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  • Oct 17, 2025

    SPECIAL ALERT: CMS Releases Updated Medicare Telehealth Guidance – Clarifications Provided! 🙌

    Center for Connected Health Policy
    On October 1, 2025, the Centers for Medicare and Medicaid Services (CMS) issued guidance regarding Medicare telehealth claims during the government shutdown via a special edition of the Medicare Learning Network (MLN) Newsletter. In the update, CMS stated that when legislative payment provisions are scheduled to expire, CMS directs Medicare Administrative Contractors (MACs) to implement a temporary claims hold, typically of up to 10 business days. The hold is meant to prevent a large reprocessing of claims if Congress acts after the statutory expiration date, which was September 30, 2025. As the 10-day hold period had expired on October 14, CMS has now issued an additional claims hold update on October 15, 2025, stating that in anticipation of possible Congressional action, CMS has instructed all MACs to continue to temporarily hold claims with dates of service of October 1, 2025 and later for services impacted by the expired Medicare legislative waivers. This includes all claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center (FQHC) claims. While providers may continue to submit these claims, CMS states that payment will not be released until the claims hold is lifted. Also noted in the update, CMS again suggests that without further Congressional action, providers that continue to deliver telehealth services that are now not eligible for Medicare payment as of October 1, 2025, may want to provide patients with an Advance Beneficiary Notice of Noncoverage. Meanwhile, stakeholders including the American Telemedicine Association (ATA) are advocating that Congress include a retroactive statement in any future funding fix, to help reassure providers that reimbursement of telehealth services delivered during the waiver gap period will eventually be provided.

    Importantly, CMS also has updated their Telehealth FAQ document (as of October 15, 2025) to reflect the Medicare changes in effect as of October 1, 2025, consistent with the legislative waiver expirations at the end of September. In particular, two of the issues, which CCHP has recently received many questions around, appear to now be addressed in the updated FAQ:
    • Payment for FQHC and rural health clinic (RHC) non-behavioral health services via telecommunications technology.
    • Application of in-person visit requirements to behavioral health services provided post-September 30, 2025.
    Continue reading below for specific details on both of these clarifications.

    Payment for FQHC/RHC Non-Behavioral Health Services via Telecommunications Technology – Allowed through December 31, 2025

    The updated CMS FAQ states:

    Q4: How does CMS make payment for telehealth services furnished in RHCs and FQHCs? Can Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) continue to serve as distant sites for the provision of telehealth services?

    A4: Any behavioral health service furnished by an RHC or FQHC on or after January 1, 2022 through telecommunications technology is paid under the All Inclusive Rate (AIR) and Prospective Payment System (PPS), respectively. Through December 31, 2025, RHCs and FQHCs may continue to bill for non-behavioral health services furnished through telecommunications technology by reporting HCPCS code G2025 on the claim.

    As discussed in previous CCHP newsletters, there has been much confusion around payment for FQHC/RHC non-behavioral health services via telecommunications technology post-waiver expiration, as previous iterations of the CMS FAQ document stated that RHCs and FQHCs could continue to bill for non-behavioral health services furnished through telecommunications technology by reporting HCPCS code G2025 on the claim through September 30, 2025. However, the updated FAQ makes clear that FQHCs/RHCs can continue billing for non-behavioral health services delivered through telecommunications technology by reporting HCPCS code G2025 on the claim through December 31, 2025. It is crucial to emphasize that this new update to the FAQ confirms information supplied by CCHP in previous newsletters and materials and remains consistent with prior CMS 2025 Physician Fee Schedule (PFS) policy and other related documentation.

    It is also important to highlight that CMS included an additional extension of this FQHC/RHC policy to continue allowing non-behavioral health services billing through December 31, 2026, in the proposed 2026 PFS. If that proposal is finalized (typically in November), FQHC/RHC telecommunications allowances may be further protected in the absence of renewed legislative waivers. For more information on the proposed 2026 PFS, see CCHP’s fact sheet.

    Telehealth Behavioral Health Services In-Person Visit Requirements

    The updated CMS FAQ states:

    Q5: Will in-person visit requirements apply to behavioral health services furnished by professionals through Medicare telehealth? What about behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, or behavioral health visits furnished by RHCs, and FQHCs where the patient is present virtually?

    A5: Yes, as was finalized in the CY 2022 PFS, payment for behavioral health services furnished through certain telecommunications technology while the patient is at home may be made only if the physician or practitioner has furnished an item or service in-person to the patient, without the use of telehealth, for which Medicare payment was made (or would have been made if the patient were entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6 months prior to the initial telehealth service. After the first mental health telehealth service in the patient’s home, there must be an in-person, non-telehealth service within 12 months of each mental health telehealth service—but to allow for limited exceptions to the requirement. These in-person visits may be performed by a physician or practitioner of the same specialty within the same group practice as the physician or practitioner who furnishes the telehealth service, if the physician or practitioner who furnishes the telehealth service is not available. 

    While section 1834(m) of the Act requires an in-person, non-telehealth visit within 6 months prior to the first mental health telehealth service, we do not believe this requirement applies to beneficiaries who began receiving mental health telehealth services in their homes prior to October 1, 2025. In other words, if a beneficiary began receiving mental health services on or before September 30, 2025, then they would not be required to have an in-person visit within 6 months; rather, they will be considered established and will instead be required to have at least one in-person visit every 12 months.

    Regarding behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, we are continuing to align our policy with requirements for Medicare telehealth services billed under the PFS. In the CY 2025 PFS final rule, we finalized that for behavioral health visits furnished by RHCs and FQHCs where the patient is present virtually, we are delaying in-person visit requirements at least until January 1, 2026.

    It had previously been unclear how CMS would potentially apply the now in effect (in the absence of the legislative waiver) in-person behavioral health requirements to telehealth patients established prior to September 30, 2025. This updated guidance confirms that the initial 6-month in-person requirement will not be required for already established telehealth patients (established prior to September 30, 2025), however the one in-person visit every 12 months thereafter requirement will continue to apply.

    Additionally, there was confusion about how the separate in-person visit requirements applicable to FQHCs/RHCs delivering behavioral health services may apply during this post-waiver period. This updated FAQ guidance from CMS also addresses that issue, confirming that consistent with their 2025 PFS policy, FQHC/RHC behavioral health in-person visits remain waived at least until January 1, 2026.

    For more information regarding the recent expiration of Medicare telehealth waiver policies, see CMS’ updated Telehealth FAQ and review CCHP’s recent newsletters and resources regarding the return to more restrictive Medicare policies:

    CCHP Newsletters: CCHP Resources:
     

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