The Medicare telehealth waivers are a series of temporary policy flexibilities implemented by the Centers for Medicare & Medicaid Services (CMS) during the COVID-19 public health emergency (PHE), which officially ended in May 2023. Initially set to lapse with the PHE’s conclusion, these waivers have been extended multiple times by Congress to sustain expanded virtual care access amid ongoing recovery needs. The most recent extension, via the Full-Year Continuing Appropriations and Extensions Act, 2025, pushes the expiration to September 30, 2025—now just weeks away as of early September 2025—unless further legislative action intervenes. Unless congress acts to extend the waivers, key telehealth flexibilities will expire, impacting both providers and patients. Notably, the expiration of these waivers is linked to the potential government shutdown starting October 1, 2025. These waivers were designed to expand access to virtual healthcare by relaxing longstanding restrictions under Section 1834(m) of the Social Security Act.
Key components include waiving geographic and originating site requirements (allowing services from any U.S. location, including patients’ homes, rather than limiting to rural areas or specific facilities), permitting audio only services for certain health care services—an important option for beneficiaries in rural areas or with limited broadband access—expanding the list of eligible providers (such as therapists and audiologists), enabling Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to bill as distant sites, and delaying in-person mandates for mental health services. Providers bill Medicare for telehealth services using updated billing codes and policies that have adapted to these flexibilities, allowing for reimbursement of a broader range of telehealth visits. These waivers and policy changes are tied to the calendar year for compliance and billing purposes. Medicare telehealth coverage and Medicare telehealth services have also been broadened to include more provider types and service modalities, specifically expanding services via telehealth for a wider range of medical and mental health needs. Permanent coverage for home use has been established, removing geographic restrictions for mental health and substance use disorder telehealth services.
These changes have dramatically increased telehealth utilization, with a surge in telehealth visits and telehealth service delivery, Medicare visits surging from under 1 million in 2019 to over 128 million in 2020, and have improved access to health care services for Medicare beneficiaries. The inability to perform a full physical or neurological examination during telehealth sessions can result in missed diagnostic information. Certain populations, such as those with end stage renal disease, have shown higher rates of telehealth use due to their ongoing care needs. These changes have been credited with maintaining care continuity during the pandemic—particularly in psychiatry, where virtual visits have addressed acute shortages and improved access to behavioral health. Ongoing policy debates continue regarding the expansion of more telehealth services and the implications for future Medicare policy. Medicare patients have benefited from these expanded telehealth options, and the broader field of human services has also seen increased integration of telehealth to support mental health and social care needs. Telehealth offers benefits such as increased convenience, accessibility, and reduced stigma, but also has limitations including reduced non-verbal cues and technical issues.
Regulatory agencies have also issued a proposed rule that could impact telehealth psychiatry, potentially introducing new requirements for prescribing controlled substances via telemedicine. The federal government plays a central role in regulating telehealth practices, including setting policies for telemedicine prescribing, registration processes, and interstate regulations, which continue to evolve in response to changing healthcare needs.
A clear communication strategy is essential for providers and patients to stay informed about policy changes and compliance deadlines. As telehealth practices continue to evolve, it is important for providers to remain compliant with updated laws and consider future policy developments.
Introduction to Medicare Telehealth Coverage
Medicare telehealth coverage has experienced a remarkable transformation in recent years, fundamentally reshaping how healthcare is delivered to millions of Americans. Driven by the urgent needs of the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) introduced a series of telehealth flexibilities that have expanded access to essential health services—including mental health services and behavioral health services—for Medicare beneficiaries nationwide. These changes have enabled patients to receive telehealth services from the safety and convenience of their own homes, eliminating many of the barriers associated with traditional in-person care.
For rural communities, where access to healthcare providers has historically been limited, these telehealth services have been especially impactful. By allowing Medicare beneficiaries to connect with mental health providers and receive behavioral health care remotely, Medicare telehealth coverage has helped bridge longstanding gaps in care. The expansion of telehealth flexibilities has also supported the delivery of Medicaid services, further broadening the reach of virtual care for vulnerable populations.
As telehealth becomes an increasingly integral part of the healthcare system, understanding the current landscape of Medicare telehealth is essential for mental health providers, healthcare organizations, and policymakers. The ongoing evolution of telehealth services not only enhances patient access but also supports the delivery of high-quality behavioral health and mental health care, regardless of a patient’s geographic location. As the future of Medicare telehealth coverage continues to unfold, staying informed about these developments is crucial for those seeking to expand access and improve outcomes for all Medicare beneficiaries.
