What Medicare’s 2025 Final Rule Means for Telehealth Providers
As we move toward 2025, healthcare providers across the U.S.—especially those relying on telehealth—are preparing for a significant shift in Medicare billing rules. With temporary telehealth flexibilities from the COVID-19 public health emergency set to expire on December 31, 2024, the Centers for Medicare & Medicaid Services (CMS) has released the 2025 Physician Fee Schedule (PFS) final rule, clarifying which virtual care services will still be reimbursable under Medicare starting January 1, 2025.
At Paracletos LLC, we specialize in helping independent medical practices understand and adapt to these types of regulatory changes. Here’s what you need to know about how Medicare is reshaping telehealth in 2025—and how your practice can stay compliant and financially protected.
Key Changes to Medicare Telehealth Billing in 2025
Retirement of Audio-Only Codes
CMS has aligned with the CPT® Editorial Panel in discontinuing audio-only CPT® codes 99441-99443. Instead, Medicare will recognize only one new brief virtual visit code—CPT® 98016—as separately payable, replacing HCPCS code G2012, which will be removed.Permanent Expansion for Mental & Behavioral Health
Certain behavioral and mental health services will be permanently eligible for Medicare telehealth coverage beginning in 2025. This is a major win for providers focused on mental health access and remote care delivery.Supervision Rules Extended
CMS will continue to allow real-time audio and video communication (but not audio-only) to meet direct supervision requirements for services performed virtually. This impacts how supervising physicians participate in care delivery remotely.Place of Service (POS) Codes Still Apply
Providers must continue to use:POS 02 for patients receiving care outside of their home
POS 10 for patients located in their home
Important: POS 10 continues to receive the non-facility rate, which is typically higher.
Location-Based Limitations Are Returning
One of the most impactful updates is the reinstatement of pre-pandemic geographic restrictions. Starting in 2025, Medicare will only reimburse telehealth services if the patient is located:In a Health Professional Shortage Area (HPSA)
In a rural area
Outside a Metropolitan Statistical Area (MSA)
This change will greatly affect telehealth coverage for urban and suburban populations unless Congress takes further action.
Flexibility for Physician Location
Physicians can continue to use their practice address on claims even when providing telehealth services from home, helping avoid compliance headaches.Teaching Physicians Still Go Virtual—For Now
Virtual presence rules for teaching physicians remain temporarily extended through December 31, 2025, for Medicare telehealth services only.
What Does This Mean for Your Practice?
If your practice relies on Medicare reimbursement for virtual care, the upcoming changes mean it’s time to:
Review your telehealth services against CMS’s updated list of covered procedures
Assess how geographic restrictions may affect your patient base
Update your coding and documentation processes
Ensure your billing team understands the new CPT® and HCPCS guidelines
At Paracletos LLC, we help providers transition smoothly into regulatory changes like these. From telehealth billing audits to custom consulting for medical practices, our team ensures you stay compliant and get paid.
Congress Still Has a Say
The proposed Telehealth Modernization Act of 2024 could override the reinstated location restrictions—but it remains stalled in committee as of fall 2024. Without legislative action, it’s estimated that over 85% of Medicare-covered telehealth visits could become ineligible for payment in 2025.
We encourage all providers to contact their representatives and support efforts to modernize telehealth laws. Meanwhile, having a partner like Paracletos LLC ensures your operations are ready—whatever Congress decides.
Need Help Navigating Medicare Telehealth Rules?
Let our experienced billing and compliance experts at Paracletos LLC in Boonville, NY walk you through the updates, review your current telehealth offerings, and future-proof your practice. Contact us today to schedule a free consultation.
