Telehealth Updates

Beginning October 1, 2025, if congress does not act, many of the statutory limitations that were in place for Medicare telehealth services, prior to the COVID-19 Public Health Emergency, will take effect again for services that are not behavioral and mental health services.

• Including prohibition of many services provided to beneficiaries in their homes, outside of rural areas and hospice recertifications that require a face-to-face encounter.
  • These restrictions may impact requirements for meeting continued eligibility for other Medicare benefits.
• Practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, should evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage.
• Practitioners may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of Congressional action. .
• For further information: https://www.cms.gov/medicare/coverage/telehealth.

ACOs and Telehealth Services

• CMS notes that the Bipartisan Budget Act of 2018 allows clinicians in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) to provide and receive payment for covered telehealth services to certain Medicare beneficiaries
• There is no special application or approval process for applicable ACOs or their ACO participants or ACO providers/suppliers.
• Clinicians in applicable ACOs can provide these covered telehealth services and bill Medicare for the telehealth services that are permissible under Medicare rules during CY 2025, irrespective of further Congressional action.

Further information can be found at:

https://www.cms.gov/files/document/shared-savings-program-telehealth-fact-sheet.pdf

Michele Krpata, BSW, CPC, CPMA

Compliance Officer, Quality Reporting Analyst

Integrated Physicians Management Services