The Center for Connected Health Policy (CCHP)’s newsletter included a summary of frequently asked questions (FAQs) along with CCHP’s responses, based on requests for technical assistance that CCHP has recently received as well as questions asked during the January 9 CCHP and National Consortium of Telehealth Resource Centers (NCTRC) hosted webinar on federal telehealth policy.

Key topics covered in CCHP’s FAQ resource include: 

• Medicare Telehealth Waivers Extended: The recent Continuing Resolution (HR 10545) extends key Medicare telehealth waivers until March 31, 2025, including waived originating site location requirements, coverage for audio-only visits, expanded provider eligibility, and flexibility for mental health services.
• Audio-Only Telehealth Changes: CMS removed specific audio-only codes (99441-99443) in the 2025 Physician Fee Schedule (PFS) but clarified that codes 99202-99215 can be used with appropriate modifiers for reimbursement.
• In-Person Mental Health Visit Requirement Delayed: The waiver delaying the in-person visit requirement for telehealth mental health services has been extended but may return on April 1, 2025, if no further action is taken.
• New Telehealth Codes Not Adopted by Medicare: CMS declined to adopt most of the AMA’s new 98000-series telehealth codes, except for 98016, which replaces G2012. Medicaid and private payers may handle these codes differently.
• Controlled Substance Prescriptions via Telehealth: The DEA extended its waiver through 2025, allowing telehealth prescribing of controlled substances without a prior in-person visit. However, state-specific prescribing rules may still apply. Additionally, the DEA has adopted two new final rules creating exceptions from in-person visit requirements for veterans’ affairs and prescribing buprenorphine. They have also proposed a rule for a special telemedicine registration.

The answer to some questions regarding CMS telehealth policy remains unclear as we await further guidance from CMS. Compounding the uncertainty, an article posted to the Post-Acute and Long-Term Care Medical (PALTmed) Association website on January 27, 2025, indicates that CMS has yet to release temporary guidance for Medicare administrative contractors (MACs) on the telehealth billing extensions contained in HR 10545 (many of which are bulleted above). The delay, coupled with the new administration’s two-week health communication freeze, has added to the uncertainty and could mean a longer wait for clarity on lingering telehealth questions. CMS is only making exceptions for “mission critical” announcements, leaving it uncertain whether telehealth guidance will be issued before March 31, 2025 when the current telehealth extensions are set to expire.

For more details, access CCHP’s full FAQ newsletter write-up.

In the 2025 Final Physician Fee Schedule, the Centers for Medicare & Medicaid Services (CMS) finalized important updates for Opioid Treatment Programs (OTPs) aligning with regulations previously adopted by the Substance Abuse and Mental Health Services Administration (SAMHSA). These changes aim to enhance access to care for individuals with opioid use disorder (OUD) by expanding telehealth options.

Key updates include: 

• Periodic assessments may now be conducted via audio-only technology on a permanent basis if live video is unavailable, as long as they meet all applicable SAMHSA and DEA requirements.
• The OTPs intake add-on code (G2076) can now be billed when using live video for the initiation of methadone treatment.

As a result of these changes, CMS has updated its Opioid Treatment Program (OTP) webpage to reflect proper billing practices. OTPs should use the following HCPCS add-on codes when treating eligible patients: 

• G2076—Used to initiate buprenorphine or methadone treatment via two-way interactive audio-video or audio-only technology when video is unavailable.
• G2077—Covers periodic patient assessments via audio-only technology when video is unavailable.
• G2080—Applies to additional counseling or therapy provided via audio-only technology when video is unavailable.

For more details on the finalized policy, review the 2025 Final Physician Fee Schedule. To learn more about billing and G-codes for OTPs, visit the CMS Opioid Treatment Program webpage.

Shared from the Center For Connected Health Policies (CHHP) February newsletter

USDA Distance Learning & Telemedicine Grants

This competitive program helps rural communities use advanced telecommunications technology to connect to each other—and the world—overcoming the effects of remoteness and low population density. USDA encourages you to consider projects that promote equity and economic opportunity in rural America, specifically those that advance these key priorities:

• Helping rural communities recover economically through more and better market opportunities and through improved infrastructure
• Ensuring that all rural residents have fair access to Rural Development programs and benefits from Rural Development funded projects
• Reducing climate pollution and increasing resilience to the impacts of climate change through economic support to rural communities

Deadline: March 6, 2025

Refer to the funding page on the NRTRC website for additional updated grant opportunities.