CMS Telehealth Deadline Extended: Key Changes, and Billing Updates

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CMS Telehealth Deadline Extended: Key Changes, and Billing Updates

CMS Telehealth Deadline Extended: Key Changes, and Billing Updates

Wednesday, March 26, 2025

Telehealth has become an integral part of health care delivery, providing patients with greater access to health care services while offering physicians and providers more flexibility in care delivery. To keep pace with evolving needs and in response to pressure from interested parties, the Centers for Medicare & Medicaid Services (CMS) continues the work to finalize its telehealth policies.

Initially set to expire on March 31, 2025, the expanded telehealth services have been extended through September 30, 2025. This extension allows Medicare patients to continue receiving a wide range of telehealth services from their homes, without geographic restrictions. All eligible Medicare providers can furnish these services, and Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are authorized to serve as distant site providers for non-behavioral/mental telehealth services during this period.

Additionally, the requirement for an in-person visit within six months of initiating a behavioral/mental telehealth service, and annually thereafter, has been waived through September 30, 2025, and through January 1, 2026 for FQHCs and RHCs under specified circumstances.  Non-behavioral/mental telehealth services can continue to be delivered using audio-only communication platforms through September 30, 2025. This provision ensures that beneficiaries without access to video technology can still receive necessary care.

Meanwhile, certain flexibilities have been made permanent for behavioral and mental health services. Medicare patients can receive behavioral/mental telehealth services in their homes without geographic restrictions. FQHCs and RHCs can permanently serve as distant site providers for these services. Audio-only communication platforms are permanently permitted for delivering behavioral/mental telehealth services.

CMS has indicated that any changes to the list of Medicare telehealth services will be effective on an annual basis, with changes proposed in the summer and finalized by November each year. With another deadline on the horizon, physicians and others health care partners are advocating for further extensions or, ideally, permanent adoption of these telehealth services to ensure continued access to care for Medicare beneficiaries.

All these changes have led to some confusion with what payers in Michigan are reimbursing, and what codes to use when billing for telehealth visits. MSMS has gathered Health Plan specific telehealth coverage and billing information for your reference.  Please refer to payer instructions and information as they may make changes or updates.


Health Plan

Telemedicine Codes Payable

Additional Information

Aetna

Self and fully insured plans cover 98000 - 98007 & G0546, G0547, G0548, G0549, G0550 and G0551 [covered with or without telemedicine modifiers]

Self-funded plans will NOT reimburse audio-only codes 98008 - 98015. Fully insured plans WILL reimburse audio-only codes 98008 - 98015. Bill Telemedicine visits as you have been doing using codes 99202 - 992015 with the appropriate telemedicine modifier for those product lines that do not reimburse the new telemedicine services codes.

BCBSM/BCBSM Commercial

98000 - 98016 Effective 1/1/2025

99202 - 99215 are still payable codes for telemedicine visits through 6/30/2025. Use an appropriate modifier to indicate a telemedicine visit. Effective 7/1/2025, these codes will no longer be paid for telemedicine visits.

CMS/Medicare/MA Plans

98016 is payable, but 98000 - 98015 are designated as "I" inactive = not payable.

Bill telemedicine visits as you have been doing using codes 99202 - 99215. CMS recommends appending modifier 93 if it is an audio only service.

Health Alliance Plan (HAP)

Following CMS guidelines and currently not reimbursing 98000 - 98015. 98016 is being reimbursed.

Bill telemedicine visits as you have been doing using codes 99202 - 99215. CMS recommends appending modifier 93 if it is an audio only service.

Priority Health

98000 - 98016 payable for commercial plans.

Bill telemedicine visits as you have been doing using codes 99202 - 99215. CMS recommends appending modifier 93 if it is an audio only service.

United HealthCare

Following CMS guidelines on all product lines.

Bill telemedicine visits as you have been doing using codes 99202 - 99215. CMS recommends appending modifier 93 if it is an audio only service.