On November 1, 2024, CMS released the CY 2025 Medicare Physician Fee Schedule (MPFS) Final Rule, outlining significant changes to telehealth policies effective January 1, 2025. Without Congress’ intervention, these updates could severely limit access to telehealth services for Medicare patients, potentially affecting over 85% of beneficiaries. Congress must act on this CMS 2025 Final Rule for Telehealth.
Key Telehealth Policy Changes in the 2025 MPFS Final Rule:
-
Telemedicine Flexibilities Ending:
- Flexibilities for telehealth originating site locations introduced during the COVID-19 public health emergency (PHE) and extended through 2024 will end.
- Beginning January 1, 2025, telehealth services will only be covered in specific rural and underserved areas unless Congress enacts legislation to extend these flexibilities.
-
Audio-Only Communication:
- Under specific conditions, two-way, real-time audio-only communication will meet interactive telecommunications system requirements when patients cannot or do not consent to video use. However, the distant site practitioner must still have audio-video capabilities.
- If pre-PHE geographical restrictions are reinstated, this policy may have limited practical impact.
-
Distant Site Practitioner Address:
- Practitioners can continue using their practice location instead of their home address for telehealth services provided from home through 2025, with further considerations for future rulemaking.
-
CPT® Code Updates:
- CMS will not recognize most newly introduced telehealth CPT® codes for 2025, assigning 16 out of 17 codes an “I” (invalid) status.
- Medicare will separately reimburse brief virtual check-in encounters under CPT® code 98016, replacing HCPCS code G2012.
-
Behavioral and Mental Health Services:
- Certain mental health and behavioral services will be permanently available via telehealth for Medicare beneficiaries starting January 1, 2025.
-
Place of Service (POS) Codes:
- Telehealth will continue to use POS codes 02 (patient not at home) and 10 (patient at home), with POS 10 reimbursed at the non-facility rate.
-
Geographical and Location Restrictions:
- Pre-pandemic geographic restrictions will return, limiting telehealth coverage to patients in rural or health professional shortage areas.
-
Teaching Physicians:
- Virtual presence for teaching physicians during telehealth services is extended through December 31, 2025.
Urgent Congressional Action Needed on CMS Final Rule
Without congressional intervention to address geographical restrictions, the vast majority of Medicare patients’ telehealth encounters in 2025 may not qualify for reimbursement. The window to enact legislative changes closes at the end of 2024, leaving limited time to ensure continued access to virtual care.
For further details, refer to the authoritative resources listed in the CMS guidance.
https://www.congress.gov/bill/118th-congress/house-bill/7623
https://www.congress.gov/bill/117th-congress/house-bill/2617/text
https://aspr.hhs.gov/legal/PHE/Pages/covid19-11Jan23.aspx
https://www.cms.gov/medicare/coverage/telehealth/list-services
https://www.aapc.com/blog/91584-telehealth-2025-the-final-rule/
For information regarding the Key 2025 MPFS Updates on Telehealth and Frequency Limitations, please see our previous blog here: https://streamlinemd.com/2025-mpfs-key-updates-on-telehealth-and-frequency-limitations/
StreamlineMD provides Revenue Cycle Solutions to Radiology & Interventional Specialists. Our Mission is to Improve Healthcare for All Americans. Our Core Values that guide us on our mission are Service Quality, Teamwork, Accountability, Efficiency, Adaptability, Communication, and Integrity. Proud winner of the Great Place To Work award. Learn more about us at streamlineMD.com.