Why FasPsych Remains the Top Choice Regardless of Medicare Telehealth Waivers 2025 Outcomes
In the ever-evolving landscape of Medicare telehealth waivers, FasPsych stands resilient as the premier provider in telepsychiatry, irrespective of whether Medicare telehealth waivers are extended or expire. Our commitment to excellence ensures that we operate strictly within all current regulations, adapting seamlessly to federal and state guidelines to maintain compliance and deliver uninterrupted care. This includes staying compliant with Drug Enforcement Agency (DEA) regulations, particularly regarding the prescribing of controlled substances via telehealth psychiatry, and closely monitoring proposed DEA rules that impact behavioral health and substance use disorder treatments. FasPsych also recognizes the significant influence of federal government policy on telehealth psychiatry, including the need for clear guidance on registration processes, prescribing limits, and interstate prescribing regulations, all of which affect provider operations and Medicare billing. FasPsych ensures its clinicians are always eligible to provide telehealth services under evolving Medicare rules. FasPsych’s dedicated team conducts ongoing policy research, monitoring developments in real-time to stay ahead of changes like those stemming from the One Big Beautiful Bill Act (OBBBA) and impending waiver deadlines, and closely tracks policy considerations to anticipate and respond to regulatory changes. This proactive approach allows us to provide the best possible services for our clients, offering flexible models to mitigate any disruptions and optimize outcomes for behavioral health organizations. As an industry leader with experience and a trusted telehealth provider in the field of psychiatry, FasPsych has been through several policy changes and will continue to adapt and provide excellent service, making it the best partner for navigating Medicare telehealth waivers 2025.
Navigating the Medicare Telehealth Waivers 2025 Landscape: Preparing for Potential Changes and Why FasPsych Leads in Telepsychiatry
As the September 30, 2025, deadline approaches for the expiration of these key Medicare telehealth waivers—extended most recently through the Full-Year Continuing Appropriations and Extensions Act, 2025—the healthcare landscape is poised for potential shifts. These flexibilities, originally introduced during the COVID-19 public health emergency, have enabled widespread access to virtual care, and preparing for their possible evolution can help ensure continued progress in service delivery. As telehealth evolves, telehealth practices have adapted in response to policy changes and regulatory flexibilities, including expanded access and updated supervision requirements. It is important to establish clear guidelines for the initial telehealth visit and any required in-person follow-ups to comply with regulatory requirements. Any exceptions or deviations from standard procedures should be thoroughly documented in the patient’s medical record to ensure compliance and support regulatory review. This article explores the detailed potential impacts of changes to the Medicare telehealth waivers 2025 on psychiatry, ongoing legislative efforts to extend or permanize them, and the push to ensure certain telehealth flexibilities, such as payment parity and provider authorization, are established on a permanent basis within Medicare. Additionally, payment for telehealth services is determined by the physician fee schedule, which may impact provider reimbursement as policies change. Drawing from expert analyses and industry insights, we’ll highlight why proactive planning is key to embracing opportunities, even as extensions appear promising.
Potential Impacts of Medicare Telehealth Waivers 2025 Changes on Psychiatry and Medicare Beneficiaries: Opportunities for Adaptation
If Congress does not extend the Medicare telehealth waivers beyond September 30, 2025, Medicare telehealth rules would revert to pre-pandemic guidelines starting October 1, offering a chance for psychiatry providers to innovate and strengthen care models. This shift could mean a greater reliance on in-person care. However, the benefit of in-person visits must be carefully weighed against the convenience and improved access provided by telehealth, especially for psychiatry patients. This evolution could encourage a focus on resilient strategies that enhance access and efficiency in mental health services where telepsychiatry continues to play a vital role.
Ripple Effects on Medicaid Programs and Federally Qualified Health Centers
While the Medicare telehealth waivers 2025 primarily affect Medicare, their expiration could have ripple effects on Medicaid programs, as many states have aligned their telehealth policies with federal flexibilities to promote consistency. Medicaid, which covers over 90 million low-income Americans, often mirrors Medicare’s expansions for telehealth reimbursement, especially for behavioral health. Individuals eligible for both Medicare and Medicaid—often referred to as ‘both Medicare’ beneficiaries—face unique challenges, as they tend to have higher rates of telehealth use but may encounter different access issues compared to those with only Medicare coverage. If waivers lapse, states may revert to more restrictive policies, potentially reducing coverage for audio-only visits or home-based services, leading to decreased access for vulnerable populations and increased administrative burdens for providers in psychiatry. Geographic location can significantly affect access to telehealth services, as Medicaid and Medicare policies may vary by state, resulting in different levels of coverage and availability depending on where a patient lives. However, some states have made permanent changes independent of federal waivers, creating a patchwork of regulations that underscores the need for adaptable solutions in mental health care. Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can permanently serve as telehealth providers for psychiatric services under Medicare.
