CMS Issues Updated Telehealth FAQs in Light of Pre-COVID-19 Telehealth Waivers
CMS updated its Telehealth FAQs for 2025 in light of the expiration of the telehealth flexibilities created during the COVID-19 Pandemic. The COVID-19 telehealth flexibilities expired on October 1, 2025. Beginning October 1, 2025, except for behavioral health services, Medicare beneficiaries will generally need to be located in a medical facility and in a rural area to receive Medicare telehealth services; physician therapists, speech-language pathologists, and audiologists can no longer furnish Medicare Telehealth services; and hospitals may no longer bill for outpatient therapy or diabetes self-management training and medical nutrition therapy services when furnished remotely by hospital staff to beneficiaries in their homes. CMS also clarified that beginning October 1, 2025, physicians and practitioners may use two way real time audio-only communication technology for any telehealth service furnished to a patient in their home, provided that the physician is technically capable of using the audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology.
CMS Issues Claims Hold Update in Light of Government Shutdown
CMS issued a Claims Hold Update in which CMS has instructed all Medicare Administrative Contractors (“MACs”) to continue to temporarily hold claims with dates of service of October 1, 2025 and later for services impacted by the expired Medicare legislative payment provisions. Such claims include all claims paid under the Medicare Physician Fee Schedule, ground ambulance transportation claims, and all Federally Qualified Health Center claims. Although providers may continue to submit claims, CMS will not release payment for claims made until the hold is lifted. CMS recommends that practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025 may want to provide beneficiaries with an Advanced Beneficiary Notice of Noncoverage.
OIG Finds Limited Behavioral Health Providers Amongst Medicare Advantage and Medicaid Managed Care Plans
An HHS-OIG review found that many Medicare Advantage and Medicaid Managed Care plans had limited networks of behavioral health providers. In reviewing data from 60 plans in 10 counties, HHS-OIG found that 30 of the 40 Medicare Advantage plans had less than 25% of the counties’ behavioral health workforce in their networks. For the Medicaid Managed Care plans, nine out of 20 plans had less than 25% of the counties’ workforce in their networks. As a result, enrollees in those plans did not have access to 75% or more of the behavioral health providers in their counties. Moreover, in 26 Medicare Advantage plans and in seven Medicaid Managed Care plans, at least one-third of the providers listed in their networks were inactive. In 18 Medicare Advantage plans and one Medicare Managed Care plan, more than 60% of providers listed in their networks did not provide a single service to enrollees. On average, plans had more social workers and psychologists who were inactive, compared to psychiatrists.
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