Key takeaways:
- Medicare telehealth flexibilities originally set to expire on March 31, have been extended for an additional six months.
- Unless Congress acts again on this issue, Medicare’s geographic restrictions for originating sites will resume on Oct. 1.
As outlined in our prior client alert, the healthcare industry can breathe a temporary sigh of relief as Congress has once again acted to extend for an additional six months the Medicare telehealth flexibilities implemented at the height of the COVID-19 pandemic, which were slated to expire on March 31. Without this extension, telehealth would only have been reimbursable under Medicare in a very restrictive manner for those patients located in a rural area or an area with a health provider shortage or who were physically located in a specific setting (e.g., a physician’s office); Medicare would not have been able to reimburse care rendered to patients who were participating in telehealth visits from their home.
However, Congress passed H.R. 1968, the Full-Year Continuing Appropriations and Extensions Act, 2025, which the president signed into law on March 15. Under Section 2207 of this act, Congress extended the existing telehealth flexibilities for an additional six months until Sept. 30. Unless Congress passes further legislation on the matter, Medicare’s geographic criteria restricting how telehealth can be delivered will resume on Oct. 1.
Other flexibilities extended by Section 2207 include expanding the list of practitioners eligible to furnish telehealth, extending telehealth services for Federally Qualified Health Centers and Rural Health Centers, delaying the in-person requirements for mental health services furnished through telehealth, allowing the furnishing of certain audio-only services, and extending the use of telehealth for conducting face-to-face encounters for hospice recertification.
For the time being, healthcare organizations can continue operating under current flexibilities as they inch closer to the cliff’s edge looming this fall. Some stakeholders, like the American Telemedicine Association, remain encouraged by comments made by Dr. Mehmet Oz, the nominee for administrator of the Centers for Medicare & Medicaid Services, who commented at his Senate hearing that telehealth is a major focus and “one of the areas … [where] we’ll be able to make major inroads because there are no opponents to this.”
Six months’ time will tell. We will continue to monitor ongoing legislative developments.
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