April 2025 CMS Telehealth Update

The CMS telehealth extension has been a rolling story since the pandemic.

CMS first used emergency waivers to allow telehealth use without abiding by CMS’s long-standing telehealth restrictions (rural-only, in-office originating sites, lower audio-only rates) in 2020, then Congress locked in a 151-day grace period after the Public Health Emergency ended on May 11th, 2023, by way of the Consolidated Appropriations Act (CAA) in 2022. That window carried the video and audio-only flexibilities through October 9th, 2023. A year later, Congress then stretched the waiver to December 31st, 2024 and told CMS to keep paying home-based visits at the higher non-facility rate.

By early 2025 the clock was ticking again. The American Relief Act pushed the sunset to March 31st, 2025, but Congress still needed more time to craft a long-term fix. On March 15th, 2025, lawmakers passed H.R. 1968, a stop-gap spending bill that tacked another six months onto the CMS telehealth extension. All key waivers (no geographic limits, FQHC/RHC distant-site billing, audio-only coverage, therapy and hospice telehealth) now last until September 30th, 2025.

What stays in place through Sept 30

• No geographic “originating-site” limits for non-behavioral visits; patients can connect from home.

• Audio-only visits remain billable for non-behavioral services.

• FQHCs/RHCs may keep acting as distant-site providers for non-behavioral care.

• PT, OT, SLP and audiology services stay on the telehealth list.

• Telehealth may continue to satisfy the hospice re-cert face-to-face.

Additional flexibilities through Dec 31

• “Virtual” direct supervision (audio-video) for incident-to services.

• Schedule II–V controlled-substance prescribing without a prior in-person visit.

What did not change

• Payment rates follow the 2025 Physician Fee Schedule; no new parity mandate.

• The waivers still end unless Congress acts again. CMS has not promised automatic extensions.

What you need to know

1. Keep billing exactly as you have since the PHE ended. No new modifiers, POS codes, or consent language are required today.

2. Flag September 30th on your calendar. Build a 90-day look-back in July to gauge telehealth volume at risk if waivers lapse.

3. Update patient messaging. Let Medicare patients know nothing changes for them until at least October.

4. Refresh cheat sheets for staff. Reinforce that POS 02 (outside home) and POS 10 (home) still drive commercial claims in Texas.

5. Track contracts. Some plans tie their telehealth rules to CMS dates; others bake them into policy. Ask your network reps for their post-Sept 30 stance now.

Looking forward: impact on commercial televisits

• Short-term stability. Most large commercial payers, especially those with Medicare Advantage lines, shadow CMS to reduce administrative friction. Expect current coverage to hold through at least Q3 2025.

• Possible Q4 2025 divergence. If Congress lets the waivers expire, insurers gain room to re-impose pre-COVID rules (rural-only, in-office originating sites, lower audio-only rates). Plan manuals typically update each January; watch 2026 policy drafts closely.

• Parity pressure. Forty-plus states now have some form of private-payer telehealth parity, but not all require equal pay. Insurers could keep telehealth but drop payment to office-visit minus facility overhead.

Stay tuned. We’ll update you the moment Congress signals its next move.