Medicare Telehealth Reprieve: Congress Includes Virtual Care Lifeline Through Fall 2025 in CR

As of the date of publication, the March 2025 Continuing Resolution (CR) includes significant extensions for telehealth flexibilities and reimbursement policies that were set to expire on March 31, 2025. These extensions push the expiration date to September 30, 2025, providing a six-month reprieve for healthcare providers, hospitals, and patients who rely on telehealth services. Below is a comprehensive analysis of the telehealth provisions contained in the CR.

Key Telehealth Extensions

Geographic and Originating Site Restrictions

The CR extends the waiver of geographic requirements and expands originating sites for telehealth services until September 30, 2025 (Section 2207(a)). This means:

• Medicare beneficiaries can continue to receive telehealth services regardless of their location

• Patients are not restricted to receiving telehealth services only at designated healthcare facilities

• Services can be provided to patients in their homes or other non-traditional locations

Expanded Practitioner Eligibility

Section 2207(b) extends the expanded list of practitioners eligible to furnish telehealth services through September 30, 2025. This broader eligibility ensures continued access to a wider range of healthcare professionals via telehealth.

FQHC and RHC Telehealth Services

The CR extends telehealth services for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) until September 30, 2025 (Section 2207(c)). This extension is critical for underserved and rural communities that heavily rely on these facilities for healthcare access.

Mental Health Services Flexibility

Several provisions specifically address telehealth for mental health services:

1. Delay of In-Person Requirements for Mental Health Services (Section 2207(d)(1))

   • Postpones the requirement for an in-person visit before telehealth mental health services can be provided

   • New implementation date: October 1, 2025

2. Mental Health Visits Furnished by Rural Health Clinics (Section 2207(d)(2))

   • Extends flexibilities for RHCs providing mental health services via telehealth

   • New expiration date: October 1, 2025

3. Mental Health Visits Furnished by Federally Qualified Health Centers (Section 2207(d)(3))

   • Continues allowances for FQHCs to provide mental health services through telehealth

   • New expiration date: October 1, 2025

Audio-Only Telehealth Services

Section 2207(e) extends the authorization for audio-only telehealth services until September 30, 2025. This is particularly important for:

• Patients without access to video technology

• Areas with limited broadband infrastructure

• Elderly patients who may struggle with video technology

Hospice Care Recertification

The CR extends the use of telehealth to conduct face-to-face encounters prior to recertification of eligibility for hospice care through September 30, 2025 (Section 2207(f)). This provision helps ensure continuity of care for hospice patients while reducing unnecessary in-person visits.

Acute Hospital Care at Home Program

Section 2208 extends the Acute Hospital Care at Home waiver authorities until September 30, 2025. This program allows hospitals to:

• Provide hospital-level care to patients in their homes

• Receive appropriate Medicare reimbursement for these services

• Expand capacity during high-demand periods

• Reduce infection risks for vulnerable patients

Prescription Drug Coverage Extension

The CR also extends the temporary inclusion of authorized oral antiviral drugs as covered Part D drugs until September 30, 2025 (Section 2209). While not explicitly a telehealth measure, this provision complements virtual care by ensuring patients can access prescribed medications following telehealth encounters.

Implementation Authority

Section 2207(g) grants the Secretary of Health and Human Services the authority to implement the telehealth amendments through program instruction or otherwise. This provides administrative flexibility for rapid implementation of these extensions.

Implications for Stakeholders

For Hospitals and Health Systems

• Continued ability to offer telehealth services across their patient populations

• Extended reimbursement for virtual care services

• Sustained operation of hospital-at-home programs

• Greater planning certainty for the next six months

For Healthcare Providers

• Continued Medicare reimbursement for telehealth services

• Maintained flexibility in practitioner eligibility

• Extended ability to serve patients remotely

• Reduced administrative burden with delayed in-person visit requirements for mental health

For Mental Health Providers

• Extended flexibility for providing services via telehealth

• Postponed in-person visit requirements

• Continued ability to serve patients in rural and underserved areas

• Maintained access to patients who benefit from remote mental health services

For Telehealth Companies and Technology Providers

• Extended market stability for telehealth solutions

• Additional time to develop sustainable business models beyond the pandemic-era flexibilities

• Continued growth opportunity in serving Medicare populations

Looking Ahead

While the six-month extension provides short-term relief, the telehealth industry still faces uncertainty about permanent policy changes. The temporary nature of these extensions suggests Congress and regulatory agencies are:

1. Evaluating the long-term effectiveness and cost implications of expanded telehealth

2. Considering more comprehensive telehealth legislation

3. Gathering data on utilization patterns and outcomes

4. Potentially moving toward more permanent solutions

Stakeholders should use this six-month window to:

• Advocate for permanent telehealth policies

• Document outcomes and cost-effectiveness

• Prepare contingency plans for potential policy changes in October 2025

• Engage with policymakers on long-term telehealth regulations

This extension reflects the continued recognition of telehealth's value in the healthcare system, while giving policymakers additional time to develop more permanent solutions. For additional information and analysis on how this CR could impact your organization, reach out to CTeL today.