Telehealth Services Restrictions Effective 04/01/2025: What Healthcare Providers Need to Know

Telehealth services have played a pivotal role in healthcare delivery, especially during the COVID-19 pandemic, when they were rapidly expanded to maintain patient care while minimizing the risk of exposure. As the pandemic wanes, changes to telehealth regulations are on the horizon.

Table of Contents

Starting January 1, 2025, the Centers for Medicare & Medicaid Services (CMS) will reinstate pre-pandemic statutory limitations on telehealth services for Medicare beneficiaries, unless Congress takes action to extend or alter these provisions.

While some restrictions will return, CMS has also made efforts to preserve certain flexibilities and expand access to telehealth services where appropriate.

This article will delve into the key changes to telehealth services under the Physician Fee Schedule (PFS) for 2025, focusing on the restoration of geographic restrictions, the expansion of telehealth services, and the continued use of innovative technologies.

1. Restoration of Statutory Limitations

Starting in 2025, many of the telehealth service expansions that were implemented during the COVID-19 Public Health Emergency (PHE) will be rolled back. This includes the reinstatement of geographic and location restrictions on where services can be provided.

Previously, telehealth services were allowed to reach beneficiaries in rural and urban areas alike. In 2025, however, these services will return to being limited to rural areas or specific healthcare settings, like hospitals or certain clinics.

Additionally, the scope of practitioners who can offer telehealth services will be restricted, as it was before the PHE.

2. Expansion of Telehealth Services

Despite the return of certain limitations, CMS is finalizing plans to expand access to specific telehealth services:

Caregiver Training Services will be added to the Medicare Telehealth Services List on a provisional basis for 2025. This expansion allows for more comprehensive care for family members and informal caregivers who assist beneficiaries with daily living tasks.
PrEP Counseling and Safety Planning Interventions will also be permanently added to the Medicare Telehealth Services List, improving access to preventive care for high-risk populations.
Additionally, the suspension of frequency limitations for certain services, including inpatient visits, nursing facility visits, and critical care consultations, will continue through 2025.

3. Audio-Only Telehealth Communication

A significant change for 2025 is the expanded use of audio-only telehealth technology. Beginning January 1, 2025, Medicare will allow two-way, real-time audio-only communication technology to be used for any telehealth service provided to a beneficiary in their home.

This change allows providers to continue delivering services to patients who may not have access to video technology or prefer not to use it.

Providers must be technically capable of using interactive telecommunications systems, but the patient’s ability to engage with video technology is no longer required for reimbursement.

4. Practice Location Requirements for Telehealth

To ease the delivery of telehealth services, CMS has decided to continue permitting distant-site practitioners to use their currently enrolled practice locations instead of requiring them to list their home addresses when providing telehealth services from home.

This adjustment provides greater flexibility to healthcare professionals offering telehealth care, making it easier for them to serve Medicare beneficiaries remotely.

5. Direct Supervision via Virtual Presence

One of the more innovative changes in 2025 is the virtual supervision of healthcare providers. For certain services that require direct supervision by a physician or other supervising practitioner, CMS is permanently adopting a definition of “direct supervision” that allows this supervision to occur via real-time audio and visual telecommunications. Specifically, this will apply to:

Services provided by auxiliary personnel employed by the billing physician or supervising practitioner.
Office or outpatient visits for established patients where physical presence may not be necessary. This flexibility will be available until December 31, 2025, after which the regulations may change again. For other services that require direct supervision, CMS will continue to permit virtual supervision only through 2025.

6. Virtual Presence for Teaching Physicians

CMS has also introduced a virtual presence for teaching physicians in the context of teaching hospitals.

Teaching physicians will be allowed to have a virtual presence during services furnished with residents in clinical settings.

This applies to situations where a service is delivered virtually, such as a telehealth visit with the patient, resident, and teaching physician in separate locations.

This policy will remain in effect through December 31, 2025, helping to preserve the educational environment for residents while allowing patients to continue receiving care remotely.

Potential Risks of Telehealth Services: What Healthcare Providers Must Know

As telehealth services are set to face significant restrictions starting January 1, 2025, healthcare providers and organizations must understand the possible consequences of these changes.

If Congress does not take action to address the “policy cliff,” several key issues will arise for Medicare beneficiaries and providers, potentially disrupting critical healthcare programs. Here’s a breakdown of what this could mean:

1. Loss of Reimbursement for Home-Based Telehealth Visits

Without an extension of the telehealth provisions, Medicare beneficiaries may no longer be able to receive reimbursed telehealth visits from their homes.

As geographic and location restrictions are reinstated, many patients who currently benefit from receiving telehealth services at home could lose access to care, especially those in non-rural areas.

2. Reinstatement of Rural and Facility Restrictions

Telehealth services were expanded to urban and rural areas alike during the COVID-19 PHE, but if the policy cliff isn’t addressed, restrictions will return.

This means telehealth services will once again be limited to rural areas or specific healthcare facilities, such as hospitals and clinics, potentially leaving patients in urban areas without access to these services.

3. Potential Disruption of Critical Programs like Hospital at Home

Key healthcare initiatives, such as Hospital at Home programs, which have been pivotal in providing care to patients remotely, may face disruption if telehealth flexibility ends.

These programs rely on telehealth for monitoring and care delivery, and without ongoing support, their viability could be jeopardized.

4. Loss of Distant Site Provider Status for FQHCs and RHCs

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) have been able to serve as distant site providers for telehealth services during the PHE.

However, if the policy changes, these centers will lose the ability to provide telehealth services as distant site providers for most services, severely limiting access to care for patients in underserved areas.

5. Struggles in Sustaining Telehealth-Based Care Without Reimbursement

While the Drug Enforcement Administration (DEA) has extended flexibilities for prescribing controlled substances via telehealth until December 2025, providers may struggle to sustain telehealth care if reimbursement for these services disappears.

Many practices have grown reliant on telehealth reimbursements, and losing that funding could lead to challenges in continuing these services.

6. Urgency for Healthcare Providers to Prepare

Healthcare organizations, practices, and providers cannot afford to wait for last-minute solutions. With the clock ticking down to the March 31 deadline (or until Congress acts), it is crucial to start preparing for the potential changes.

One of the first steps is to implement a clear communication strategy to help both staff and patients understand and navigate the possible disruptions.

Conclusion: Preparing for Telehealth Service Changes in 2025

Starting January 1, 2025, many telehealth services will face restrictions, including the loss of home-based reimbursement, reinstated rural and facility limitations, and potential disruptions to programs like Hospital at Home.

FQHCs and RHCs may also lose their distant site provider status. With these changes, providers must act now to prepare.

Developing a communication strategy and contingency plans will help ensure continued care delivery and minimize disruptions.

Staying proactive will enable healthcare organizations to navigate the evolving telehealth landscape and continue providing high-quality care.