It is important to note that occupational therapists, along with other provider types, will no longer be eligible to bill Medicare for telehealth services starting October 1, 2025, unless Congress intervenes. Additionally, teaching physicians are permitted by CMS to provide virtual supervision during Medicare telehealth consultations using real-time audio/video communication technology, which impacts how telehealth psychiatry services are delivered and supervised.
Intersections with the Ryan Haight Act and DEA Declarations
Additionally, the Medicare telehealth waivers 2025 status intersects with the Ryan Haight Act and the Drug Enforcement Agency’s (DEA) role in regulating telemedicine practices, especially regarding controlled substances. The DEA plays a central role in setting and enforcing regulations for prescribing controlled substances via telehealth, including proposed rules that impact registration requirements, prescribing limits, and compliance for behavioral health and substance use disorder treatments. The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 generally requires an in-person evaluation before prescribing controlled substances via telehealth. During the PHE, the DEA waived this requirement, allowing telehealth prescriptions without in-person exams, which has been extended through December 31, 2025. Telehealth providers must carefully navigate evolving regulations and registration requirements to ensure compliance when prescribing controlled substances. The DEA is currently rulemaking for permanent telehealth prescribing flexibilities, and has proposed a special registration process for telemedicine providers to prescribe controlled substances, but uncertainty persists regarding eligibility and procedural details. The federal government is responsible for setting and updating telemedicine prescribing policies, including those issued by the DEA, and providing guidance on interstate prescribing and compliance. If Medicare waivers expire without alignment, it could complicate integrated care, particularly for psychiatric medications involving controlled substances like benzodiazepines or stimulants, and may also impact telehealth treatment for substance use disorder by restricting access to necessary medications and behavioral health services.
Medicare Part B covers outpatient mental health services, including psychiatric evaluations and medication management, after meeting the annual deductible.
Evolving Patient Locations and Access in Psychiatry
Currently, beneficiaries can receive telehealth services from any location in the U.S., including their homes, without geographic limitations. If changes occur with Medicare telehealth waivers 2025, services might focus more on rural areas and approved originating sites like hospitals or clinics—potentially excluding homes for most non-behavioral health visits. For mental health, adjustments to in-person requirements for telemental health could prompt more integrated care plans, potentially improving treatment adherence while reducing barriers for those with mobility issues, chronic conditions, or in underserved communities. Notably, annual in-person visits required for compliance can be conducted with a provider of the same subspecialty within the practice, not just the original provider, to meet documentation and compliance standards. Exceptions to in-person requirements may be granted based on where the patient lives and their specific circumstances, such as patient stability, risk factors, or logistical challenges, with thorough documentation needed to support these considerations. The in-person visit requirement for established patients will revert to an annual requirement after the waiver expires.
In Person Visits and Requirements: What Psychiatrists Need to Know
With the extension of Medicare telehealth flexibilities set to expire on September 30, 2025, psychiatrists and mental health providers must prepare for significant changes in how they deliver care to Medicare beneficiaries. One of the most critical shifts will be the reinstatement of the in-person visit requirement for mental health services provided via telehealth. This requirement is set to return on October 1, 2025, unless Congress acts to extend the waivers.
Under the pre-pandemic Medicare telehealth policy, new patients are required to have an in-person visit with their psychiatrist or mental health provider within six months before starting telehealth services. After initiating care, an in-person visit must occur at least once every 12 months, with the timing based on when the patient is designated as an established patient, to continue receiving telehealth services. While these in-person visit requirements apply to both new patients and established patients, there are important exceptions. For example, patients who began receiving telehealth services before a specific date during the public health emergency are considered established and may be exempt from the initial six-month in-person visit requirement. Additionally, if a patient faces significant risks or burdens—such as mobility challenges, lack of transportation, or living in underserved areas—the in-person visit requirement may be waived. However, psychiatrists must carefully document the rationale for any exception in the patient’s medical record to ensure compliance with Medicare audit standards. New patients will require an in-person visit within six months prior to starting telehealth services after the waiver expires.
