Enhancing Telehealth Billing Efficiency: Key Updates for 2025

In 2025, telehealth billing will face significant changes as several temporary flexibilities introduced during the COVID-19 public health emergency (PHE) are phased out. Telehealth providers must familiarize themselves with these updates to ensure compliance and maximize reimbursement under the Medicare Physician Fee Schedule (MPFS). Below is an in-depth analysis of essential telehealth billing updates for 2025, focusing on expiring PHE waivers, proposed CMS flexibilities, and new billing requirements.

Key Changes in Telehealth Billing for 2025

1. Expiring PHE Telehealth Flexibilities

Temporary telehealth waivers enacted during the PHE expanded Medicare access by loosening restrictions on originating sites, allowing audio-only telehealth, and broadening the range of practitioners eligible to bill for services. These waivers, extended through the 2023 Consolidated Appropriations Act (CAA), will expire on December 31, 2024, unless further extended by Congress.

Key impacts of these expirations include:

• Originating Site Restrictions: Beginning January 1, 2025, a patient’s home will be an originating site only for mental health and substance use disorder services, as well as monthly End-Stage Renal Disease (ESRD) assessments.
• Audio-Only Services: Most audio-only telehealth services will no longer be covered, as CMS emphasizes two-way audio-video technology.

CMS has sought feedback on the potential effects of these changes, noting that reduced access to flexible originating sites and audio-only services may hinder telehealth utilization in 2025.

2. Proposed CMS Flexibilities for 2025

Recognizing the ongoing demand for telehealth, CMS has proposed retaining select PHE-era flexibilities to support continued service delivery while ensuring compliance with regulatory standards.

·Remote “Direct Supervision”:

• Extension Through 2025: Practitioners may fulfill “direct supervision” requirements remotely using real-time audio-video technology through December 31, 2025, provided they remain immediately available.
• Permanent Supervision for Specific Services: CMS proposes making virtual supervision a permanent option for certain services, such as CPT code 99211 visits, benefiting practitioners overseeing auxiliary personnel remotely.

·       “Distant Site” Address Flexibility: Practitioners will continue billing from enrolled locations without needing to list their home address, maintaining privacy and safety through December 31, 2025.

·       Updated Definition of “Telecommunications System”:

• CMS proposes allowing audio-only telehealth under specific circumstances, provided the provider’s equipment supports two-way audio-video communication, and the patient cannot or declines to use video technology.
• Claims for audio-only services must use CPT modifier “93” to ensure compliance.

3. Additions to the Telehealth Services List

While CMS has not confirmed permanent additions to the telehealth services list, several provisional codes are under consideration for 2025:

• Home Monitoring: HCPCS Code G0248 for INR monitoring.
• HIV Preventive Care: HCPCS Codes G0011 and G0013 for PrEP.
• Caregiver Training: New codes (e.g., GCTD 1-3, GCTB 1-2) for training on behavior and functional performance.

These codes aim to address emerging healthcare needs in home settings and support caregiver involvement in patient care.

4. Non-Adoption of New AMA Telemedicine Codes

CMS will not implement new AMA CPT codes (9X075–9X091) for telemedicine Evaluation and Management (E/M) services in 2025. Instead, providers should continue using existing E/M codes, as CMS deems the new codes redundant.

5. Compliance Considerations for Providers

The proposed changes introduce complex compliance challenges for healthcare providers, including:

• Adapting to Originating Site and Supervision Changes: Updating policies and workflows to align with new site restrictions and remote supervision requirements is crucial.
• Audio-Only Billing Updates: Providers must ensure audio-only claims are properly filed using CPT modifier “93” for eligible services.
• Monitoring Provisional Codes: Providers should prepare for workflow adjustments to integrate provisional codes, particularly for services like PrEP and caregiver training.

Conclusion

The 2025 Medicare Physician Fee Schedule introduces pivotal updates to telehealth billing, balancing the expiration of PHE waivers with new flexibilities and regulatory requirements. As telehealth continues to evolve as a core component of healthcare delivery, providers must stay proactive in adapting to these changes to maintain access, ensure compliance, and optimize reimbursement.

By understanding and implementing these updates, telehealth practitioners can navigate the complexities of the regulatory landscape while continuing to deliver quality care to their patients.