Medicare Telehealth Changes Ahead, But Behavioral Health Gets a Pass — Here’s What You Need to Know

Medicare telehealth rule changes 2025 — behavioral health providers remain protected under CMS’s permanent telehealth flexibilities. Straight from the Hive by Golden Bee Billing Services.

🩺 The Big Picture

The telehealth landscape under Medicare is shifting again. As CMS rolls out its 2025 updates, many providers are bracing for the return of pre-pandemic restrictions — the infamous “telehealth cliff.”

But here’s the good news: behavioral health practices are still protected. Most of the new rules do not apply to mental and behavioral health services, thanks to ongoing federal recognition of the critical role telehealth plays in mental-health access and continuity of care.

📘 What’s Changing (for Everyone Else)

For non-behavioral specialties, several pandemic-era flexibilities are ending or being phased out by September 30, 2025:

• Geographic and originating-site restrictions will return for most services, meaning patients may need to be located in rural or designated areas to qualify.

• Audio-only visits will no longer count for many evaluation and management (E/M) codes.

• Temporary waivers allowing providers to bill for telehealth from home offices are set to expire.

• Some codes will revert to pre-pandemic lists, requiring in-person encounters for continued reimbursement.

In short: CMS is tightening the leash for most specialties.

Behavioral health telehealth services that remain covered under Medicare — including home-based (POS 10) and audio-only (modifier 93) visits — alongside key areas to monitor for 2026, such as modifier accuracy and MAC-specific rules. Designed by Golden Bee Billing Services.

💬 Why Behavioral Health Gets a Pass

Behavioral health telehealth has been given permanent exceptions in the Medicare rulebook — a direct acknowledgment of how vital virtual care has become in treating mental health conditions.

Here’s what remains protected:

• No geographic or originating-site limits. Behavioral health patients can continue to be seen from any location, including home.

• Audio-only telehealth stays covered. For psychotherapy, medication management, and related behavioral health visits, phone-only care remains billable when clinically appropriate.

• RHCs and FQHCs stay eligible. Rural Health Clinics and Federally Qualified Health Centers can continue serving behavioral health patients via telehealth without interruption.

• In-person visit requirement still delayed. The rule that would have required an in-person visit within six months of the first telehealth appointment — and annually thereafter — is still on hold through at least 2025 for mental health.

🐝 GBBS Tip: Always document clinical justification for telehealth, note patient location, and confirm consent — even when the rules seem relaxed. CMS loves an audit trail.

🕰 What to Watch in Late 2025

CMS has flagged October 1, 2025 as a critical date. Unless Congress extends key flexibilities, non-behavioral services may lose certain telehealth privileges. For behavioral health, though, the safety net remains intact.

Still, keep an eye on:

• Any reintroduction of the in-person requirement after 2025

• Audio-only coverage reviews tied to utilization data

• Medicare Advantage plan variations — some may impose their own restrictions even when traditional Medicare doesn’t

💡 Practice managers should review payer contracts now to ensure that telehealth services are still recognized under each plan’s policies.

📊 What This Means for Behavioral Health Practices

This stability gives behavioral health clinics a competitive advantage in patient access and retention. While other specialties prepare to scale back, mental-health providers can continue offering seamless, nationwide care for Medicare patients — particularly those who are homebound or in underserved areas.

But don’t get complacent:

• Review your telehealth documentation and modifier usage (95, 93, FQ, FR).

• Confirm location codes (02 vs 10) are applied correctly.

• Continue tracking updates from CMS and your MAC (Medicare Administrative Contractor).

🧭 The Takeaway

While the headlines make it sound like telehealth is shrinking, behavioral health is holding strong. You can keep offering the same high-quality, virtual care your patients depend on — with little disruption — through at least 2025.

As always, GBBS will keep monitoring CMS, payer bulletins, and MAC policy changes so our partner practices never miss a beat.

Stay steady. Stay compliant. Stay ahead — that’s the Hive way.

Golden Bee Billing Services, LLC

www.gbbillings.com