For the second time in three months, Medicare telehealth came within days of reverting to the rules of 2019. The December spending bill (the American Relief Act, 2025, signed December 21, 2024) had extended the pandemic-era flexibilities only through March 31, 2025. On March 15, 2025, the President signed the Full-Year Continuing Appropriations and Extensions Act, 2025, the continuing resolution that funds the government through September 30, and it carries the telehealth provisions with it to the same date.
Practices that had spent February building two April schedules can put one of them away. But the extension is six months, not permanent, and the same conversation will happen again in September. Here is what changed, what did not, and what to do in the billing office this week. We have also included the billing rules that we still see wrong on telehealth claims, because a cliff that did not happen is a good moment to clean up the claims that did.
Key takeaways
- Home as an originating site, the waived geographic restriction, audio-only coverage, FQHC and RHC distant-site billing, the delayed in-person requirement for tele-mental health, and telehealth hospice recertification all continue through September 30, 2025.
- Nothing about coding changed: Medicare telehealth office visits are still 99202 to 99215 with POS 10 or 02, modifier 93 for audio-only, and 98016 for a brief check-in.
- Any scrubber edit, patient letter or schedule change built for an April 1 cliff needs to be reversed or re-dated to October 1.
- Commercial and Medicaid telehealth rules did not move; they follow the payer and the state.
- Put an early-September review on the calendar. The extension is six months.
What the continuing resolution extends, through September 30, 2025
| Flexibility | Before March 15 | Now |
|---|---|---|
| Originating site and geography: patient may be at home or anywhere, no rural requirement | Expired March 31, 2025 | Through September 30, 2025 |
| Audio-only telehealth paid where permitted | Expired March 31, 2025 | Through September 30, 2025 |
| FQHCs and RHCs as distant-site telehealth providers | Expired March 31, 2025 | Through September 30, 2025 |
| In-person visit within six months before tele-mental health, and periodically after | Would have applied from April 1, 2025 | Delayed until October 1, 2025 |
| Hospice recertification face-to-face encounter by telehealth | Expired March 31, 2025 | Through September 30, 2025 |
| Expanded list of eligible distant-site practitioner types (for example physical and occupational therapists, speech-language pathologists, audiologists) | Expired March 31, 2025 | Through September 30, 2025 |
Each of these was scheduled to end on March 31. Each now ends on September 30, 2025, unless Congress acts again. The permanent exceptions that predate the pandemic, such as behavioral health services furnished to a patient at home and certain services for end-stage renal disease and acute stroke, were never at risk and are unaffected.
What did not change
The 2025 Medicare Physician Fee Schedule rules that were already in place for the year continue as they were. Medicare still does not pay the new CPT telemedicine codes 98000 to 98015; office visits by telehealth are billed with 99202 to 99215. Place of service 10 (telehealth in the patient's home) is paid at the non-facility rate; place of service 02 (telehealth other than home) is paid at the facility rate. Modifier 93 identifies audio-only services. Teaching physician virtual presence and the ability of distant-site practitioners to list their practice address rather than a home address were already extended for all of 2025 by CMS in the fee schedule and are unaffected by the continuing resolution.
Nothing in the continuing resolution changes commercial or Medicaid telehealth policy. Those payers follow their own rules and state law, and several commercial payers adopted the 98000 series on January 1, 2025. If your scrubber maps telehealth codes by payer, the Medicare rows do not change; the commercial rows were never tied to this deadline.
Documentation that still matters
The extension keeps the payment rules in place; it does not relax what the note has to show. For every Medicare telehealth visit we want to see the patient's location at the time of service (which decides POS 10 versus POS 02), the provider's location, the modality (audio-video or audio-only) and, for audio-only, a line on why video was not used, the patient's consent to a telehealth visit, and the total time or the medical decision making that supports the E/M level. Auditors ask for these on telehealth claims more often than on in-person visits, because the service is easier to question. A short template block at the top of the note covers all of it in twenty seconds.
