Improving Telehealth Billing Efficiency with Must-Know Essential Updates for 2025

In 2025, telehealth billing is set to undergo critical adjustments as several temporary flexibilities introduced during the COVID-19 public health emergency (PHE) expire. In fact, understanding these updates is essential for telehealth providers to ensure compliance and optimize reimbursement under the Medicare Physician Fee Schedule (MPFS). Therefore, the following is a comprehensive guide on the must-know telehealth billing changes for 2025, covering expiring PHE waivers, CMS-proposed flexibilities, and new requirements for billing procedures.

1. Expiring PHE Telehealth Flexibilities

During the PHE, telehealth waivers expanded Medicare beneficiaries’ access to remote healthcare by broadening definitions for “originating site” and “audio-only telehealth” and allowing a wider variety of practitioners to bill for telehealth services. These waivers, extended through the 2023 Consolidated Appropriations Act (CAA), are set to expire on December 31, 2024, unless Congress intervenes. The expiration will end several expanded access points, meaning:

●        Originating Site Limitations: Previously, any site, including a patient’s home, could be used as an originating site for telehealth services. As of January 1, 2025, this flexibility will narrow, restricting the patient's home to serving as an originating site only for mental health and substance use disorder treatments and monthly assessments for End-Stage Renal Disease (ESRD).

●        Audio-Only Limitations: Flexibilities that allowed the use of audio-only telehealth are expected to end for most services, reinforcing CMS’s preference for two-way audio-video technology.

CMS has solicited feedback on how these changes could impact healthcare utilization in 2025, as the restricted originating site provisions and audio-only limitations may significantly reduce patients’ access to telehealth services.

2. CMS-Proposed Flexibilities for 2025

CMS has introduced a set of proposals within its regulatory authority to retain some PHE-era telehealth flexibilities beyond 2024. These proposed updates aim to balance compliance requirements with the growing demand for telehealth services.

Extended Remote “Direct Supervision”

One of the most notable flexibilities CMS intends to extend is related to “direct supervision.” During the PHE, CMS permitted “direct supervision” through real-time audio-video technology, rather than requiring a physician's physical presence. For 2025, CMS proposes:

●        Continued Remote Supervision: Until December 31, 2025, healthcare practitioners will be able to meet “direct supervision” requirements remotely via audio-video technology, with the condition that the supervising practitioner remains immediately available.

●        Permanent Flexibility for Specific Services: For certain incident-to services (such as CPT code 99211 visits), CMS proposes to make this virtual supervision option permanent. This will be beneficial for practitioners supervising auxiliary personnel remotely, ensuring continuity in service provision without requiring physical proximity.

Use of “Distant Site” Address Flexibility

Telehealth providers could bill from their home during the PHE without listing it as an enrolled location, primarily to protect privacy and safety. CMS proposes to continue this flexibility through December 31, 2025, allowing practitioners to use their current enrolled location, rather than their home address, as their billing address.

Revised Definition of “Telecommunications System”

The definition of “Interactive Telecommunications System” was expanded during the PHE to include audio-only technology for specific situations, making it easier for beneficiaries unable to use video technology to still receive care. Starting in 2025, CMS proposes to make this flexibility permanent under certain circumstances:

●        Audio-Only Communication: CMS would allow audio-only telehealth if the provider’s equipment can support two-way audio-video communication, but the patient either cannot use or declines video technology.

●        Claims Billing with Modifier “93”: Providers billing for audio-only services under this flexibility must use CPT modifier “93” for compliant claims.

While this update will allow audio-only services for patients who lack video capabilities, the impact may be limited by originating site restrictions, as homes will not broadly qualify unless the service relates to mental health or ESRD.

3. Additions to the List of Telehealth Services

CMS proposes adding provisional telehealth codes for a range of services in 2025, but no permanent additions have been confirmed. Proposed codes include:

●        Home Monitoring: HCPCS Code G0248 for INR monitoring

●        HIV Preventive Care: HCPCS Codes G0011 and G0013 for PrEP

●        Caregiver Training: New codes (e.g., GCTD 1-3, GCTB 1-2) for caregiver training on behavior and patient functional performance.

These provisional additions address emerging healthcare needs in home settings and support the inclusion of caregiver training in telehealth, enhancing the care environment.

4. Non-Recognition of New AMA Telemedicine Codes

In 2025, CMS will not adopt the new AMA CPT codes (9X075–9X091) for telemedicine Evaluation and Management (E/M) services. These codes were designed to differentiate telemedicine E/M services from standard outpatient codes, but CMS has opted to use existing codes, categorizing the new ones as redundant. As a result, telehealth providers will need to continue billing traditional E/M codes instead.

5. Compliance Challenges for Providers

With the proposed updates, healthcare providers must navigate a complex landscape of expiring waivers, provisional flexibilities, and nuanced billing requirements. Providers should be vigilant about the following compliance considerations:

●        Adapting to Site and Supervision Changes: Providers must update policies to reflect the revised site restrictions, especially for patients requiring telehealth services in non-home locations, and integrate audio-video supervision where permitted.

●        Differentiating Audio-Only Claims: Ensuring that audio-only claims are filed with CPT modifier “93” for eligible services will be crucial to comply with new billing standards.

●        Staying Updated on Temporary Codes: Provisional additions to telehealth codes may require workflow adjustments, particularly for services like PrEP and caregiver training, which are newly available via telehealth.

Conclusion

CMS’s 2025 Medicare Physician Fee Schedule introduces significant shifts in telehealth billing, with key flexibilities set to expire and others being selectively extended or permanently adopted. As telehealth remains an integral part of healthcare delivery, providers must adapt billing practices to align with new supervision and originating site requirements, adopt audio-only billing updates, and remain vigilant in navigating the complexities of the evolving regulatory industry. These updates are vital for maintaining access to telehealth services while ensuring compliance and optimizing reimbursement under Medicare.