CMS Extends Telehealth & Audio‑Only Flexibilities Through September 30, 2025

CMS has extended critical telehealth provisions—including audio-only services and remote face‑to‑face recertifications for home health and hospice—through September 30, 2025, under a six-month continuing resolution  .

⸻

🗓️ What Was Extended? • Home-based telehealth services: Continued waiver of originating-site and geographic restrictions through 9/30/2025 for both non-behavioral and behavioral health services  . • Audio-only telehealth: Providers may bill standard E/M codes (99202–99215) with modifier 93 (or FQ for FQHC/RHC) when patients can’t or won’t use video  . • Expanded provider eligibility & distant-site options: All Medicare-enrolled providers—including PTs, OTs, SLPs, clinical psychologists, FQHCs, and RHCs—can furnish telehealth  . • Hospice face-to-face recertifications: Remote face-to-face encounters via audio-video remain allowed through 9/30/2025  . • Mental/behavioral health in-person waivers: Delayed requirement for in-person visits within 6 months of initiation and annually thereafter—through 9/30/2025 for practitioners, and through 1/1/2026 for FQHCs/RHCs  .

⸻

⚙️ Why This Matters for Home Health & Hospice

Area Key Impact Access & Equity Removes tech and location barriers, enabling remote visits for vulnerable patients. Financial Stability Ensures continued reimbursement streams through Q3 2025. Regulatory Relief Reduces administrative burden and supports telehealth-coded workflows. Operational Efficiency Enables planning for hybrid in-home and telehealth recertification workflows.

⸻

✅ Compliance & Billing Guide 1. Billing Requirements • Report standard E/M codes (99202–99215) with modifier 93 (or FQ for FQHC/RHC) for audio-only claims  . • Use POS 10 for home-originating site or POS 02 for facility-based telehealth  . 2. Documentation Essentials • Note the provider’s capability for video. • Record patient’s inability or refusal to use video. • For hospice recertification, indicate use of real-time audio-video. 3. Tech & Platform Compliance • Ensure HIPAA-secure audio-video platforms for remote recertifications    . 4. Policy & Workflow Updates • Update internal telehealth policies, billing protocols, and staff training to reflect these extensions.

⸻

❓ FAQ

Q1: Where can I find the CMS Telehealth Services list (including audio-only)? Visit the official CMS telehealth services list to review approved CPT/HCPCS codes and check audio-only eligibility. 🔗 CMS Telehealth Services List

Q2: Is audio-only allowed for hospice face-to-face recertifications? No. Hospice recertification must use real-time audio and video; audio-only is not permitted for these encounters     .

Q3: What happens after September 30, 2025? Authorization reverts to pre-pandemic rules—geographic limits return and audio-only telehealth is restricted—unless Congress acts    .

Q4: Are behavioral health telehealth waivers still in place? Yes—behavioral and mental health telehealth flexibilities (including audio-only and in-person visit waivers) extend through 9/30/2025, and for FQHC/RHC behavioral care through 1/1/2026  .

⸻

🔍 Final Thoughts

Home health and hospice organizations should immediately: • Incorporate extended telehealth languages into standard operating procedures. • Train clinicians and billing teams on using modifier 93/FQ and POS codes. • Ensure telehealth platforms meet service requirements and documentation standards. • Prepare for potential reversal after September 2025 with contingency planning.

By proactively aligning workflows now, your organization can maintain equitable access and reimbursement through this extension—and stay ahead of future policy shifts.

⸻