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COVID-19 Telehealth Policies Wind-down Timeline

The Biden Administration announced that the COVID-19 public health emergency (PHE) will end on May 11, 2023. The following timeline depicts the when and how telehealth policies enacted during the COVID-19 pandemic will wind-down at the end of the public health emergency (PHE) declaration.

These policy provisions are accurate as of the publication date: March 13, 2023, and can change at any time. State, local, and private actions may affect the policies and requirements in your practice.

January 30, 2023

  • White House announced that the COVID-19 PHE will end on May 11, 2023.

May 11, 2023

  • End of the Public Health Emergency Declaration.

May 12, 2023

  • Requirements back in place around virtual prescribing of controlled substances. Practitioners will need to have seen a patient in person at least once before issuing a prescription for a controlled substance. Learn more on virtual controlled substance prescribing here.
  • RPM services for Medicare once again restricted to established patients, requiring a new patient E/M visit before billing for RPM.
  • Practitioners will once again need to use HIPAA-compliant communications software.
  • Practitioners must be licensed in every state they are providing services to bill Medicare (note that most state PHEs have already expired and most state-based licensure requirements are back in place).

October 10, 2023

(151 Days after end of PHE)

  • Medicare coding for audio-only telehealth services transitions from telephone codes to E/M + audio modifiers.

November 7, 2023

(180 Days after end of PHE)

  • Requirements around in-person visits for the prescription of controlled substances resume for any patients that established a controlled substances prescription via telehealth during the PHE.

January 1, 2024

  • Telehealth services in Medicare receive the lower facility fee rather than the higher non-facility fee that they have received throughout the PHE.
  • Virtual direct supervision in Medicare expires, but behavioral health clinicians can be supervised under general supervision on a permanent basis and general supervision can be virtual on a permanent basis.

January 1, 2025

  • Extended Medicare flexibilities passed in the Consolidated Appropriations Act, 2023, expire:
    • Required initial in-person exam prior to telemental health comes into effect.
    • Required annual in-person visit for the provision of telemental health comes into effect, subject to exception based on clinical decision-making.


  • Audio-only provision of mental health services in Medicare.
  • The patient’s home as an acceptable originating site in Medicare.
  • General supervision for behavioral health clinicians and virtual general supervision in Medicare.

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