Telehealth Reimbursement: What Physicians Need to Know for 2025
The landscape of telehealth reimbursement continues to evolve as Medicare and commercial payers adjust their policies. With key provisions set to expire after March 31, 2025, physicians need to be aware of how these changes impact billing and payment for telehealth services. This guide provides an overview of the current rules, upcoming changes, and how to ensure proper reimbursement.
Medicare Telehealth Billing Until March 31, 2025
Through the first quarter of 2025, Medicare will continue to reimburse for telehealth services under the temporary flexibilities established during the COVID-19 public health emergency. These include:
- No Geographic Restrictions: Medicare beneficiaries can receive telehealth services from any location, including their homes.
- Expanded Provider Eligibility: All Medicare-eligible providers can furnish telehealth services.
- Audio-Only Allowances: Medicare will continue covering audio-only visits for certain services.
- Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are eligible to bill for telehealth services using HCPCS code G2025.
Billing Guidelines:
- Audio-Visual Telehealth Visits: Use standard Evaluation and Management (E/M) codes (e.g., 99202–99215) with:
- Modifier 95 (synchronous audio-video telemedicine service)
- Place of Service (POS) codes:
- 02 (telehealth provided outside the patient’s home)
- 10 (telehealth provided in the patient’s home)
- Audio-Only Telehealth Visits:
- Modifier 93 (synchronous audio-only communication)
- Documentation must justify why video was not used and detail the medical discussion exceeding 10 minutes.
Changes After March 31, 2025
Unless further legislative action is taken, several telehealth flexibilities will expire, reverting to pre-pandemic definitions:
- Geographic Restrictions Return: Medicare telehealth services will once again be limited to patients in rural areas.
- Originating Site Restrictions Reinstated: Beneficiaries will need to visit approved medical facilities (e.g., hospitals, clinics) to receive telehealth services.
- Audio-Only Services May Be Discontinued: Audio-only visits will likely no longer be reimbursed unless tied to behavioral health services.
- Provider Eligibility Changes: Some currently eligible providers may no longer be authorized to offer telehealth services.
- FQHCs and RHCs May Lose Distant Site Eligibility: These providers may no longer be able to furnish non-behavioral health telehealth services.
How to Prepare for Telehealth Reimbursement Changes
- Monitor CMS Updates: Stay informed on Medicare’s final policies for telehealth reimbursement.
- Confirm Payer-Specific Policies: Commercial insurers may maintain more flexible policies beyond March 2025.
- Ensure Proper Coding: Use the correct CPT codes, modifiers, and POS designations for accurate billing.
- Maintain Thorough Documentation: Clearly document the modality used, the necessity of the service, and time spent with the patient.
- Advocate for Policy Extensions: Engage with professional organizations and policymakers to support continued telehealth access.
Conclusion
Telehealth continues to be a vital part of healthcare delivery, but reimbursement policies remain fluid. Physicians must stay proactive in understanding Medicare and commercial payer rules to ensure they receive proper payment for telehealth services. Keeping up with policy changes and adapting billing practices accordingly will be essential in 2025 and beyond.
