tele-behavioral health services furnished by RHCs and FQHCs, reimbursable at the RHC all-inclusive rate or under the FQHC prospective payment system (but also subject to the prior in-person visit requirement).
In the 2025 MPFS final rule, CMS amended its regulations to provide payment to RHCs and FQHCs for medical telehealth services at the national average payment rates for comparable services under the MPFS. For 2025, that rate is approximately $97.
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