The in-person visit within 6 months of telehealth requirement has been delayed through December 31, 2027.

Yes. Two-way, real-time audio-only telehealth is still permitted under Medicare for mental/behavioral health services.

• Reimbursed at parity with video visits.
• Document why audio-only was clinically appropriate (e.g., patient lacks technology or broadband).

Yes. For mental health services, the broader flexibilities remain:

• Patients can receive telehealth at home.
• Location does not matter (urban or rural).

• Telehealth claims may be denied if the requirement isn’t met.
• Practices should track timelines and remind patients in advance.
• Consider scheduling annual “check-in” visits in person to stay compliant.

Yes. They apply to psychiatrists, psychologists, clinical social workers, and other Medicare-recognized behavioral health providers.

• Note the date and provider of the last in-person visit.
• If using an exception, clearly state the reason (e.g., patient unable to safely attend in-person).
• Keep documentation consistent in case of audit.

• Reassure them: Telepsychiatry remains available at home.
• Explain the new check-in visit requirement and help schedule it.

• APA strongly supports eliminating the 6-month in-person requirement, arguing that it creates barriers for rural and underserved patients. Advocacy efforts are ongoing, and changes may still occur through legislation.
• For patients with barriers, discuss whether an exception can be applied and document accordingly.

• The rule says: the patient must have an in-person visit with the same provider or a same-specialty provider within the same group before initiating telehealth.
• That means:
  • If it’s for psychiatric services the in-person visit must be with a psychiatrist (either the treating psychiatrist or another psychiatrist in the same group).
  • If it’s for therapy the in-person visit must be with a clinician of that specialty (e.g., psychologist, LCSW) in the same group.

So, psychiatrists and therapists each need their own “initial in-person” unless they’re the same specialty within the group.