Resources & Reports

With the recent extension of the telehealth waivers (until September 30, 2025) to allow services to continue being reimbursed without stringent rural and facility-based requirements, one key distinction deserves attention: Communication Technology-Based Services (CTBS). The Centers for Medicare and Medicaid Services (CMS) separated CTBS from traditional telehealth in 2019 when they announced through their 2019 Physician Fee Schedule (PFS) reimbursement for remote services that do not fall under “Medicare telehealth services.” These services, although delivered in an electronic format, don’t qualify as telehealth (in Medicare’s eyes) and providers won’t find the majority of these CTBS codes on the list of services eligible for telehealth coverage in Medicare.

Last Friday, Congress passed a new Continuing Resolution (CR) to maintain federal government funding and extend temporary Medicare telehealth flexibilities to September 30, 2025 (pushing back the previous expiration date of March 31). President Trump signed it into law shortly after. While this extension provides some relief, telehealth stakeholders now face yet another looming deadline in September, keeping long-term policy uncertainty in play. Meanwhile, lawmakers continue to stress the need for data to justify permanent telehealth coverage.  Two recent studies from the University of Michigan’s Institute for Healthcare Policy and Innovation may help to alleviate concerns that expanded Medicare telehealth coverage will increase healthcare utilization and spending:

• Telehealth and Outpatient Utilization: Trends in Evaluation and Management Visits Among Medicare Fee-For-Service Beneficiaries, 2019-2024
• Association Between Telehealth Use and Downstream 30-Day Medicare Spending

CCHP’s March Newsletter is here! This month’s newsletter includes the following topics – Upcoming Medicare Telehealth Changes: What You Need to Know; AI in Healthcare 2025: Trends, Adoption, and the Evolving Regulatory Landscape; Telehealth’s Evolution in California: Progress, Challenges, and Opportunities; Latest Developments in CCHP’s Telehealth Policy Finder and Policy Trend Map; For California Farmworkers, Telehealth Visits With Mexican Doctors Fill a Gap; Medicaid Telehealth Policies Strain FQHCs, Worsening Workforce Shortages and Access to Care.

Telehealth billing is an increasingly complicated policy area given that billing rules vary widely across different payers, including Medicare, Medicaid, and commercial insurance. This newsletter seeks to provide information on provider and payer coding considerations that dictate current billing practice. We will also address related research and a few areas of confusion when it comes to billing challenges for telehealth services. Note that while the Medicare telehealth waivers, currently set to expire on March 31, 2025, are not the primary focus of this newsletter, they are briefly addressed at the end of this write-up.

The Drug Enforcement Administration (DEA) and the Department of Health and Human Services (HHS) have announced a delay in the effective date for the recently issued final rules regarding the telemedicine prescribing of buprenorphine and telemedicine for Veterans Affairs Patients (which are further detailed below). Originally scheduled to become effective February 18, the rules will now take effect on March 21, 2025. This decision aligns with the White House memorandum issued on January 20, which called for “A Regulatory Freeze Pending Review” to allow agencies further review of any fact, law, and policy considerations prior to proposing, issuing, or finalizing any regulatory activities. In particular, the DEA/HHS announcement cites the third paragraph of the Freeze Memo, which ordered agencies to consider postponing the effective dates for any recently published rules that have yet to take effect.