The expiration of telehealth waivers will also bring back geographic restrictions and originating site requirements. This means that most telehealth services will only be reimbursed if the patient is located at an approved originating site, such as a hospital, clinic, or other qualified health centers (FQHCs and RHCs), rather than from their home. These changes could limit access to telehealth services for patients in rural communities and underserved areas, where travel to an approved site may be difficult or impossible. Federally qualified health centers and rural health clinics, which have played a vital role in expanding mental health care through telehealth, will face new limitations on their ability to provide these services as distant site providers. It is essential for FQHCs and RHCs to review updated eligibility rules and telehealth flexibilities to ensure ongoing service delivery and compliance.
Advocacy efforts are underway to address these challenges. Organizations like the American Telemedicine Association and other stakeholders are actively working to extend Medicare telehealth flexibilities and eliminate the in-person visit requirement, recognizing the importance of telehealth in maintaining access to behavioral health services. Psychiatrists should stay informed about these policy developments and consider participating in advocacy to support the continuation and expansion of telehealth benefits for their patients.
Broader Systemic Issues in Psychiatry
Potential changes with Medicare telehealth waivers 2025 encourage a proactive stance against issues like in-person service demands, uncompensated care, and staffing needs, fostering innovation in telepsychiatry programs. It is essential to document any exceptions to in-person requirements in the patient’s medical record to ensure regulatory compliance and justify the exception. In mental health, where workforce needs are met at only 28% capacity, this could drive solutions to economic burdens exceeding $290 billion annually from untreated disorders, promoting equity for rural and vulnerable populations through reduced emergency visits and better health outcomes.
Clinical Guidelines and Resources
Delivering high-quality telehealth services requires adherence to established clinical guidelines and the use of trusted resources, especially when providing mental health services and behavioral health services. Organizations such as the American Telemedicine Association (ATA) have developed comprehensive best practices for telehealth visits, ensuring that care delivered remotely meets the same standards as in-person care. These guidelines cover a range of topics, from conducting effective virtual assessments to maintaining patient privacy and security during telehealth sessions.
For mental health providers, staying current with recommendations from the Substance Abuse and Mental Health Services Administration (SAMHSA) and the National Institute of Mental Health (NIMH) is essential. These agencies offer valuable resources on delivering behavioral health services via telehealth, including strategies for engaging patients, managing complex cases, and supporting those with conditions like end stage renal disease or those receiving home dialysis services.
Prescribing controlled substances through telehealth also requires careful attention to regulatory requirements. The ATA and other professional bodies provide guidance on safe and compliant prescribing practices, helping providers navigate the evolving landscape of telehealth regulations. Medicare telehealth services have specific documentation, consent, and platform requirements that must be followed to ensure compliance and protect patient safety.
By leveraging these clinical guidelines and resources, healthcare providers can confidently deliver effective, efficient, and compliant telehealth services. This commitment to best practices not only enhances patient care but also supports the ongoing integration of telehealth into the broader healthcare system, ensuring that Medicare beneficiaries continue to benefit from expanded access to mental health and behavioral health services.
Ongoing Legislative Efforts for Medicare Telehealth Waivers 2025: Building Momentum for Positive Change
With the deadline approaching, bipartisan support is growing in Congress to extend and enhance these flexibilities, opening doors for sustained innovation. Over 350 organizations, including the American Hospital Association (AHA), American Medical Association (AMA), and American Physical Therapy Association (APTA), are advocating for robust extensions. Legislative action is crucial to ensure continued access to the telehealth visit for Medicare beneficiaries, making these services more accessible and permanent. The Center for Telehealth and e-Health Law (CTeL) is actively engaged, emphasizing congressional action for permanent extensions and equipping stakeholders with resources for the evolving landscape. Other groups, such as the American Occupational Therapy Association (AOTA), are championing short-term wins while advancing comprehensive reforms. Occupational therapists, along with other provider types, are actively involved in advocacy efforts to maintain their ability to bill Medicare for telehealth services, as current policy changes may impact their eligibility after October 1, 2025. These telehealth policy changes have significant implications not only for healthcare but also for the broader field of human services, affecting access to mental health and social support for vulnerable populations.
