2025 MPFS: Key Updates on Telehealth and Frequency Limitations
As the landscape of healthcare continues to evolve, the Centers for Medicare & Medicaid Services (CMS) has proposed significant updates for the 2025 Medicare Physician Fee Schedule (MPFS). Among the most noteworthy are the extensions of telehealth flexibilities and revisions to frequency limitations. Key highlights include:
New Telehealth CPT Codes
- 17 new codes (98000-98016) for Evaluation and Management (E/M), effective January 1, 2025.
- New audio-only codes for new patients (98008-98011) and established patients (98012-98015).
- Replacement of old telephone-only codes (99441-99443) and HCPCS code G2012 with 98016.
New and Revised Telehealth-Related Codes
- 9X091: Virtual check-in encounters. This code replaces the G2012-G2252 codes.
- 98975-98978: Updates for digital therapeutic interventions and device-related services.
CMS Policies and Proposals
- Suspension of frequency limitations for certain high-acuity telehealth visits through December 31, 2025.
- Looser direct supervision requirements for telehealth, allowing supervision via real-time audio-visual tools.
- Recognition of telehealth services provided from practitioners’ homes under their office address.
- Proposals to add specific services to the Medicare Telehealth Services List, such as home INR monitoring and caregiver training.
Medicare Physician Fee Schedule (MPFS)
- Conversion factor decreased by 2.8% to $32.36 for 2025.
- Several telehealth flexibilities from the COVID-19 pandemic will continue.
- New add-on codes, including GIDXX for infectious disease care and codes for digital mental health treatment.
Telehealth Codes Not Recognized by CMS
- CMS declined recognition and payment for certain new AMA telehealth E/M codes (9X075–9X091), suggesting they duplicate existing codes.
Frequency Limitations
- CMS has proposed to extend the delay in reinstating frequency limitations for telehealth services in high-acuity settings through December 31, 2025.
- This proposal allows medical professionals to continue delivering certain telehealth services without the pre-Public Health Emergency (PHE) restrictions, which included:
- Inpatient visits (CPT 99231-99233): Limited to one telehealth visit every three days.
- Nursing facility visits (CPT 99307-99310): Limited to one telehealth visit every 14 days.
- Critical care consultations (HCPCS G0508, G0509): Limited to one telehealth visit per day.
New Additions to the Medicare Telehealth Services List
For 2025, CMS is proposing to add new services to the Medicare Telehealth Services List on a provisional basis. These services include caregiver training and initiation of home International Normalized Ratio (INR) monitoring. This expansion reflects CMS’s ongoing effort to address patient needs through accessible telehealth options.
Audio-Only Telehealth
- CMS has proposed that, starting January 1, 2025, an interactive telecommunications system may include two-way, real-time audio-only communication for telehealth services furnished to patients in their homes.
- This proposal will apply when the distant site physician or practitioner is capable of using video technology, but the patient either cannot use or does not consent to video.
- This change is designed to enhance accessibility for patients who may face technological or other barriers to video-based telehealth.
G2211 Complexity Add-On Code
- This code can now be billed when the base code is reported on the same day as a preventive service, such as an annual wellness visit or vaccine administration.
- This flexibility enhances the billing potential for comprehensive patient care.
Changes in Direct Supervision Requirements
Virtual Supervision
- CMS will continue to allow direct supervision through real-time audio and visual interactive telecommunications until December 31, 2025.
- This flexibility is particularly beneficial for services that typically require the supervising physician’s presence, such as diagnostic tests, physician services, and certain hospital outpatient services. Virtual supervision can streamline workflows for practices while maintaining the required level of oversight.
Supervision for Teaching Physicians
- Under the 2025 MPFS, teaching physicians will still be permitted to fulfill supervision requirements virtually when involved in clinical settings where telehealth is used. For example, a three-way telehealth visit involving the patient, resident, and teaching physician across separate locations will satisfy CMS’s “key portion” supervision requirement.
- CMS is also soliciting feedback on potentially expanding the primary care exception to include additional services in future rulemaking.
The 2025 Medicare Physician Fee Schedule proposes to extend several temporary flexibilities originally introduced during the COVID-19 PHE, including telehealth allowances and virtual supervision. Medical professionals should remain vigilant for potential changes after 2025, as CMS continues to assess the long-term value of these flexibilities. Staying informed of these proposals and CMS updates will be essential for practitioners navigating reimbursement structures in the upcoming year.
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Blog Title: 2025 MPFS: Key Updates on Telehealth and Frequency Limitations
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