Telehealth emerged as a lifeline during the pandemic, making care accessible without compromising safety. Today, it continues to serve as a critical pillar of healthcare, helping healthcare providers navigate workforce shortages while ensuring patients in rural and underserved areas receive timely, high-quality care.
However, with shifting regulations and mounting uncertainty around the rollback of pre-pandemic flexibilities, healthcare providers find themselves navigating a landscape of ambiguity. Remaining vigilant and strategically prepared is key to sustaining seamless telehealth delivery. Let’s take a closer look at the latest CMS Telehealth update to understand what’s changing in 2025 and how you can stay ahead.
Telehealth has transformed from a pandemic-era solution into a core component of modern healthcare. By eliminating distance and reducing wait times, it has brought care closer to patients.
Valued at USD 123.26 billion in 2024, the global telehealth market is on track to reach an impressive USD 455.27 billion by 2030. North America remains at the forefront of this growth, with the United States commanding the largest share of the market.
According to the Medicare Telehealth Trends Report, over 6.7 million Medicare beneficiaries utilized telehealth services in 2024. Although utilization has tapered off since the pandemic due to the return of in-person visits, nearly one in four Medicare patients still rely on virtual care, underscoring its lasting role in modern healthcare delivery.
Furthermore, a ScienceSoft study offers valuable insight into where telehealth proves most effective. Patients most frequently turned to telehealth for medication refills, highlighting its convenience and efficiency. Interestingly, for mental health and weight management, they expressed equal preference for in-person and telehealth visits, signaling trust in the effectiveness of digital health interventions.
Many of the telehealth flexibilities introduced during the pandemic are still in effect for now, but they won’t last indefinitely. Here’s what providers need to keep in mind for 2025.
The telehealth flexibilities introduced during the COVID-19 public health emergency will remain active until September 30, 2025. Starting October 1, 2025, non-behavioral health telehealth services will once again be subject to geographic and originating site restrictions, meaning patients may no longer receive these services from just anywhere, including their homes.
Currently, a broad range of practitioners, including physical therapists, occupational therapists, speech-language pathologists, and audiologists, can deliver telehealth services under Medicare. This flexibility also ends on September 30, 2025, unless further extended.
Regarding the use of technology, two-way audio-video communication remains the standard for most telehealth visits. However, audio-only communication is temporarily allowed through September 30, 2025, in select non-behavioral cases, particularly when the provider can use video but the patient cannot or declines consent.
Additionally, the in-person visit mandate for behavioral health services delivered remotely has been pushed to October 1, 2025.
There’s encouraging news for behavioral and mental telehealth services. Telehealth access for these services will continue with no restrictions on the originating site. Patients can receive care from home regardless of geographic location. For Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), the in-person visit requirement for behavioral health has been extended until January 1, 2026.
Moreover, patients may continue to access behavioral and mental health services via audio-only telehealth from the comfort of their homes. Additionally, the frequency caps for telehealth visits remain lifted, with the suspension now extended till the end of 2025.
CMS has transitioned to a new system for categorizing telehealth services, labeling them as either “permanent” or “provisional.” But don’t confuse provisional with temporary; these services aren’t going away anytime soon. Instead, CMS plans to take a closer look at them in future rulemaking before making final decisions.
As part of this update, CMS has also expanded the Medicare Telehealth Services List with three new additions:
Telehealth is evolving, and the changes ahead may impact your workflow and your patients. A little preparation now can help you stay compliant, avoid disruptions, and continue delivering high-quality virtual care. Here are a few steps:
Review the services you’re offering remotely. Are you using audio-only visits? Are therapy or behavioral health sessions part of your virtual care model? Flag anything tied to temporary flexibilities that might phase out after key deadlines.
Your entire team should be aligned. Brief all your front-line and back-office teams on the Telehealth updates to avoid missteps in telehealth delivery or billing. Ensure they’re aware of newly approved codes and services, including:
Patients who rely on virtual care need to know what’s coming. Now is a great time to draft and share updates that explain any upcoming changes.
Mark your calendars; October 1, 2025, and January 1, 2026, are two important dates when several telehealth flexibilities could change or expire. Staying on top of CMS announcements will help you adjust your services proactively and avoid last-minute disruptions to care or compliance.
Telehealth is here to stay, but the rules are shifting. As we move forward, staying informed, agile, and well-prepared will be essential to maintaining compliance and ensuring uninterrupted care. By adapting early to regulatory changes, you can continue to deliver high-quality virtual services without disruption.
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