866-488-3103If you provide telemental health services, you’ve lived through a rollercoaster of regulatory changes over the past few years. The pandemic-era flexibilities were a lifeline, but their temporary nature created a cloud of uncertainty. Could you plan your practice’s future around telehealth? Would your Medicare patients retain access to the virtual care that had become so vital?
The recent legislative actions have provided some much-needed answers. The 2025 policy extensions for Medicare and telehealth offer a significant degree of stability, but they also come with specific nuances that every mental health provider must understand. This isn’t just about administrative compliance—it’s about ensuring the seniors who rely on you for care don’t face unnecessary disruptions. Let’s demystify what these extensions mean for your practice.
A Foundation of Stability: What’s Been Extended
First, the good news. Congress, through various legislative packages, has extended the vast majority of pandemic-era telehealth flexibilities through December 31, 2024. This means that for the 2025 coverage year, providers can operate with confidence under the following key provisions:
Geographic Flexibility: Medicare beneficiaries can receive telehealth services from their home or any other location. The prior requirement that patients must be located in a designated rural area has been waived.
Provider Eligibility: A much broader range of providers, including licensed clinical social workers (LCSWs), clinical psychologists, and marriage and family therapists (MFTs), can continue to be reimbursed for telehealth services.
Audio-Only Coverage: Medicare will continue to reimburse for audio-only telephone visits for mental health services under certain conditions. This is a critical access point for patients with limited broadband or technological proficiency.
Expanded Service Codes: Many of the telehealth-covered CPT and HCPCS codes that were temporarily added will remain covered, allowing for a comprehensive range of telemental health services.
The Centers for Medicare & Medicaid Services (CMS) is the definitive source for the specific list of covered codes and their requirements.
Key Considerations and Practice Implications for 2025
While the extensions provide a framework, smart practice management requires attention to the details. Here’s what you need to know to ensure your services are both effective and reimbursable.
1. The In-Person Requirement: Navigating the Rules
This is one of the most important rules for mental health providers. The extensions maintain the requirement that for telehealth treatment of a mental health disorder, a patient must have had an in-person visit within 6 months prior to the initial telehealth service.
Furthermore, subsequent telehealth services require an in-person visit at least every 12 months.
What this means for your practice:
New Patients: You must coordinate an in-person initial evaluation for new Medicare patients seeking ongoing telemental health care. This cannot be done via telehealth.
Existing Patients: For patients you’ve been seeing, you must track their last in-person visit and ensure they come into the office at least annually to maintain their eligibility for telehealth reimbursements.
Documentation is Key: Meticulously document these in-person visits in the patient’s record. This will be essential during any audit.
There are exceptions for patients living in a designated Health Professional Shortage Area (HPSA), but the specifics are complex. The U.S. Department of Health and Human Services (HHS) provides a tool to check a patient’s address against HPSA designations.
2. Licensing and Originating Site Regulations
A significant easing of restrictions remains in place:
Provider Location: You can provide telehealth services from your home or office; you do not need to be at a qualified healthcare facility.
Patient Location: The patient can be at home or any private location.
State Licensing: The federal public health emergency waiver that allowed providers to practice across state lines has largely expired. You must be licensed in the state where the patient is located at the time of the service. This is a critical legal and reimbursement requirement.
3. Billing and Reimbursement Best Practices
Reimbursement rates for telehealth services are generally equivalent to in-person rates. However, accuracy is paramount.
To ensure clean claims:
Use the correct Place of Service (POS) code: Use POS 02 to indicate the service was provided via telehealth.
Use the appropriate modifier: Append modifier -95 to the procedure code to signify a synchronous telehealth service.
For audio-only visits: Use the modifier -93 (Synchronous Telemedicine Service Rendered via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) and ensure the service is on the list of those eligible for audio-only delivery.
A study by the Journal of General Internal Medicine on telehealth billing highlighted that coding errors are a primary reason for claim denials, emphasizing the need for precision.
Why This Matters: The Impact on Patient Access and Your Practice
Understanding these policies isn’t just bureaucratic box-ticking. It has a direct and profound impact on clinical care.
Continuity of Care: These extensions allow you to maintain uninterrupted treatment relationships with your vulnerable Medicare patients, many of whom have come to depend on the accessibility of telehealth.
Reducing Barriers: For seniors with mobility issues, transportation challenges, or chronic illnesses, the ability to receive care at home is not a convenience—it is a necessity. These policies directly reduce health disparities.
Practice Sustainability: The certainty of reimbursement through 2025 allows practices to invest confidently in the technology and staff training needed to deliver high-quality virtual care, making it a sustainable part of their long-term service model.
Looking Ahead: Preparing for the Future
While the 2025 extensions provide a clear runway, the long-term future of Medicare telehealth policy remains a topic of ongoing legislative debate. The best thing providers can do is:
Document Outcomes: Track patient satisfaction, clinical outcomes, and no-show rates for telehealth versus in-person visits. This data is powerful for advocating for permanent telehealth coverage.
Stay Informed: Regularly check the CMS telehealth resource page and updates from professional associations for any mid-year changes or new guidance.
Optimize Your Workflow: Use this period of stability to refine your telehealth intake, documentation, and billing processes to maximize efficiency and compliance.
For practices committed to serving the Medicare population, like Psychehope LLC, staying ahead of these policy shifts is integral to their mission. It ensures they can continue to offer a seamless, hybrid model of care that meets patients where they are, both physically and in their journey to wellness.
The 2025 extensions are a vote of confidence in the value of telehealth. By mastering their intricacies, you can ensure your practice is built to last, providing critical mental health support to those who need it most.