A worked example. A 71-year-old established patient with hypertension has a video visit from home on March 20 to review blood pressure readings and adjust a medication; the provider is in the office. The note records: patient at home, provider at practice location, real-time audio-video, consent obtained, 22 minutes total time. The claim is 99213 (or 99214 if time or medical decision making supports it) with POS 10. If the video fails and the visit finishes by phone, the note says so, modifier 93 is added, and the level is supported by time, since an audio-only visit has no exam.
Who this affects
Any practice billing Medicare fee-for-service for telehealth, which after five years is most of them: primary care, behavioral health, endocrinology, neurology, follow-up visits in surgical practices, and every FQHC and RHC. Behavioral health practices are the most exposed to the in-person requirement, and they should keep the September 30 date circled: a patient who started tele-mental health during the pandemic and has never been seen in person would need an in-person visit before October 1 if the delay is not extended again. Therapy practices should note the same date for the practitioner-type expansion.
The billing rules that still trip people up
| Situation | Medicare coding | Common error |
|---|---|---|
| Video visit, established patient, home | 99212 to 99215, POS 10 | Billing POS 02, which pays the lower facility rate |
| Audio-only visit, home | 99212 to 99215, POS 10, modifier 93 | Omitting modifier 93, or billing 98008 to 98015 which Medicare does not pay |
| Brief 5 to 10 minute check-in, not tied to a visit within 7 days before or 24 hours after | 98016 | Still billing G2012, which was replaced for 2025 |
| Tele-mental-health, no in-person visit in the last six months | Allowed through September 30, 2025 | Assuming the in-person requirement is already in force |
| Patient at a clinic site, provider elsewhere | 99212 to 99215, POS 02 | Billing POS 10 because "telehealth"; POS 10 is only for the patient's home |
The POS 10 versus POS 02 error is the expensive one, because it is silent: the claim pays, just less. On a practice with 300 Medicare telehealth visits a month, a few dollars per visit is thousands a year that no denial report will ever show. The only way to find it is to sample telehealth claims against notes, which is why we include it in the steps below.
Our view
Six-month extensions are a poor way to run a service line. Practices cannot hire, buy equipment or promise patients on a six-month horizon, and the last two cliffs each cost the billing office a week of contingency work. Physician and telehealth groups are pushing for a multi-year extension in the next appropriations cycle. We think that is the right ask. Until then, treat telehealth as a service that is on through September 30 and keep the contingency plan in a drawer rather than throwing it away. The February version, with the list of patients who would need to convert to in-person visits, is exactly what you will need again in September.
Questions we hear
Do we need to re-enroll or notify Medicare of anything?
No. The extension is statutory and applies automatically. Continue billing as you did in February. Medicare Administrative Contractors will update their own guidance, but nothing is required of the practice.
What about Medicare Advantage plans?
Medicare Advantage plans must cover at least what fee-for-service Medicare covers, and most cover telehealth more broadly as a supplemental benefit. Check each plan's telehealth policy, especially for audio-only and for the 98000 codes, which some MA plans accept even though fee-for-service Medicare does not.
Can Revelrex help us prepare for September?
Our medical billing team maintains payer-specific telehealth rules for every practice we serve and will run the same review in early September. If you want a look at your telehealth claims and denials now, book a call.
What to do this week
- Unwind the April contingency: if the scheduling team converted Medicare telehealth appointments after March 31 to in-person or cancelled them, call those patients and offer telehealth again.
- Release any telehealth claims held for late-March dates of service. There was never a gap, so there is nothing to hold.
- Move any scrubber edit written to block Medicare telehealth from April 1 to October 1, 2025, or remove it.
- Send a short correction to patients who received a letter or portal message saying Medicare telehealth ends March 31.
- Sample 20 telehealth claims from March 1 forward and check place of service and modifier 93 against the note, correcting any POS 02 that should have been POS 10.
- Behavioral health practices: list the tele-mental-health patients with no in-person visit in the last six months, so the list is ready if the in-person requirement takes effect October 1.
- Put an early-September review on the calendar and file the February contingency plan where you can find it.
