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The National Voice for Clinical Social Work

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CMS Update on Telemental Health

October 01, 2025 2:52 PM | Anonymous member (Administrator)


October 1, 2025

This guidance on telehealth was published today by CMS on the status of telemental health. All telehealth services will return to the status of non-coverage that was in place before the pandemic, except for mental health services. This was what CSWA was expecting.

CMS made no change to the in-person requirement that goes into effect today. To review, it means that we need to see virtual Medicare patients once a year in-person. There is an option to document that the in-person requirement will interfere with ongoing treatment and waive it. It is unclear whether it is possible for new virtual patients to have the in-person requirement waived as of today.

Additionally, there will be a 10-day hold on payments for traditional Medicare. Claims can continue to be submitted but will not be processed for 14 days. Here is the guidance (yellow highlight is that of Laura Groshong, CSWA Director of Policy and Practice):

CENTERS FOR MEDICARE & MEDICAID SERVICES (CMS)

Wednesday, October, 1, 2025

Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown

When certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact on providers due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.

Absent Congressional action, beginning October 1, 2025, many of the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency will take effect again for services that are not behavioral and mental health services. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas and hospice recertifications that require a face-to-face encounter. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits. In the absence of Congressional action, practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage. Practitioners should monitor Congressional action and may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of Congressional action. Additionally, Medicare would not be able to pay some kinds of practitioners for telehealth services. For further information: https://www.cms.gov/medicare/coverage/telehealth.

CMS notes that the Bipartisan Budget Act of 2018 allows clinicians in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) to provide and receive payment for covered telehealth services to certain Medicare beneficiaries without geographic restriction and in the beneficiary’s home. There is no special application or approval process for applicable ACOs or their ACO participants or ACO providers/suppliers. Clinicians in applicable ACOs can provide these covered telehealth services and bill Medicare for the telehealth services that are permissible under Medicare rules during CY 2025, irrespective of further Congressional action.

For more information:

https://www.cms.gov/files/document/shared-savings-program-telehealth-fact-sheet.pdf.

MACs will continue to perform all functions related to Medicare Fee-for-Service claims processing and payment.

Please continue to let members of Congress know that the in-person requirement will be a hardship for many patients. Let Laura Groshong, LICSW, CSWA Director of Policy and Practice, know if you have any more questions about the changes to telemental health coverage at lwgroshong@clinicalsocialworkassociation.org.


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