2025 telehealth flexibilities and policy updates
CMS Medicare claims processing and telehealth update
CMS has clarified that it will continue to pay Medicare telehealth claims as if there had been no lapse in telehealth flexibilities, including services furnished during the government shutdown period starting Oct 1, 2025. Telehealth flexibilities apply retroactively through Jan. 30, 2026.
Legislation passed in November 2025 included extensions of several telehealth flexibilities. Below are Medicare telehealth requirements through 2025 and flexibilities extended through Jan. 30, 2026.
Telehealth provisions
Teaching physicians
Through 2025: CMS will continue to allow teaching physicians to use real-time audiovisual telecommunications when the resident furnishes Medicare telehealth services in all residency training locations through the end of 2025; the teaching physician and resident do not have to be co-located.
Starting 2026: CMS will permanently allow teaching physicians to join telehealth visits virtually with residents and patients when the service is furnished virtually.
In-person supervision remains required for face-to-face visits in metropolitan areas. Documentation must specify in-person vs. virtual presence and the portion of the service supervised.
Virtual direct supervision
Through 2025: CMS will allow virtual direct supervision for a subset of services. Specifically, a supervising clinician may use real-time audiovisual telecommunications for services furnished “incident to” a dermatologist’s or non-physician clinician’s (NPC) professional services. This policy includes services with a PC/TC indicator of “5” (e.g., 96900-96912) and the service described by CPT code 99211, as well as other office or outpatient E/M visits for established patients who may not require the dermatologist’s or NPC’s physical presence.
For all other services provided “incident to” that require direct supervision, CMS will only allow use of real-time audiovisual telecommunications through Dec. 31, 2025.
Starting 2026: CMS is permanently allowing “direct supervision” to be met through virtual presence using real-time audio-video (excluding audio-only). This applies to incident-to-services, diagnostic tests, pulmonary rehabilitation, and cardiac and intensive cardiac rehabilitation. Exceptions include procedures with a global surgery indicator of 010 or 090.
Audio-only telehealth (permanent policy implemented in 2025)
The 2025 Final Rule finalized the definition of “interactive telecommunications system” to include two-way, real-time audio-only communication technology for any telehealth services furnished to beneficiaries in their homes if the distant site dermatologist or NPC is technically capable of using an interactive telecommunications system that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site dermatologist or NPC, but the patient is not capable of, or does not consent to, the use of video technology.
CMS clarified that no additional documentation, other than the appropriate modifier, e.g., modifier 93 Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system, is required for audio-only services.
Telehealth flexibilities through Jan. 30, 2026
Removal of geographic and originating site restrictions
Medicare beneficiaries may receive telehealth services from any location in the U.S., including home.
Authority for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)
FQHCs and RHCs may serve as distant-site telehealth providers.
Audio-only
CMS will continue coverage of audio-only telehealth for non-behavioral health services. Starting Jan. 31, 2026, audio-only coverage is expected to become more limited. According to the CMS FAQ, “Starting January 31, 2026, physicians and practitioners may use two-way, real-time audio-only communication technology for behavioral health services furnished to a patient in their home, provided that the furnishing physician or practitioner is technically capable of using audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology.”
Note, these telehealth flexibilities do not apply to private payers. We encourage practices to check with private payers before providing the service to ensure appropriate reimbursement expectations.
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