A Turning Point for Virtual Care
Over the past few years, telehealth has evolved from a stopgap measure into a core part of care delivery. During the COVID-19 public health emergency (PHE), CMS granted broad temporary flexibilities—allowing Medicare patients to receive care from home, expanding the list of eligible providers, and even reimbursing audio-only visits.
These changes fueled a telehealth boom that not only improved access to care but also opened new business models for providers. But now, with the pandemic in the rearview mirror, many of those flexibilities are set to expire—unless Congress acts again. The year 2025 will be pivotal for anyone who relies on virtual care.
What’s Changing in 2025—and What’s Not
What’s Staying (Through December 31, 2024)
Thanks to legislation passed under the Consolidated Appropriations Act of 2023, several key flexibilities remain in place through the end of this year:
- Geographic Restrictions Waived: Medicare will continue covering telehealth for patients in any location, including their homes.
- Home as an Originating Site: Patients don’t have to be in a clinic or facility to qualify.
- Expanded Provider Eligibility: Physical therapists, occupational therapists, speech-language pathologists, and audiologists are still allowed to provide virtual care.
- FQHCs and RHCs can serve as distant site providers.
- Audio-Only Mental Health Services are permanently allowed under certain conditions.
But unless Congress intervenes again, these policies will sunset on January 1, 2025.
? Source: CMS MLN901705 – Pages 2–3
? HHS Telehealth Policy Updates
What Could Expire in 2025 Without New Legislation
If nothing changes legislatively:
- Geographic Restrictions Return: Only patients in rural areas will be eligible for most Medicare-covered telehealth.
- Facility Requirements Reinstated: The patient must be physically located in an eligible originating site (like a clinic or hospital).
- Home-Based Telehealth Ends: Most care delivered from home would no longer be reimbursable under traditional Medicare.
- Provider Eligibility Shrinks: PTs, OTs, SLPs, and other non-physician providers could lose their ability to offer telehealth services.
- FQHCs and RHCs may no longer qualify as distant site providers.
These policies don’t change automatically—CMS is bound by law and cannot extend them on its own. It’s up to Congress to decide whether these expanded flexibilities remain in place.
Remote Patient Monitoring (RPM) in 2025
Unlike telehealth, Remote Patient Monitoring (RPM) is regulated under a different framework and is expected to remain intact into 2025.
Here’s what you need to know:
- Still Reimbursable: RPM services (CPT codes 99453–99458) remain covered under Medicare.
- 16-Day Rule Applies: Most RPM programs require at least 16 days of data over a 30-day period.
- Established Patient Relationship Required: You can’t bill RPM for new patients unless certain conditions are met.
- Must Be Ordered by a Physician or Qualified Health Provider: Direct-to-consumer RPM services won’t qualify unless managed appropriately.
? Source: CMS MLN901705 – Pages 6–7
What Healthcare Businesses Should Do Right Now
With potential changes looming, businesses that have built services around telehealth—especially those serving Medicare patients—should begin preparing now.
1. Stay Informed on Congressional Activity
Keep tabs on legislation that could extend these telehealth flexibilities. CMS cannot make these policies permanent on its own—only Congress can.
2. Plan for Two Scenarios
Don’t get caught off guard. Develop an operational strategy for both outcomes:
- If telehealth flexibilities are extended, continue investing in virtual care infrastructure.
- If they’re rolled back, plan for transitions to in-person care for impacted patients.
3. Diversify Your Payer Mix
Many commercial insurers, Medicaid plans, and Medicare Advantage organizations will continue supporting telehealth. Focus growth efforts where policies are more stable.
4. Bolster Hybrid Care Models
Even if telehealth is limited under Medicare, digital tools like intake forms, care coordination, and follow-up messaging still offer value. Build a flexible care experience that doesn’t rely entirely on real-time video visits.
5. Educate Your Patients and Staff
Most patients assume telehealth is permanent. It’s not. Start setting expectations early—especially with your Medicare population.
Final Thoughts: Prepare for a Crossroads
The uncertainty surrounding 2025 is real. For some healthcare businesses, especially digital-first or RPM-enabled practices, this could be a make-or-break year.
That said, change also brings opportunity. The organizations that prepare now—by watching policy updates, educating patients, and retooling their workflows—will be in the best position to succeed no matter what happens in Washington.
? References
- CMS MLN901705 – Telehealth & Remote Patient Monitoring (March 2024)
Download PDF - HHS Policy Tracker – Telehealth Policy Updates
