The future of Medicare telehealth is once again uncertain. Earlier this year, the American Psychiatric Association (APA) urged practices to prepare for the possible end of key flexibilities, including the requirement that Medicare beneficiaries receive an in-person visit within six months of a telemental health appointment. While this rule has never been implemented—thanks to the COVID-19 Public Health Emergency and advocacy efforts to delay or eliminate it—the clock is now ticking again.

Unless Congress acts, the Medicare telehealth flexibilities are set to expire on September 30, 2025. With lawmakers currently deadlocked on the annual federal funding bill, the risk of a government shutdown looms large. Absent a funding agreement that specifically includes an extension of telehealth provisions, the in-person requirement for telemental health will go into effect.

Looking further ahead, flexibilities allowing clinicians to prescribe controlled medications via telemedicine—including audio-only visits for opioid use disorder treatment—are authorized through December 31, 2025.

The coming weeks will be pivotal. Congress must decide whether to extend these telehealth provisions or allow a major shift in the delivery of mental health care for Medicare beneficiaries. The DEA must also decide whether to finalize the telemedicine special registration, extend the current flexibilities, or create a telehealth cliff for patients and physicians.

To prepare for the potential shift, read the blog from November 2024.