Telehealth: Post-September 30, 2025 Requirements and Restrictions 

The integration of telehealth and remote patient monitoring (RPM) has reshaped healthcare delivery, offering physicians powerful tools to enhance patient care. However, the regulatory landscape is shifting. The American Medical Association’s 2024 telehealth guidelines, extended through Sept. 30, 2025, by the Full-Year Continuing Appropriations and Extensions Act, will see significant changes as pre-COVID-19 public health emergency (PHE) restrictions return for most services.  

Telehealth After Sept. 30, 2025: A Return to Pre-PHE Restrictions 

The COVID-19 PHE, which ended on May 11, 2023, prompted temporary waivers that expanded telehealth access. These flexibilities, extended through Sept. 30, 2025, allowed patients to receive services from any location, eliminated geographic restrictions, and broadened provider eligibility. However, starting Oct. 1, 2025, most non-behavioral and non-mental health telehealth services will revert to pre-PHE statutory limitations, significantly impacting how physicians deliver care. 

Key Restrictions Post-September 30, 2025 

Originating Site Requirements: For non-behavioral and non-mental health services, patients must receive telehealth at designated originating sites, such as hospitals, rural health clinics, or federally qualified health centers (FQHCs), located in specific geographic areas (typically rural or underserved). The flexibility to provide services to patients at home will end, except for behavioral and mental health services. 

Geographic Restrictions: Telehealth services will be limited to patients in rural or underserved areas, excluding urban and suburban patients unless they travel to an eligible originating site. This reinstates pre-PHE barriers to access. 

Provider Eligibility: Only specific types of providers, as defined by pre-PHE Medicare rules, will be eligible to bill for distant site telehealth services, reducing the pool of practitioners who can deliver remote care. 

Technology Requirements: Two-way, interactive audio-video technology will be mandatory for most non-behavioral and non-mental health services. Audio-only telehealth, permitted through Sept. 30, 2025, for patients at home who cannot or do not consent to video, will no longer be covered after this date, except for behavioral and mental health services. 

FQHCs and RHCs: After Dec. 31, 2025, FQHCs and RHCs will lose their ability to serve as distant site providers for non-behavioral and non-mental telehealth services, though they can continue for behavioral and mental health services. Payments for non-behavioral services under the Physician Fee Schedule (PFS) will also end by Dec. 31, 2025. 

Exceptions for Behavioral and Mental Health Services 

Behavioral and mental health telehealth services are permanently exempt from many of these restrictions. Patients can continue receiving these services from their homes without geographic or originating site requirements. Audio-only communication is also permanently allowed when patients are at home, ensuring equitable access for those with limited technology. However, starting Jan. 1, 2026, FQHCs and RHCs must conduct an in-person visit within six months of an initial behavioral or mental health telehealth service and annually thereafter. 

Other Temporary Extensions 

Direct Supervision: Through Dec. 31, 2025, supervising physicians can provide virtual oversight using real-time audio-visual technology. For a subset of services, this virtual supervision model is permanent. After 2025, CMS has not clarified whether this will continue, so physicians should monitor future rulemaking. 

Teaching Settings: Through Dec. 31, 2025, teaching physicians can bill for services involving residents with a virtual presence in clinical situations (e.g., three-way telehealth visits). Post-2025, traditional in-person supervision may resume unless extended. 

Controlled Substances: The Drug Enforcement Administration (DEA) has extended flexibilities for prescribing controlled substances via telehealth through Dec. 31, 2025. After this, providers must comply with stricter in-person evaluation requirements unless new regulations are issued. 

Remote Patient Monitoring: Continuity and Constraints 

RPM, encompassing remote physiological monitoring (e.g., blood pressure, oxygen saturation) and remote therapeutic monitoring (RTM), remains a critical tool for managing chronic conditions. Post-September 30, 2025, RPM regulations are largely unaffected by telehealth restrictions, but physicians must adhere to specific requirements to ensure compliance and reimbursement. 

RPM Requirements 

Established Patient Relationship: Remote physiological monitoring requires an established patient relationship, while RTM does not. 

Eligible Providers: Only physicians and non-physician practitioners eligible to bill evaluation and management services can provide RPM. 

Data Collection: Physiological monitoring requires data collection for at least 16 days in a 30-day period, except for treatment management codes (99457, 99458, 98980, 98981). 

