Telehealth Modernization Act of 2025: What Healthcare Providers Need to Know

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The Telehealth Modernization Act of 2025, introduced by U.S. lawmakers on September 2, aims to solidify many of the telehealth flexibilities that were initially adopted during the COVID-19 public health emergency. Without congressional intervention, these key pandemic-era waivers are set to expire on September 30, 2025, potentially creating a so-called “telehealth cliff” for Medicare beneficiaries and providers alike.

The bipartisan legislation, led by Representatives Buddy Carter (R-GA) and Debbie Dingell (D-MI), would extend critical provisions through September 30, 2027, while introducing new measures to enhance patient safety, expand access, and address fraud risks.

Here’s what healthcare providers, payers, and patients should know about the Telehealth Modernization Act of 2025:

1. Expanded Medicare Telehealth Access

The Act aims to maintain the broader access to telehealth that became a hallmark of the pandemic response. Key provisions include:

• Geographic and originating site waivers: Patients in both rural and urban areas can continue to access telehealth services without traveling to a designated “originating site” like a clinic or hospital.
• Expanded provider types: Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can continue providing telehealth services as distant-site providers.
• Audio-only flexibility: Certain telehealth services can continue to be delivered via phone, ensuring patients without access to video technology are not left behind.

Implication for providers: Maintaining these flexibilities allows healthcare organizations to sustain telehealth programs that reach underserved populations, including rural patients and those with mobility challenges.

2. Delayed Behavioral Health In-Person Requirements

One of the critical challenges in telehealth for behavioral health has been the Medicare requirement for some in-person visits. The Act would:

• Delay in-person visit mandates for Medicare-covered behavioral health services provided by FQHCs and RHCs until 2027.
• Ensure continuity of care for mental health and substance use disorder patients, many of whom rely on telehealth for regular follow-up visits.

Implication for providers: Clinics can continue offering tele-behavioral health without disrupting care continuity, improving access for patients with chronic mental health needs.

3. Extending “Hospital at Home” Programs

The Act supports innovation in hospital care delivery by extending the Acute Hospital Care at Home waivers:

• The waivers would continue through 2030, allowing eligible patients to receive hospital-level care in their homes.
• The Department of Health and Human Services (HHS) must report program outcomes to Congress by September 30, 2028, providing data on cost, quality, and patient safety.

Implication for providers: Hospitals can safely expand home-based care programs, reducing inpatient burden and potentially improving patient satisfaction.

4. New Fraud Prevention Measures

To safeguard against telehealth and medical fraud, the Act introduces new oversight requirements:

• High-risk lab tests: HHS must identify lab tests vulnerable to fraud starting in 2026.
• Prepayment reviews: In 2028, the Centers for Medicare & Medicaid Services (CMS) will initiate prepayment reviews for specific equipment and prosthetics claims.

Implication for providers: Healthcare organizations must ensure accurate coding, documentation, and billing processes to comply with these new safeguards, minimizing risk of audits and penalties.

5. Support for Chronic Care and Patients with Limited English Proficiency (LEP)

The Act recognizes the ongoing need for telehealth in managing chronic conditions and improving health equity:

• Virtual chronic care programs: The Diabetes Prevention Program can continue via telehealth through 2030.
• LEP guidance: HHS is required to provide telehealth guidance for patients with limited English proficiency.
• Home-based rehab: In-home cardiac and pulmonary rehabilitation via audio-video telehealth remains permissible until January 1, 2027.

Implication for providers: Telehealth can continue to serve as a critical tool for chronic disease management, while expanding access for linguistically diverse patients.

What’s Next for Telehealth Policy?

Lawmakers may pass the Telehealth Modernization Act of 2025 or rely on a continuing resolution to prevent disruption in Medicare telehealth services. Providers and practices should stay informed and be prepared to adapt their telehealth workflows to align with any new permanent regulations.

Key takeaway: The Act reflects a broader trend toward modernizing telehealth beyond the pandemic, supporting access, equity, and innovative care delivery while introducing accountability measures to protect against fraud.

How Practices Can Stay Ahead with Telehealth Billing

The Telehealth Modernization Act of 2025 creates exciting opportunities for healthcare providers—but it also introduces complexities that can affect billing, reimbursement, and compliance. Practices must ensure they are properly coding telehealth services, tracking audio-only visits, and documenting care for chronic conditions, behavioral health, and home-based programs.

This is where expert telehealth billing and revenue cycle management services can make a difference:

• Accurate coding and documentation: Ensure every telehealth visit is billed correctly under Medicare and commercial payer guidelines, including new provisions for audio-only and home-based care.
• Compliance with evolving regulations: Stay up to date with in-person visit requirements, fraud prevention measures, and LEP guidance to avoid audits or denials.
• Optimized reimbursement: Maximize revenue from telehealth services while reducing administrative burden on your staff.
• Support for chronic and behavioral care programs: Efficiently manage billing for virtual Diabetes Prevention Programs, cardiac and pulmonary rehab, and mental health services.

By partnering with a specialized revenue cycle management team, practices can confidently expand telehealth offerings, enhance patient access, and navigate the regulatory landscape introduced by the Telehealth Modernization Act—without sacrificing compliance or financial performance.