Telehealth is an important part of modern healthcare delivery, offering unprecedented convenience and accessibility for patients and providers. Recognizing its critical role, the federal government has once again extended key telehealth flexibilities through March 31, 2025, under Section 3207 of the American Relief Act, 2025. This extension modifies Section 1834(m) of the Social Security Act and ensures that healthcare providers can continue delivering care with the same flexibility as in 2024.
The announcement, released by National Government Services (NGS) on January 9, 2025, outlines continued waivers on geographic, site of service, and practitioner type restrictions, among other provisions. Here’s what healthcare providers need to know about these changes, their implications, and how to optimize their telehealth practices during this period.
Key Provisions of the Extension:
Geographic Flexibility
The traditional telehealth model restricted services to non-metropolitan statistical areas (non-MSA), effectively limiting access for patients in urban and suburban settings. Under the extended waiver, geographic restrictions are entirely removed.
This means patients can receive telehealth services irrespective of their location—whether in rural areas, cities, or suburban neighborhoods. This move significantly expands access to care, enabling providers to reach a broader patient population.
Site of Service
Patients are no longer required to visit an approved originating site, such as a clinic or hospital, to receive telehealth services. The waiver allows patients to access telehealth directly from their homes, not only for behavioral health services but for all other covered services.
This provision addresses long-standing barriers to telehealth adoption, including travel challenges, childcare concerns, and work-life conflicts. For patients with mobility issues or chronic conditions, home-based telehealth is a transformative option.
Practitioner Flexibility
Another critical extension eliminates practitioner-type restrictions. Healthcare professionals across disciplines can deliver telehealth services, provided they are qualified to perform the services in question.
From primary care physicians and nurse practitioners to physical therapists and specialists, this provision ensures a diverse range of providers can meet patient needs through telehealth.
Behavioral Health Waivers
Behavioral health remains a top priority under the extension. Waivers continue to exempt providers from requiring in-person visits within six months before initiating telehealth services and every 12 months thereafter.
This flexibility is vital for maintaining continuity of care, especially for patients managing mental health conditions who may face barriers to in-person visits. Behavioral health providers can focus on delivering care remotely without the administrative burden of scheduling in-person evaluations.
Why These Extensions Matter
Expanding Access to Care: Removing geographic and site-of-service restrictions allows providers to address disparities in healthcare access. Rural patients, urban residents with limited mobility, and individuals with demanding schedules can all benefit from equitable access to telehealth services.
Supporting Public Health Goals: The COVID-19 pandemic underscored the importance of telehealth in reducing disease transmission. While the immediate threat of the pandemic has receded, these flexibilities support broader public health goals, including managing chronic diseases, addressing behavioral health crises, and promoting preventive care.
Enhancing Provider Efficiency: For healthcare providers, these extensions simplify workflows and enable seamless integration of telehealth into practice. By eliminating practitioner-type restrictions and streamlining site-of-service rules, providers can focus on delivering quality care rather than navigating regulatory hurdles.
Driving Innovation: Providers can explore new telehealth models, such as group therapy sessions, chronic disease management programs, and virtual physical therapy, to meet evolving patient needs.
Considerations for Providers
Billing and Coding: To take full advantage of these flexibilities, providers must stay informed about billing and coding requirements. National Government Services has confirmed that claims for services provided between January 1, 2025, and March 31, 2025, will be processed using the same guidelines as in 2024.
It’s essential to use appropriate modifiers and codes to avoid claim denials. Examples include the 95 modifier for synchronous telehealth services and the POS 10 code for telehealth provided in the patient’s home. Providers should regularly review payer updates to ensure compliance.
Technology and Security: Providers must maintain HIPAA-compliant telehealth platforms to safeguard patient privacy. While enforcement discretion during the pandemic allowed for more flexible technology use, it’s unclear if similar leniency will continue. Investing in secure, reliable telehealth systems is a critical step for long-term success.
Patient Engagement: Educating patients about telehealth options and addressing their concerns about technology or quality of care is vital. Providers should offer clear instructions on accessing telehealth services, troubleshoot technical issues proactively, and ensure that patients feel confident in the quality of remote care.
Documentation: Accurate documentation remains a cornerstone of telehealth practice. Providers should clearly record the location of the patient and provider, the type of service delivered, and any modifiers used for billing. Comprehensive records not only support compliance but also enhance care continuity.
Challenges to Watch
Post-March 2025 Uncertainty: The extension through March 31, 2025, provides a temporary reprieve, but questions remain about the long-term status of these flexibilities. Providers should advocate for permanent legislative changes that solidify telehealth as a standard mode of care delivery.
Reimbursement Parity: While most payers currently offer parity for telehealth and in-person services, reimbursement policies could evolve after the waiver period. Staying updated on payer-specific policies is essential to mitigate financial risks.
Digital Divide: Despite the widespread adoption of telehealth, disparities in technology access persist. Patients without reliable internet or devices may struggle to engage in virtual care, highlighting the need for continued investment in digital infrastructure.
Steps to Optimize Telehealth Practices
- Train Your Team
Equip your staff with the knowledge and skills needed to deliver effective telehealth care. This includes training on technology use, telehealth etiquette, and compliance with regulatory requirements.
- Evaluate Your Technology
Ensure your telehealth platform is user-friendly, secure, and capable of handling high patient volumes. Regularly update software and test systems to minimize disruptions.
- Focus on Patient Experience
Delivering exceptional telehealth experiences is critical for patient retention. Personalized care, seamless scheduling, and responsive technical support can set your practice apart.
- Monitor Outcomes
Track key performance indicators (KPIs) such as patient satisfaction, visit completion rates, and health outcomes to assess the impact of telehealth on your practice.
- Advocate for Change
Join industry organizations advocating for permanent telehealth policies. Provider voices are instrumental in shaping the future of virtual care.
Telehealth is poised to remain an integral part of care delivery. The extended flexibilities through March 2025 represent a crucial step in solidifying its role.
While uncertainties remain, proactive planning, investment in technology, and patient-centered strategies will position providers for success in the years ahead. The time is now to embrace telehealth as a permanent fixture in modern healthcare.
We’ve prepared a handy cheat sheet for you, which you can download and save for quick reference whenever you need it. Download it here: https://insights.wchsb.com/2025/01/06/medicare-telehealth-2025-the-new-era-of-remote-care/
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