Medicare Telehealth Regulations: Current Status
There have been many reports of Medicare telehealth "ending" after March 31st. Those reports have some partial truth, but not at all the full story, and include some inaccurate and incomplete information.
The bottom line is that there is no reason for panic! Read below for accurate and complete information on current situation, and what to expect. These facts have been verified by direct contacts at CMS.
Many of you may notice that some of the information here looks familiar. That is because the situation now is essentially the same as in December 2024, when I sent out an alert about this same issue.
The Facts on the Ground
- There could be a number of changes coming after March 31st for some aspects of Medicare telehealth. That would include an end to telehealth for medical services for the most part.
- But those overall changes do NOT apply to behavioral health. Medicare regulations now ensure telehealth allowances for BH to continue permanently, to include both video and audio-only.
- The changes that could possibly be coming for BH are: requirements for one in-person visit during the first 6 months of treatment, and once every 12 months after that.
- These changes may still be reversed through Congressional action before March 31st, as happened at the last minute in December, when the same changes were set to be enacted.
- Even if these in-person requirements do go through, there are exceptions built into the regulations, at least for the 12-month requirement, which "must be documented in the patient’s medical record noting a reason of the exception (such as a travel hardship, or unavailability of providers or patients in scheduling)."
- There is not yet information on any more specifics for how exceptions would be determined or documented, and how enforcement on this overall.
- There are not exceptions in the regulations for the in-person visit in first six months for new clients. As I understand it, that would not apply for ongoing clients. But, it could be a factor for new clients, so it seems advisable to take that into consideration for new clients after April 1st, if this goes into effect.
What You Can Do
- You can reach out to your federal Senators and Representative to express your support for extension of Medicare telehealth allowances. There is not yet a template established for this, but you can simply call or email with your thoughts. You can use the link below to find your congressional legislators and their contact information
- Watch for announcements from NASW for updates. These changes may well be averted over the next month.
- Start to be planful to be ready if changes do go through. For ongoing clients, consider how to potentially arrange for an in-person visit within next 12 months. That could include a home visit or meeting at a location other than an office. For others, consider how to document reasons that in-person visits are not possible.
- In the event that changes do move forward, be ready to consider carefully any new Medicare telehealth cases, and whether it could be feasible to arrange an in-person visit during first 6 months of treatment.
NASW-RI and MA are following closely, and will be posting updates on this topic through alerts, notices to our website, social media, postings to the Private Practice Google Group, listings in the monthly Chapter E-News, etc.