Telehealth Billing in 2025: Navigating the Changes
Telehealth billing rules are shifting again in 2025. Understanding what’s changing and what’s staying the same is essential for maintaining revenue from virtual care services.
What’s Ending October 1, 2025
Several Medicare pandemic flexibilities expire for non-mental health telehealth:- Geographic restrictions return: Patients must be in rural areas (as defined by HRSA) to receive most telehealth services
- Originating site requirements return: Patients must be at eligible healthcare facilities, not at home
- Audio-only limited: Audio-only services restricted to mental/behavioral health and substance use disorder only
Mental Health Exception: Extended Through January 30, 2026
Mental health telehealth services retain significantly more flexibility:- Home-based care still allowed without geographic restrictions
- Audio-only services permitted if patient lacks video capability or prefers audio
- No in-person visit requirement before initiating telehealth mental health services
- FQHCs and RHCs can continue providing mental health telehealth
Permanent Telehealth Provisions
Some telehealth expansions are now permanent:- Remote patient monitoring (RPM) for chronic and acute conditions
- Many specialty consultations via telehealth
- Telehealth services for certain conditions at rural health clinics (RHCs) and federally qualified health centers (FQHCs)
Modifiers and Place of Service Codes
Current modifier requirements remain in effect:- Modifier 95: Telehealth services (audio-video)
- Modifier 93: Audio-only services (mental health primarily)
- Modifier FQ: Audio-only for FQHCs/RHCs
- POS 02: Patient NOT at home during telehealth
- POS 10: Patient at home during telehealth
Action Items for Your Practice
- Audit your telehealth patient population: Identify which patients will no longer qualify for telehealth after October 1
- Communicate with affected patients: Provide advance notice about service changes
- Update scheduling workflows: Build in checks for telehealth eligibility based on patient location and service type
- Train staff on new requirements: Ensure front desk and billing staff understand the changes
- Review payer policies: Commercial payers may have different rules than Medicare
Commercial Payer Considerations
While Medicare rules are changing, commercial payers may maintain broader telehealth coverage:- Many states have telehealth parity laws requiring coverage
- Verify each payer’s current telehealth policy
- Watch for policy updates as the October deadline approaches