Key Bills and Actions for Medicare Telehealth Waivers 2025
Preserving Telehealth, Hospital and Ambulance Access Act (H.R. 8261): Introduced by Reps. David Schweikert (R-Ariz.) and Mike Thompson (D-Calif.), this bipartisan bill would extend flexibilities through 2026, including geographic exemptions, home-based services, audio-only options, and a moratorium on the in person requirement for mental health telehealth services. It unanimously passed the House Ways and Means Committee in May 2024 and includes a five-year extension for HaH waivers.
Telehealth Modernization Act of 2024 (H.R. 7623): Passed by the House Energy and Commerce Committee, this bill was amended to align with H.R. 8261 for a two-year extension, focusing on similar flexibilities.
CONNECT for Health Act (H.R. 4189/S. 2016): With over 100 cosponsors in the House and 60 in the Senate, this aims for permanent removal of geographic restrictions and expansions for FQHCs/RHCs. It’s seen as a long-term solution but may face delays.
Senate Finance Committee action is anticipated soon, potentially attaching extensions to must-pass funding bills before September 30. Advocacy groups like HIMSS and APTA are prioritizing permanency for specific providers, such as physical therapists. While encouraging, political dynamics—such as funding adjustments in legislation like OBBBA—underscore the value of preparation.
Why FasPsych is the Best Choice in Staffing Amid Medicare Telehealth Waivers 2025
In this dynamic environment, FasPsych excels as the leading provider in telepsychiatry and locum tenens, with strong staffing for telemedicine and expanded on-site offerings. Established in 2007, FasPsych offers scalable, customizable virtual care via long-term placements, on-demand consultations, and flexible models like pay-by-visit or pay-by-hour. FasPsych maintains an extensive network of qualified telehealth providers ready to meet the needs of mental health organizations, ensuring access to care even as regulations evolve. This adaptability helps organizations respond to patient volumes and funding shifts, lowering overhead and securing access to qualified psychiatrists and nurse practitioners.
While FasPsych primarily focuses on telepsychiatry and does not significantly utilize hybrid or on-site care at present, these options are ones we are fully prepared for and can implement as requested if policies change, ensuring readiness for any regulatory or market shifts. This preparation puts FasPsych in the best position for the future, allowing us to pivot seamlessly as needed. Amid these uncertainties, this is a terrible time to do direct hiring, given the high costs—recruitment fees often reach 25–30% of a psychiatrist’s starting salary (exceeding $300,000), with turnover costing $250,000–$500,000 per departure—and lengthy timelines of 6–12 months to fill roles. Instead, it’s the right time for temporary staffing through FasPsych, which saves up to $200,000 per new hire by deploying clinicians in weeks and handling administrative burdens. FasPsych understands this is a pain point for mental health facilities, and our account managers are working closely with current customers while implementation specialists assist new clients to navigate these challenges effectively. For FQHCs and Community Mental Health Centers (CMHCs), reliant on Medicaid amid OBBBA’s $1.02 trillion cuts over a decade, FasPsych delivers cost-effective solutions with a $4 return per $1 invested and 30% reduced no-shows. In the face of political volatility that strains mental health resources and worsens shortages, FasPsych ensures stability, streamlining operations and prioritizing patient results. FasPsych actively backs CTeL and congressional initiatives to extend and make permanent telehealth waivers, championing lasting behavioral health access. As an industry leader with experience, FasPsych has been through several policy changes and will continue to adapt and provide excellent service, making it the best partner.
FasPsych firmly believes telepsychiatry remains the optimal solution for addressing mental health needs efficiently and effectively. However, in FasPsych’s view, the waivers are likely to be extended due to robust bipartisan backing, though without certainty—delays or lapses might cause short-term challenges. Therefore, immediate planning is vital to avoid reactive measures. Drawing from the Titanic analogy, evading fiscal obstacles like OBBBA via delayed responses risks disaster, whereas direct, short-term tactics safeguard operations and care quality. Delaying could lead to abrupt staffing cuts, service overloads, and cost surges—emphasizing the need for prompt telemedicine adoption.
FasPsych’s implementation experts collaborate closely with clients to sustain service availability for patients, tailoring strategies that uphold telepsychiatry’s advantages while navigating any regulatory adjustments.
Partner with FasPsych Today for Medicare Telehealth Waiver Solutions
Don’t delay amid policy shifts—fortify your organization with telemedicine solutions built to adapt. Contact FasPsych to speak with an implementation expert who can assist in rolling out telepsychiatry now and planning for future changes. Head to our Partner with Us page or call 877-218-4070 to craft durable care frameworks that guarantee continuity in uncertain times. Take action today to protect your finances and patient care—your forward-thinking move could define success tomorrow.