Medicare Telehealth Flexibilities: Some Will Expire, Some Will Continue, and Some Are Made Permanent

On November 1, 2024, CMS announced that certain telehealth flexibilities that were issued during the COVID-19 Public Health Emergency (PHE) will either: (1) expire on December 31, 2024, (2) be extended through December 31, 2025, or (3) be made permanent.

Expiring. In the recently published 2025 Medicare Physician Fee Schedule update, CMS indicated that many PHE-era telehealth coverage flexibilities will expire on December 31, 2024. Most notably, CMS will reinstate the requirement that a beneficiary be located in a qualifying “originating site” (i.e., certain rural, non-urban geographies, and in a clinic or other approved healthcare facility) in order for Medicare to cover the telehealth service. Additionally, effective January 1, 2025, only certain categories of practitioners can provide Medicare-covered telehealth. The PHE-era flexibility that allowed any category of Medicare-enrolled practitioner to furnish telehealth services will expire at the end of this year.

Extended. Telehealth flexibilities extended through December 31, 2025 include: 

• Removing frequency limitations on certain inpatient visits, skilled nursing facility visits and critical care consults furnished via telehealth
• The use of live video to meet certain Medicare “direct supervision” requirements
• Allowing Medicare coverage of any type of telehealth (not just behavioral health) furnished by FQHCs and RHCs

Permanent. The telehealth flexibilities made permanent by CMS are: 

• Permitting audio-only telehealth for any Medicare-covered telehealth service
• Allowing Opioid Treatment Programs to furnish assessments via audio-only (if video is unavailable)
• Coverage of new codes for interprofessional consults by behavioral health providers