October 22, 2025

Here are two additional pieces of news related to the Medicare Telemental Health changes. First, the good news! CMS has decided to eliminate the hold on payment of claims for mental health treatment (though not for other health care services) so claims will be paid on the usual basis, i.e., about 14 days after being submitted. Below is the message that was sent yesterday from CMS (yellow highlight mine):

Claims Hold Update

"CMS instructed all Medicare Administrative Contractors (MACs) to lift the claims hold and process claims with dates of service of October 1, 2025, and later for certain services impacted by select expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025 (Pub. L. 119-4, Mar. 15, 2025). This includes claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and Federally Qualified Health Center (FQHC) claims. This includes telehealth claims that CMS can confirm are definitively for behavioral and mental health services. CMS has directed all MACs to continue to temporarily hold claims for other telehealth services (i.e. those that CMS cannot confirm are definitively for behavioral and mental health services) and for acute Hospital Care at Home claims.

Beginning October 1, 2025, for services that are not behavioral health services, many of the statutory limitations on payment for Medicare telehealth services that were, in response to the COVID-19 Public Health Emergency, lifted, and subsequently extended, through legislation again took effect. 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 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 (ABN). Further information on use of the ABN, including ABN forms and form instructions: https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn. Practitioners should monitor Congressional action and may choose to hold claims associated with telehealth services that are currently not payable by Medicare in the absence of Congressional action. For further information: https://www.cms.gov/medicare/coverage/telehealth."

Now for the not so good news: Kaiser Permanente has decided to start requiring the in-person meeting with patients once during every 12-month period that Medicare implemented on October 1. We can expect other commercial insurers to follow suit. Please let Laura Groshong, LICSW, CSWA Director of Policy and Practice, know if you get any information about this from insurers that you work with by contacting her at lwgroshong@clinicalsocialworkassociation.org.