Overview of Telehealth Rules, Extensions, and the Future of the Program
As of March 28, 2025, recent legislative actions have extended several telehealth flexibilities within the Medicare program.
The American Relief Act, 2025, enacted on December 21, 2024, extended various Medicare telehealth provisions through March 31, 2025. Subsequently, a Continuing Resolution (CR) passed in March 2025 extended these flexibilities until September 30, 2025.
Key provisions of the telehealth extensions include:
The Centers for Medicare & Medicaid Services (CMS) provides guidelines regarding which providers can perform telehealth services. These guidelines were expanded significantly, especially during the COVID-19 pandemic, to address public health needs and to improve access to care.
Providers Who Can Perform Telehealth Services
According to CMS, the following providers can deliver telehealth services to Medicare beneficiaries:
*These services/providers are most at risk if CMS changes the approved providers list for services in the Hospital Setting.
Follow-up considerations
- Monitor Legislative Developments: As the September 2025 deadline approaches, stay informed about potential further extensions or permanent changes to telehealth policies.
- Evaluate Technology Needs: Ensure providers and patients have access to the necessary technology and training to utilize telehealth services effectively.
- Assess Impact on Care Delivery: Analyze how extended telehealth flexibilities affect patient outcomes, access to care, and healthcare costs within your practice or organization.
- Review Compliance Requirements: Remain compliant with evolving telehealth regulations and billing practices to avoid potential reimbursement issues.
Summary
The CMS recognizes various healthcare professionals, including physicians, nurse practitioners, physician assistants, clinical psychologists, social workers, registered dieticians, audiologists, and therapists, as eligible to perform telehealth services for Medicare beneficiaries. Expanding these telehealth services, especially during the COVID-19 pandemic, aims to enhance access to care while adhering to safety guidelines.
Resources:
We have compiled a selection of reference materials and source links for your review to support the subject of telehealth. These resources provide valuable insights and information that may be beneficial for discussion internally with your organization.
- CMS Telehealth Services Regulations and Updates:
- https://www.cms.gov/medicare/coverage/telehealth?redirect=/telehealth
- This page provides a comprehensive overview of telehealth services and the different health professionals approved for telehealth delivery, including recent policy updates.
- Telehealth Services FAQs:
- https://www.cms.gov/files/document/telehealth-faq-calendar-year-2025.pdf
- This resource offers FAQs about telehealth policies, the types of providers who can participate in telehealth services, and updates on coverage.
- Medicare payment policies:
- https://telehealth.hhs.gov/providers/billing-and-reimbursement/medicare-payment-policies
- The latest on the Centers for Medicare and Medicaid Services (CMS) coverage for telehealth
- List of Telehealth Services
- https://www.cms.gov/medicare/coverage/telehealth/list-services
- This page contains a link to the “List of Telehealth Services for Calendar Year 2025 (ZIP),” which you can download with the list.
- HRSA’s Medicare Telehealth Payment Eligibility Analysis:
- https://data.hrsa.gov/
- This site can be used to see if an address is eligible for Medicare telehealth originating site payment.
- Health & Human Services (HHS) – Telehealth Policy Updates
- Health & Human Services (HHS) – What can be treated through telehealth
- Health & Human Services (HHS) – How do I use telehealth for behavioral health care? (patient’s perspective but also very useful as it provides a list of services in layman terms)
- Useful Links – Discussion of Telehealth Policies in Previous Rulemaking
The links below navigate readers to the prior years’ Medicare Physician Fee Schedule Notice and Comment rulemaking sections on the U.S. Government Federal Register website. We have curated links to ease the burden of finding historical information. For more ways to search the Federal Register, please navigate here; using advanced filters may be helpful (the advanced filter can be used to search, for example: “Documents matching ‘\ “Physician Fee Schedule\”, ‘from Centers for Medicare & Medicaid Services, of type Rule, affecting 42 CFR 410, and about Medicare” ). General reader aids for the Federal Register may be found here.
The following links navigate to various previous discussions of Medicare Telehealth:
- CY 2003 PFS Final Rule (67 FR 79988 through 79989) – discussion of the implementation of legacy Category 1 and Category 2
- IFC-1 (85 FR 19232 through 19243) – PHE-related flexibilities
- IFC-2 (85 FR 27602) – PHE-related flexibilities
- CY 2021 PFS Final Rule and IFC (85 FR 84502 through 84540)
- CY 2022 PFS Final Rule (86 FR 65047 through 65062)
- CY 2023 PFS Final Rule (87 FR 69445 through 69467)
- CY 2024 PFS Final Rule (88 FR 78852 through 78878)
- CY 2025 PFS Final Rule (89 FR 97746 through 97767)
Other Federal Resources
These links to other U.S. Government resources may be useful for context when preparing a submission:
