Effective October 1, 2025, many of the telehealth flexibilities granted during the COVID-19 public health emergency have expired. A continuing resolution failed to pass by midnight on September 30th, creating a telehealth cliff for many Medicare beneficiaries across the country. Here’s what it means for psychiatric and mental health care:

• The in-person visit waiver expired: starting October 1, patients must have had an in-person mental health visit with that provider (or a same-specialty provider in their group) within six months before initiating telehealth, and then at least annually thereafter.
  • Two exceptions to the subsequent 12-month period in-person requirement that require a clear justification documented in the patient’s medical record:
    • Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate.
    • Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability.
• The waiver that allowed audio-only telehealth for most mental/behavioral health services will remain permitted (i.e. two-way, real-time audio) under Medicare for mental health treatment.
• Telehealth visits for mental health services will not lose broader location and geographic flexibilities: the ability for Medicare patients to receive telehealth in home settings (outside of behavioral health) and in urban areas may be reinstated to pre-pandemic restrictions.

APA strongly supports efforts to permanently remove the six-month in-person requirement. We recognize that telehealth has become an indispensable tool in expanding access to mental health care, particularly for those in rural and underserved areas. A rigid in-person evaluation requirement creates unnecessary barriers to care, undermining the progress made in telehealth accessibility.

To learn more about the requirements see the CMS Medicare Learning Network: MLN1986542 – Medicare & Mental Health Coverage (.pdf).