The evolution of telehealth: What to expect in 2025

Before COVID-19, telehealth was a niche service primarily used for mental health, remote monitoring, and rural care, with basic video calls and phone consultations. Regulatory barriers, limited insurance reimbursement, and provider hesitancy slowed adoption.

The pandemic rapidly transformed telehealth into a mainstream care model. Usage skyrocketed — telehealth visits in the U.S. surged over 150% from 2019 to 2020, according to the Centers for Medicare Medicaid Services (CMS). Governments relaxed regulations, allowing cross-state practice and expanding Medicare/Medicaid coverage. Emergency funding, like the CARES Act, bolstered telehealth infrastructure.

Healthcare systems quickly integrated advanced telehealth platforms, enabling video consultations, remote monitoring and secure electronic health record (EHR) access. Patients became more comfortable using virtual care for mental health, chronic disease management and specialty services like cardiology and dermatology. Telehealth evolved from a temporary solution to an essential healthcare tool.

With telehealth services expanding, it is essential that organizations educate providers, staff and patients on the virtual care process. These standards help with the quality of patient care in virtual settings. Accreditors evaluate various aspects of telehealth programs, with criteria differing across accreditation bodies. Key areas include:

1. Clinical processes: Protocols for virtual care, such as triage, assessments, diagnoses, treatment plans, prescriptions and follow up
2. Patient monitoring: Quality assurance systems to track health outcomes and address complaints or adverse events
3. Clinical documentation: Proper documentation, including patient consent forms and encounter notes, is required

The overall goal is to ensure that telehealth programs provide safe, high quality care to patients while adhering to industry best practices and regulations. As we continue to provide telehealth services in the upcoming 2025 new year, it’s also important to stay updated with the Medicare Physician Fee Schedule updates and changes.
 

Telehealth services under the physician fee schedule (PFS) in 2025

Beginning Jan. 1, 2025, telehealth services will see limitations on patient location, primarily allowing telehealth originating sites only in certain rural and underserved areas while still permitting two-way, real time audio-only communication in specific situations where a patient cannot or does not consent to video technology. However, CMS plans to preserve some flexibilities and expand telehealth access where appropriate. It should be noted that the CPT® Editorial Panel decided to delete audio-only telephone services CPT codes 99441-99443 and added seventeen new CPT codes 98000-98016.

Some of the key changes in telehealth services in 2025 include:

• New services: Several services will be added to the Medicare Telehealth Services List, including caregiver training (provisionally) and pre-exposure prophylaxis (PrEP) counseling (permanently).
• Frequency limitations: The suspension of frequency limits for subsequent inpatient visits, subsequent nursing facility visit, and critical care consultations will continue in 2025.
• Audio-only communication: Medicare telehealth can use audio-only technology for home-based services when video is not feasible or acceptable to the patient.
• Practice location flexibility: Distant site practitioners can continue using their enrolled practice locations for telehealth services provided from home.
• Virtual direct supervision: Direct supervision by a physician can be done virtually (via audio and video technology) 
  • (1) For services furnished incident-to a physician or other practitioner’s professional service, when provided by auxiliary personnel employed by the billing physician or supervising practitioner and working under his or her direct supervision, and for which the underlying HCPCS code has been assigned a PC/TC indicator of “5” and services described by CPT code 99211, and 
  • (2) For office or other outpatient visits for the evaluation and management of an established patient who may not require the presence of a physician or other qualified healthcare professional. 
  • For all other services furnished incident-to that require the direct supervision of the physician or other supervising practitioner, CMS will continue to permit direct supervision to be provided through real time audio and visual interactive telecommunications technology only through Dec. 31, 2025.
• Teaching physician virtual presence: Teaching physicians can continue using virtual presence for billing purposes in teaching settings, but only for services provided through telehealth until Dec. 31, 2025.

The 2025 changes to the Telehealth Physician Fee Schedule (PFS) represent a significant step forward in enhancing access to healthcare services and improving care delivery through telehealth. These updates aim to address the evolving needs of both patients and providers by expanding eligible services, adjusting payment rates and fostering greater flexibility in care options. 

As the telehealth landscape continues to evolve, these adjustments underscore the importance of adapting to technological advancements while focusing on patient-centered care. Providers will need to stay informed and prepared to navigate these changes, ensuring they can continue to offer high quality care in a rapidly changing healthcare environment.

Khadijah Hasan, MHSA, RHIA, CPC, is an ambulatory services consultant at Solventum.