Earlier last month, a bipartisan bill was introduced to “make expanded access to telehealth services permanent,” indicating the important role telehealth plays in the lives of most Americans in a post-COVID environment¹. While telehealth has undergone significant transformations in recent years, this trend is set to continue with several key changes on the horizon.  These changes are driven by evolving policies, technological advancements, and shifting healthcare needs.

Here is a brief look at what healthcare organizations can expect in the near future, and specifically on April 1, 2025:

New telehealth codes

Starting April 1st, the following new telehealth codes will be implemented

• 98000–98007: Synchronous audio-video visits for new or established patients
• 98008–98011: Synchronous audio-only visits for new patients
• 98012–98014: Synchronous audio-only visits for established patients
• 98016: Brief synchronous communication technology service
• The original audio-only telemedicine codes (99441–99443) were deleted effective January 1, 2025¹.

Extended Telehealth Flexibilities

Medicare patients can continue to receive telehealth services for non-behavioral/mental health care in their homes through March 31, 2025². This extension ensures that patients, especially those in rural areas, have continued access to essential healthcare services.

Regulatory Changes

A 60-day regulatory freeze has introduced uncertainty into the telehealth marketplace, affecting pending Drug Enforcement Administration (DEA) regulations regarding virtual prescribing of controlled substances³. This impacts mental health providers and pain management specialists who rely on telehealth for their practice.

Behavioral and Mental Health Services

Telehealth has proven to be a valuable tool for delivering behavioral and mental health services. Recent policy updates have made it easier for patients to access these services without the need for in-person visits². This is particularly beneficial for individuals in remote areas or those with mobility issues.

Reimbursement and Financial Planning

The delay in finalizing telehealth reimbursement policies creates uncertainty for healthcare providers who have invested in telehealth infrastructure based on pandemic-era waivers³. Providers will need to navigate this regulatory ambiguity while maintaining compliance and ensuring financial sustainability.

The BlueStone Medical Business Advisory Team has provided some best tips and best practices on how to navigate and protect your healthcare organization from any compliance or financial repercussions from these upcoming changes.

• Audit Current Telehealth Utilization: Identify which services and patients will be affected if the flexibilities expire².
• Train Providers and Staff: Make sure everyone is aware of the new documentation and compliance requirements².  Modality and Location temporary flexibilities will change, meaning services will be more regulated to ensure quality and integrity¹.  However, there will continue to be certain exceptions, and staying up to date on these exceptions will be critical to ensure your organization remains compliant.
• Update Scheduling Systems: Incorporate any new in-person visit requirements into your scheduling processes².  Organizations may want to use the Medicare Telehealth payment Eligibility Analyzer Medicare Telehealth Payment Eligibility Analyzer ⁴ to help determine patient eligibility for Telehealth services⁵.  Additionally, it would be prudent to notify and cancel appointments for any patients who may be affected by the new telehealth rules and who already have appointments scheduled after March 31^st1.
• Revise Patient Consent Forms and Education Materials: Ensure that all documentation reflects the new requirements and educate patients about the upcoming changes².  CMS Templates of an Advance Beneficiary Notice of Non-coverage (ABN) are available at FFS ABN | CMS ⁶.
• Evaluate Telehealth Technology Platforms: Check that your technology platforms can meet the new compliance standards⁷.
• Model Financial Impact:   Billing for any services retroactively in the event a waiver is granted after the 31^st of March will not be possible¹.  In addition, the likelihood of commercial payors adopting the same restrictions as Medicare is quite high.  Therefore, assessing how the changes will affect your practice financially and proper planning is critical to support financial stability⁷.

 

For complete details on all the upcoming changes, we highly recommend checking out the following:   The Telehealth Policy Cliff: Preparing for April 1, 2025 | National Consortium of Telehealth Resource Centers

It’s essential for practices to get ready for the upcoming changes in telehealth policies, even though these policies are still evolving. While we advise preparing for these changes, immediate implementation isn’t necessary at this moment. The BlueStone Medical Business Advisory Team will keep you informed about any updates as they occur, so please stay tuned.  However, by taking these proactive steps, physicians can better navigate the transition and continue to provide quality care to their patients.

If you have any specific concerns or need further assistance, do not hesitate to reach out to the BlueStone Medical Business Advisory Team for guidance on how to adapt and navigate these upcoming changes in the evolving telehealth environment.

¹National Consortium of Telehealth Resource Centers. (n.d.). The telehealth policy cliff: Preparing for April 1, 2025. Telehealth Resource Center. Retrieved March 3, 2025, from https://telehealthresourcecenter.org/resources/the-telehealth-policy-cliff-preparing-for-april-1-2025/

²U.S. Department of Health and Human Services. (n.d.). Telehealth policy updates. Telehealth.HHS.gov. Retrieved March 3, 2025, from https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-policy-updates

³Center for Telehealth & e-Health Law. (n.d.). The recent executive orders’ impact on telehealth policy: What you need to know. CTel. Retrieved March 3, 2025, from https://www.ctel.org/breakingnews/the-recent-executive-orders-impact-on-telehealth-policy-what-you-need-to-know

⁴Health Resources and Services Administration. (n.d.). Medicare Telehealth Payment Eligibility Analyzer. Retrieved from https://data.hrsa.gov/tools/medicare/telehealth

⁵Health Resources & Services Administration. (n.d.). Medicare Telehealth. HRSA Data. Retrieved March 3, 2025, from https://data.hrsa.gov/tools/medicare/telehealth

⁶ Centers for Medicare & Medicaid Services. (n.d.). Fee-for-Service Advance Beneficiary Notice of Noncoverage (FFS ABN). Retrieved from https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn

⁷Centers for Medicare & Medicaid Services. (n.d.). Telehealth services. Retrieved March 3, 2025, from https://www.cms.gov/files/document/mln901705-telehealth-services.pdf