Telehealth Updates Under Medicare and Medicaid
(Feb. 24, 2025) The Centers for Medicare and Medicaid Services (CMS) has updated its website to notify the public that COVID-era telehealth waivers are scheduled to expire on March 31, 2025. The update notes that starting April 1, 2025, CMS policy reverts to pre-COVID rules. At the same time, NYS has announced recent updates to its Medicaid telehealth policies, clarifying and expanding upon the use of telehealth for various services.
Medicare Flexibilities Expiring April 1st Absent Congressional Action
Under the policies in place since March 2020, telehealth is currently available to Medicare beneficiaries in both urban and rural areas, and patients can receive telehealth services from any “originating site,” including their home. Prior to the expansion, telehealth coverage in traditional Medicare was limited to rural areas (with certain exceptions), and patients were required to travel to an approved originating site, such as a clinic, a nursing home, or a doctor’s office, in order to receive telehealth services. In December, these flexibilities and others were extended until March 31, 2025.
If Congress does not pass legislation that extends the current flexibilities by March 31st, providers of Medicare Part B telehealth services will not be able to bill for services provided to patients who are not in approved originating sites. In addition, geographic restrictions for originating sites will be reinstated. For example, Part B reimbursement will not be available for telehealth visits to patients who are in their homes at the time of the visit or to patients who are not in a rural area regardless of the setting of the clinical visit. Audio-only telehealth billing will likewise end without action from Congress. Although the updated CMS webpage does not mention hospice recertification visits, it appears that face-to-face recertifications will be required as of April 1st as well, in the absence of congressional action.
Notably, these provisions apply to services provided to Medicare beneficiaries in Original (fee-for-service (FFS)) Medicare. Medicare Advantage plans and some accountable care organizations (ACOs) may have different rules around telehealth coverage and billing.
Behavioral and mental health providers will still be able to bill Medicare for patients receiving behavioral/mental health care in their homes. Moreover, there are no geographic restrictions for originating site for behavioral/mental telehealth services. Behavioral/mental telehealth services can also be delivered using audio-only communication platforms.
Although Congress still has time to act, LeadingAge National recommends that members make a plan for reversion to pre-COVID rules related to telehealth in the event that there is no extension of the current waivers.
A link to CMS Frequently Asked Questions (FAQ) on telehealth can be found here.
NYS Medicaid Telehealth Policy Manual Update
In the December Medicaid Update, released last week, the NYS Department of Health (DOH) announced its approval of updates to the Medicaid program's Telehealth Policy Manual. The information in the manual applies to all NYS Medicaid-enrolled providers and Medicaid Managed Care (MMC) plans. Updates to the manual include:
- Section 4.8: Clarified when audio-only telehealth is appropriate.
- Section 9.6: Edited audio-only billing guidance.
- Section 9.8: Clarified remote patient monitoring (RPM) policy and added guidance for RPM delivered by clinical staff.
- Section 9.10: Updated procedure code for virtual check-ins.
- Section 9.12: Clarified virtual patient education billing guidance for Community Health Worker and Asthma Self-Management Training services.
- Section 9.14: Clarified eConsult policy, added guidance for eConsults in the dental setting, and added guidance for Ambulatory Patient Group reimbursement.
- Section 9.15: Added guidance for Home Sleep Tests.
- Section 9.16: Clarified Article 28 Federally Qualified Health Center billing.
- Section 10.7: Added restriction for doula services via telehealth.
- Section 10.8: Added restriction for shipment of physician-administered drugs.
Questions may be directed to DOH as follows:
- NYS Medicaid FFS billing and claims questions should be directed to the eMedNY Call Center at 800-343-9000.
- NYS Medicaid FFS telehealth coverage and policy questions should be directed to the Office of Health Insurance Programs Division of Program Development and Management by telephone at 518-473-2160 or by email at telehealth.policy@health.ny.gov.
- MMC enrollment, reimbursement, billing, and/or documentation requirement questions should be directed to the specific MMC plan of the enrollee.
Contact: Karen Lipson, klipson@leadingageny.org