Telehealth - Effective October 1, 2025

Effective October 1, 2025, several temporary telehealth flexibilities have expired. In the absence of Congressional action, telehealth services listed on the CMS List of Telehealth Services must now comply with all original statutory requirements. This includes the reinstatement of geographic requisites, originating and distant site restrictions, and face-to-face evaluation requirements. For telehealth services to be considered for payment after September 30, 2025, providers must meet all the criteria described below in this article.

Patient Location Requirements

  • Telehealth from an approved originating site located in a rural Health Professional Shortage Area (HPSA)
    • Exception for Alaska and Hawaii participating in a federal telehealth demonstration project
  • Place of Service (POS) is 02 or 10 to indicate a telehealth service
    • 02 - telehealth provided other than in patient's home
    • 10 - telehealth provided in patient's home

Approved Originating Sites (patient location)

  • Office of physician or practitioner
  • Hospital (inpatient or outpatient)
  • Critical access hospital (CAH)
  • Rural Health Clinic (RHC)
  • Federally Qualified Health Center (FQHC)
  • Hospital-based or critical access hospital-based renal dialysis center (including satellites)
  • Skilled Nursing Facility (SNF)
  • Community Mental Health Center (CMHC)
  • *Patient home (only for mental and behavioral health)

Only HCPCS code Q3014 may be billed

Eligible Providers at Distant Site

  • Physician
  • Nurse practitioner
  • Physician assistant
  • Nurse-midwife
  • Clinical nurse specialist
  • Clinical psychologist
  • Clinical social worker
  • Registered dietitian or nutrition professional
  • Certified registered nurse anesthetist

Note: Physical therapist, occupational therapist, speech-language pathologist, acupuncturist are not eligible as distant site providers for services rendered after September 30, 2025.

Special guidelines for Behavioral and Mental Health Telehealth

  • Patients may continue to receive telehealth services wherever they are located
    • Originating site and geographic location restrictions do not apply
    • Patient's home is a permissible originating site for services provided for diagnosing, evaluating, or treating:
      • Mental health disorders
      • Substance abuse disorder
  • Mandatory in-person visits
    • Patients new to receiving telehealth must have an in-person visit six months before beginning telehealth services
    • Patients already receiving telehealth must have an annual visit (every 12 months)
      • For patient safety, it is recommended to schedule an in-person visit one year from last in-person visit
    • In-person visits may be performed by another provider in the same specialty, same group practice, when the treating provider is not available to perform in-person visit

Resources

Last Updated Oct 22 , 2025