Adjusting to Medicare’s Telemedicine Coverage Changes
December 2, 2025
Telemedicine’s landscape is shifting fast—here’s how healthcare organizations can adapt to Medicare’s new coverage limits without disrupting patient care.
News & Trends
Transaction Advisory
As healthcare providers continue recovering from the COVID-19 public health emergency, significant changes to telemedicine coverage under Medicare have become effective October 1, 2025. While telemedicine has provided a crucial service to patients and healthcare providers over the past few years, practices must now adjust to the financial and operational impacts of Medicare no longer covering telehealth care services.
Understanding the Changes
The American Relief Act of 2025 extended telehealth waivers beyond the conclusion of the COVID-19 public health emergency. As time has progressed, however, Congress has opted not to continue these flexibilities. Consequently, Medicare reimbursement for most telemedicine services has been discontinued. Additional significant policy changes include:
- Discontinued Coverage by Commercial Insurance Plans: Coverage decisions are determined by individual payers, and some may continue telemedicine benefits beyond October 1, 2025. Practices should contact each commercial insurer to confirm their telemedicine policies and update their billing procedures.
- Restrictions on Telemedicine Prescribing Rules: Prescribing regulations are evolving alongside ongoing coverage changes. The most notable updates involve controlled substances, which were temporarily allowed to be prescribed via telemedicine without an in-person visit under pandemic-related waivers. As regulations revert, special registration pathways are being developed to accommodate various circumstances surrounding telehealth care. The controlled substances schedule determines the criteria for telehealth prescribing, such as the frequency of required in-person visits.
- Requirements for Behavioral Health Services: Behavioral health telemedicine services remain flexible and can continue to be provided in the beneficiary's home. Tele-psych and related behavioral services retain home as site and audio only options when the criteria are met. For Federally Qualified Health Centers and Rural Health Clinics, in-person visits will not be required until January 1, 2026. Providers should verify each payer’s coverage for mental health services.
Practical Steps for Adjustment
To mitigate the impact of these changes, healthcare practices should identify steps they can take to address potential workflow issues.
1. Exploring Telemedicine as a Cash-Pay Service
Providers can offer telemedicine as a cash-pay service to Medicare beneficiaries. If they intend to charge patients directly, they must remain compliant with regulations covering opt-out agreements and proper documentation. Additionally, they should ensure the self-pay fee schedule they currently offer matches any new self-pay accommodations.
Providers may also offer telemedicine as a self-pay option for commercially insured patients, but the rules can vary by payer and state. Some commercial plans may still cover telemedicine, while others may not. It’s recommended that providers verify each plan’s policy before offering telemedicine as a self-pay service to ensure billing transparency.
2. Adjusting Scheduling and Workflows for Telemedicine Services
If telemedicine services continue on a self-pay basis, providers should consider:
- Clearly communicating to patients that insurance may no longer cover virtual visits.
- Having a consistent workflow to ensure payments are collected prior to virtual visits.
- Setting up a designated schedule for telemedicine slots to optimize efficiency.
- Implementing digital consent forms explaining patients’ financial responsibility.
- Providing in-office alternatives for patients whose insurance no longer covers telemedicine.
- For pain management practices, following strict guidelines to ensure UDS screening is completed prior to virtual visits.
Looking Ahead
While telemedicine has been a valuable tool in modern healthcare, Medicare’s rollback of pandemic-era policies will require both providers and patients to acknowledge regulatory adjustments and modify their care strategies accordingly. Providers should explore innovative care models and communicate effectively in order to minimize disruptions and ensure the continued delivery of high-quality care.