Billing Restrictions: Only one practitioner can bill RPM per patient per 30-day period, and physiological monitoring and RTM cannot be billed together. Concurrent billing with care management services (e.g., chronic care management) is allowed if time and effort are not double-counted. 

Medical Necessity: Monitoring must be medically reasonable and necessary, with data collected electronically via FDA-approved medical devices. 

Consent: Patient consent is required at service initiation, obtainable by auxiliary personnel under general supervision. 

RPM Billing Codes 

Key RPM CPT and HCPCS codes, which remain unchanged post-September 30, 2025, include: 

99091: 30-minute monthly data review. 

99453: Initial setup and monitoring. 

99454: Monthly review of data collected over 16+ days. 

99457, 99458: 20-minute and additional 20-minute patient-provider communication, respectively, with audio-only coverage. 

98975–98981: RTM codes for setup, monitoring (respiratory or musculoskeletal), and communication. 

Billing and Payment Post-September 30, 2025 

Accurate billing is essential to avoid audits and ensure reimbursement. After Sept. 30, 2025, physicians must adapt to stricter telehealth billing requirements: 

Place of Service (POS) Codes: Use POS 02 for telehealth provided outside the patient’s home and POS 10 for home-based telehealth (primarily for behavioral and mental health). Non-facility PFS rates apply for home-based services. 

Modifiers: Use modifier 95 for outpatient therapy services via telehealth by qualified therapists. For asynchronous telehealth in Alaska or Hawaii federal demonstrations, add the GQ modifier. 

Originating Site Facility Fee: Bill HCPCS code Q3014 for the originating site fee, set at $31.04 for CY 2025 (3.6% Medicare Economic Index increase). This applies only to designated originating sites. 

Home Health Claims: Report telehealth usage with HCPCS codes G0320 (synchronous audio-video), G0321 (audio-only), and G0322 (RPM). These must be documented in the medical record and reported with specific revenue codes (042x, 043x, 044x, 055x, 056x, 057x). 

For RPM, physicians must document medical necessity and ensure data is collected using FDA-approved devices. Billing errors, such as double-counting time with care management services, can lead to claim denials. 

Strategic Implications for Physicians 

The return of pre-PHE restrictions after Sept. 30, 2025, poses challenges but also opportunities for physicians to refine their telehealth and RPM strategies. Key considerations include: 

Technology Investment: Ensure platforms support HIPAA-compliant audio-video communication, as audio-only options will be limited to behavioral and mental health services. 

Patient Education: Prepare patients for the loss of home-based telehealth for non-behavioral services, emphasizing the need to visit originating sites. Promote RPM for chronic care to maintain continuity. 

Staff Training: Educate clinical and administrative teams on updated billing codes, documentation, and consent processes to avoid reimbursement issues. 

Advocacy: Support legislative efforts, such as the CONNECT for Health Act, to permanently extend telehealth flexibilities. The AMA and other stakeholders are pushing for these changes to ensure continued access. 

Monitor DEA Regulations: With telehealth prescribing flexibilities expiring Dec. 31, 2025, stay updated on DEA proposals, such as special telemedicine registrations, to maintain access to controlled substances. 

Post-September 30, 2025, telehealth and RPM will face significant regulatory changes, with non-behavioral and non-mental health services reverting to pre-PHE restrictions. Physicians must adapt to originating site and geographic limitations while leveraging permanent flexibilities for behavioral and mental health care. RPM remains a robust tool for chronic disease management, with consistent billing and operational requirements.  

References 

American Medical Association (AMA) Telehealth and Remote Patient Monitoring Guidelines, 2024. 

Centers for Medicare & Medicaid Services (CMS), Calendar Year 2025 Medicare Physician Fee Schedule. 

National Consortium of Telehealth Resource Centers, “The Telehealth Policy Cliff: Preparing for October 1, 2025.” 

Drug Enforcement Administration (DEA) and Substance Abuse and Mental Health Services Administration (SAMHSA), Telemedicine Flexibilities Extension through 2025. 

*Disclaimer: The information presented herein regarding telehealth and Remote Patient Monitoring (RPM) regulations effective after Sept. 30, 2025, is based on current knowledge of CMS, AMA, and DEA guidelines as of May 13, 2025. Please be aware that regulatory interpretations and guidelines may evolve, and readers are encouraged to verify critical information with official sources.