Use of telehealth services has risen rapidly since 2020, and Medicare patients are no exception. Recognizing the need for flexible access to health care during the COVID-19 pandemic, Congress allowed Medicare to implement a variety of temporary measures to make virtual care more widely accessible. These measures allowed more patients to access care from home, expanded provider eligibility, and permitted reimbursement for a wider variety of services, including audio-only visits. But as 2024 comes to a close, many of these Medicare flexibilities are set to expire. Without congressional action, telehealth providers will face a narrower set of rules for Medicare reimbursement starting January 1, 2025. Understanding these changes now will help your practice prepare for what’s ahead.

A Look Back: Medicare’s Telehealth Expansion

Prior to the pandemic, Medicare’s coverage of telehealth services was extremely limited, largely restricting coverage to patients in rural areas and excluding many types of providers and services. Since the passage of the Coronavirus Preparedness and Response Supplemental Appropriations Act and the CARES Act in March 2020, Medicare recipients have enjoyed more comprehensive coverage for virtual care. Some of the temporary changes in coverage include:

• Eliminating geographic and originating site requirements: Prior to the pandemic, Medicare coverage of telehealth was only available to patients living in remote rural areas. Coverage for these patients was further limited by originating site requirements, which required patients to receive services at certain “originating sites,” generally limited to certain rural health clinics and Federally Qualified Health Centers (FQHCs). Since then, Medicare has waived these requirements, allowing patients in suburban and urban areas to enjoy coverage for telehealth services without visiting an originating site.
• Expansion of covered services: The pandemic ushered in a new set of covered services for Medicare, including physical and occupational therapy, nursing home care, and emergency visits. Medicare also began to cover audio-only visits for certain services for the first time, waiving the traditional two-way audio/visual platform requirement for coverage.
• Increased provider eligibility: Medicare coverage now covers more telehealth providers than ever. Current Medicare flexibilities allow any provider who is eligible to bill for Medicare to provide and bill for telehealth services as a “distant site” provider, including physical therapists, occupational therapists, and speech pathologists.
• In-person visit requirements for behavioral health: Currently, ****Medicare beneficiaries may opt to receive behavioral health services without any in-person visit requirement.

These policies have undoubtedly expanded the use of telehealth in the past few years. But as they approach their sunset date, providers and patients alike are bracing for a return to pre-COVID restrictions on telehealth coverage.

What’s Changing in 2025?

Without legislative action, Medicare beneficiaries will face greater restrictions and barriers to coverage of telehealth care. For one, coverage will only be available for patients in certain rural areas who receive services in approved locations, like clinics or hospitals. Similarly, providers who have previously been able to bill Medicare for virtual services—like physical and occupational therapists—will no longer be eligible to do so. Providers who remain eligible to bill for telehealth  will only be able to bill for a set number of services, with audio-only services becoming ineligible.

While many of these flexibilities are set to expire, one key exception is behavioral health. Thanks to the Consolidated Appropriations Act of 2021, providers in this field can continue to offer telehealth from any location, including patients’ homes, and use audio-only methods when video is unavailable.

How Providers Can Prepare

The transition to post-pandemic rules may feel daunting, but there are steps you can take now to minimize disruptions.

Start by evaluating the services you offer. If your practice depends on Medicare billing for services that fall outside of the updated rules, consider how this will impact your revenue. For example, if your practice regularly provides audio-only visits, you’ll need to ensure your practice has access to traditional two-way audio/video technology like Zoom is in place, or shift to in-person care for affected patients.

Your practice’s billing and documentation systems may also need attention. Medicare compliance will likely come under increased scrutiny, so maintaining thorough and accurate records is essential. Ensure your staff understands what will be covered under the new rules and how to code services correctly to avoid denials or audits.

Communication with patients will also be key. If you’re no longer able to provide certain services via telehealth, inform your patients early to assist them in making informed decisions about their care options. Offering solutions like transitioning to in-person visits or alternative virtual options can help maintain continuity of care.

Finally, stay engaged with industry developments. Organizations and associations advocating for telehealth policy are working to extend flexibilities or make them permanent. By staying informed, you’ll be better positioned to adapt to any last-minute changes.

The Bottom Line

The expiration of pandemic-era telehealth policies represents a shift, but it doesn’t have to be disruptive if you prepare. By understanding what’s changing, addressing gaps in your practice, and communicating clearly with patients, you can navigate the transition smoothly.

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