Earlier this month, the Centers for Medicare and Medicaid Services (CMS) released several important updates regarding Medicare telehealth policies following the expiration of legislative waivers on September 30, 2025. These changes, outlined in a special edition of the Medicare Learning Network (MLN) Newsletter and an updated Telehealth FAQ, address claims processing, payment policies, and in-person visit requirements. Here’s a recap of key updates:
Claims Hold During Legislative Uncertainty
- Temporary Claims Hold: CMS has directed Medicare Administrative Contractors (MACs) to hold claims for services provided on or after October 1, 2025. This includes claims under the Medicare Physician Fee Schedule, ground ambulance transport, and Federally Qualified Health Center (FQHC) services. Payments will not be released until the hold is lifted.
- Advance Beneficiary Notice of Noncoverage: Providers delivering telehealth services no longer eligible for Medicare payment should consider issuing an Advance Beneficiary Notice of Noncoverage to patients.
- Advocacy Efforts: Stakeholders, including the American Telemedicine Association (ATA), are urging Congress to retroactively reimburse telehealth services provided during this waiver gap.
FQHC/RHC Non-Behavioral Health Services via Telehealth
- Extended Billing Period: FQHCs and Rural Health Clinics (RHCs) can continue billing for non-behavioral health services delivered via telecommunications technology using HCPCS code G2025 through December 31, 2025.
- Proposed Extension: CMS has proposed extending this policy through December 31, 2026, pending finalization of the 2026 Physician Fee Schedule (PFS) in November.
Behavioral Health Telehealth Services: In-Person Visit Requirements
- Established Patients: Patients who began receiving behavioral health telehealth services before October 1, 2025, are exempt from the initial 6-month in-person visit requirement. However, they must have at least one in-person visit every 12 months.
- New Patients: For patients starting telehealth services after October 1, 2025, an in-person visit is required within 6 months of the first telehealth service, followed by annual in-person visits.
- FQHC/RHC Behavioral Health Services: In-person visit requirements for behavioral health services provided by FQHCs and RHCs are delayed until at least January 1, 2026.
What This Means for Providers
These updates clarify lingering questions about telehealth policies post-waiver expiration. Providers should:
- Stay informed about claims holds and potential Congressional actions.
- Consider issuing an Advance Beneficiary Notice of Noncoverage for non-covered telehealth services.
- Review CMS’ updated Telehealth FAQ for detailed guidance on billing and in-person visit requirements.
For more information, consult CMS’ updated Telehealth FAQ. For the latest updates on all active bills, visit the Center for Connected Health Policy’s Pending Legislation Tracker.
Additional Resources:
- How to prepare for the telehealth cliff and the end of Medicare telehealth coverage
- The Telehealth Policy Cliff: Preparing for October 1, 2025 (MATRC)
- Virginia Medicaid Announces Telehealth Flexibility Continues
- Medicare and Mental Health Coverage, a guide on telemental health in-person requirements now in effect (CMS)