During the Public Health Emergency, Congress enacted several temporary measures that waived certain restrictions concerning telehealth coverage under Medicare, greatly improving health care access for Medicare patients. While these waivers have been extended several times since their adoption, it is possible they will expire in 2025.
Originally, Medicare telehealth waivers were set to expire on April 1; however, on March 11, the House of Representatives passed a continuing resolution to extend these flexibilities through September 30. The resolution is now with the Senate for consideration.
This update is encouraging for providers and patients who rely on telehealth via Medicare. It is important, though, to understand the direct and indirect impact the expiration of these waivers could have should Congress ultimately not enact this resolution.
Key Impacts If Medicare Telehealth Waivers Expire in 2025
If Congress fails to enact further extensions, Medicare telehealth policies will revert to pre-pandemic restrictions, limiting access and reimbursement options. Here’s what this could mean for Virginia:
Geographic and Site Restrictions
- Medicare coverage will require patients to be in rural areas or qualifying medical facilities to access telehealth services.
- Patients receiving telehealth at home, except for specific services, may lose Medicare coverage under standard rules.
Behavioral Health Exceptions
- Behavioral health services will remain an exception to geographic restrictions, but in-person visits will be required within six months of the first telehealth appointment and annually thereafter (unless risks outweigh benefits).
Practitioner Limitations
- Certain professionals, such as physical therapists, occupational therapists, speech-language pathologists, and audiologists, may lose Medicare reimbursement eligibility for telehealth services.
- Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) may only bill non-behavioral telehealth services through Medicare under code G2025 until March 31, 2025, unless further guidance is issued.
Audio-Only Telehealth
- Audio-only telehealth will remain available for patients unable to use video systems but under stricter conditions. Providers must use specific billing codes (e.g., 99202-99215 with appropriate modifiers) and meet Medicare’s requirements.
Cascading Effects on Virginia Providers and Patients
Without further extensions, these changes could have far-reaching effects, including:
- Reduced Access for Urban Patients: Patients in cities like Richmond or Virginia Beach may no longer qualify for telehealth coverage unless they travel to rural areas or eligible medical sites.
- Increased Health Care Inequities: Vulnerable populations, including those with limited mobility or access to transportation, may struggle to meet in-person requirements.
- Disruption for Providers: Health care professionals will need to navigate complex billing rules, adjust workflows, and address patient confusion over changing eligibility criteria.
Strategies to Mitigate Service Disruptions
To prepare for potential policy rollbacks, providers and advocates can take proactive steps to minimize disruptions:
- Educate Patients: Communicate potential changes to patients early, including location requirements and in-person visit criteria for behavioral health services.
- Adapt Workflows: Update workflows to ensure compliance with evolving billing codes and reimbursement policies.
- Leverage Extended Flexibilities: Take full advantage of the expanded telehealth flexibilities in the budget extension, which temporarily waives geographic restrictions and allows for broader originating sites.
- Advocate for Policy Change: Join telehealth advocacy efforts by engaging with policymakers to support permanent telehealth expansion.
- Stay Informed: Monitor updates from CMS, the Center for Connected Health Policy (CCHP), and organizations like VTN to stay ahead of policy developments.
The Road Ahead
The ongoing concern that these Medicare waivers could expire causes unnecessary doubt and worry among the Medicare community. A permanent fix should be put into place, and we encourage legislators to codify these flexibilities into Medicare coverage indefinitely.
Visit CCHP’s website to track the latest updates on this issue.