As Congress continues to find a solution to reopen the government, CMS continues to put out guidance for telehealth services. Below is the latest information that CMS has shared:

Telehealth Update

6-month in-person requirement

As of October 1, 2025, Medicare beneficiaries that are new patients will require an in-person visit prior to a telehealth visit. However, if a beneficiary began receiving mental health services on or before September 30, 2025, then they would not be required to have an in-person visit within 6 months; rather, they will be considered established and will instead be required to have at least one in-person visit every 12 months. There are 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.

For behavioral health visits furnished by RHCs and FQHCs where the patient is present virtually, CMS has delayed in-person visit requirements at least until January 1, 2026.

Virtual Supervision of residents:

Through December 31, 2025, CMS is continuing to allow teaching physicians to have a virtual presence in all teaching settings, but only for services furnished as a Medicare telehealth service. This will continue to permit teaching physicians to have a virtual presence during the key portion of the Medicare telehealth service for which payment is sought, through audio/video real-time communications technology.

For more information from CMS see: CMS 10/1 Update Telehealth FAQ Calendar Year 2025 (.pdf).

Flexibilities for prescribing of controlled medications via telehealth:

Through December 31, 2025, the DEA is continuing to allow the COVID-19 pandemic era flexibilities for the prescribing of controlled medications via telemedicine. At the beginning of 2025, the DEA released a proposed rule for a special registration related to prescribing controlled substances via telemedicine when the prescribing practitioner has never conducted an in-person medical evaluation of the patient prior to the issuance of the prescription. The proposed rule has not been finalized and the flexibilities are set to expire at the end of the year without further action.

Claims Hold Update

In anticipation of possible congressional action. 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 passed under the Full-Year Continuing Appropriations and Extensions Act, 2025. This includes all claims paid under the Medicare Physician Fee Schedule, Ground ambulance transport claims, and all Federally Qualified Health Center Claims. Providers may continue to submit these claims, but payment will not be released until the hold is lifted. For more information visit: CMS MLN Connects Newsletter for October 15, 2025: Claims Hold Update.