Telehealth has revolutionized healthcare delivery, particularly in response to evolving federal policies designed to enhance accessibility. CMS has implemented permanent and temporary measures to bolster telehealth adoption, focusing on Medicare patients, rural communities, and behavioral health services.
Telehealth Flexibilities for Medicare Patients
To ensure continued access to care, Medicare has extended the following telehealth provisions for all specialties:
- Extended Home Access: Medicare patients can receive telehealth services at home for non-behavioral/mental health care through September 30, 2025.
- No Geographic Restrictions: Originating site restrictions for non-behavioral/mental telehealth services are waived until September 30, 2025.
- Expanded Provider Eligibility: All eligible Medicare providers can deliver telehealth services through September 30, 2025.
- Enhanced Role of FQHCs and RHCs: Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can serve as Medicare distant site providers for non-behavioral/mental telehealth services through September 30, 2025.
- Standardized Reimbursement: Payments for FQHCs and RHCs providing telehealth services via real-time audio-video telecommunications or audio-only interactions (where video is not feasible) follow national average rates under the Physician Fee Schedule (PFS) through December 31, 2025.
- Behavioral Health Access: In-person visit requirements for Medicare behavioral/mental telehealth services are waived through September 30, 2025, with FQHC and RHC mental health service exceptions extended until January 1, 2026.
- Audio-Only Communication: Non-behavioral/mental telehealth services can be delivered via audio-only platforms through September 30, 2025.
- Permanently Expanded Interactive Communication: Real-time, two-way audio-only communication is now a permanent telehealth option for patients unable or unwilling to use video.
Strengthening Access to Behavioral and Mental Health Services
Telehealth has emerged as a cornerstone of behavioral and mental health care. To support this growing need, Medicare has implemented the following policies:
- Permanent Inclusion of FQHCs and RHCs: These facilities can continue serving as distant site providers for behavioral/mental telehealth services.
- Unrestricted Home Access: Medicare patients can permanently receive behavioral/mental telehealth services from home.
- No Geographic Barriers: Behavioral/mental telehealth services no longer have originating site restrictions.
- Expanded Provider Roles: Marriage and family therapists and mental health counselors are now permanently recognized as Medicare distant site providers.
- Waived In-Person Visit Requirements: In-person visit requirements for Medicare behavioral/mental telehealth services are waived through September 30, 2025, with FQHC and RHC mental health service exceptions extended until January 1, 2026.
Florida Blue – Policy Update: Telemedicine Evaluation and Management Services
Effective February 15, 2025
The American Medical Association updates the Current Procedural Terminology (CPT®) code set each year. Florida Blue has aligned its telemedicine policies for commercial and Medicare Advantage plans.
Implementation of New CPT Codes (Effective February 15, 2025):
- Synchronous audio-video: CPT codes 98000-98007
- Synchronous audio-only: CPT codes 98008-98015
- Coding criteria: Reported based on medical decision-making level or total encounter duration.
- Modifiers 93 or 95: Not required for these services.
- Medicare Advantage Plan exclusions: CPT codes 98000-98015 do not apply.
Existing CPT Codes for Medicare Advantage Plans:
- Florida Blue follows CMS guidelines, requiring existing E&M codes 99202-99205 and 99212-99215, with modifiers 93 or 95 to identify the place of service.
- 99202-99205 and 99212-99215 should not be used for commercial plans.
New Virtual Check-in CPT Code (98016):
- Allows in-network providers to report brief virtual check-ins.
- It applies to both commercial and Medicare Advantage plans.
For further details, visit Florida Blue’s payment policy page at www.FloridaBlue.com.
Telehealth Expansion for Rural Healthcare
Given the critical role of telehealth in addressing rural healthcare disparities, policymakers have implemented the following long-term strategies:
- Sustained Telehealth Access: FQHCs and RHCs remain eligible as distant site providers for non-behavioral/mental telehealth services through September 30, 2025.
- Equitable Reimbursement: Telehealth services delivered by FQHCs and RHCs via interactive audio-video or audio-only platforms will continue to follow national PFS payment rates through December 31, 2025.
- Permanent Behavioral Health Services: FQHCs and RHCs can indefinitely serve as Medicare distant site providers for behavioral/mental telehealth services.
- At-Home Services for Medicare Beneficiaries: Behavioral/mental telehealth services are permanently accessible to Medicare patients at home without geographic limitations.
- Expanded Audio-Only Options: Behavioral/mental telehealth services under Medicare can be permanently delivered through audio-only communication platforms.
Expanding telemedicine policies represents a fundamental shift in healthcare delivery, ensuring broader access for Medicare beneficiaries, rural populations, and behavioral health patients. While some policies are temporary, others have been made permanent to support ongoing patient care. Healthcare providers must stay informed and adapt to these evolving regulations to maximize telehealth efficiency and enhance patient outcomes.
If you have any questions on billing telehealth services and their impact, please don’t hesitate to contact our office.
We also recommend you read this blog: Improve the Telemedicine Experience [5 quick tips]
