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Adapting to Telemedicine Reforms: Key Updates and Impacts in 2025
Practice Management & Growth

Adapting to Telemedicine Reforms: Key Updates and Impacts in 2025

Published: 17/12/2024

Written by: Emily Montemayor, Medical Coding Support Manager

Table Of Contents

Telemedicine has fundamentally transformed healthcare delivery, strengthening the patient-provider relationship by overcoming traditional barriers such as geographic constraints, financial limitations, and logistical challenges. One of the areas where telemedicine has had a particularly profound impact is in mental health care. A 2022 survey conducted by the Kaiser Family Foundation and CNN revealed that 90% of the public believes there is a mental health crisis in the United States. This is underscored by the fact that nearly half of young adults and a third of all adults had reported experiencing anxiety frequently over the past year. 

Telemedicine, also commonly referred to as telehealth, has played a vital role in addressing this crisis by expanding access to mental health services, especially in underserved rural areas, where a shortage of mental health professionals has been a long-standing issue. Virtual consultations allow providers to extend their reach to these populations, reducing wait times, overcoming geographic barriers, and easing the burden of travel. As the healthcare landscape continues to evolve, telemedicine plays a central role in improving care coordination, expanding access, and addressing gaps in healthcare equity (Stoltzfus et al., 2023).

Through telemedicine, healthcare professionals can:

  • Engage with more patients
  • Monitor their progress
  • Offer timely interventions
  • Increase convenience and efficiency 

By providing a confidential and convenient platform for virtual visits, telemedicine fosters an open and ongoing dialogue between patients and providers, contributing to improved mental health management. This has been especially important in addressing conditions such as anxiety, depression, and PTSD, where continuity of care and regular check-ins are crucial (Kebler et al., 2024).

Beyond mental health, telemedicine has shown remarkable versatility in various medical specialties, including primary care. In conditions like dementia and Alzheimer's disease, telemedicine enables remote assessments, virtual consultations, and patient education, all of which contribute to better care coordination and treatment adherence. By ensuring that patients receive timely interventions, telemedicine helps improve overall patient outcomes and enhances the quality of life for those with chronic conditions (Ezeamii et al, 2024; AMA, 2024).

Telemedicine also plays a crucial role in reducing healthcare disparities, particularly for vulnerable populations who face systemic barriers to care. It offers an equitable solution by making healthcare more accessible, particularly for those in rural or underserved areas, as well as individuals with mobility challenges or limited transportation options (AHRQ, 2020; HRSA, 2024). Telemedicine has proven to be more than just a convenience; it is a vital tool that fosters flexibility in care delivery, creating a more inclusive healthcare system that reaches a broader spectrum of individuals.

In this article, we’ll dive into the evolution of telemedicine, examining its transformative journey, its current role in healthcare delivery, and the upcoming reimbursement changes that will shape how telemedicine is practiced in an ever-evolving healthcare landscape.

The Evolution of Telemedicine and Mental Health Care Expansion

The integration of telemedicine into healthcare systems gained momentum in the 21st century, driven by advancements in the internet, video conferencing, and the proliferation of smartphones. However, it was the COVID-19 pandemic that catalyzed the widespread adoption of virtual care, prompting swift policy and insurance framework adjustments to support its growth. What was once seen as a supplementary service is now an essential component of modern healthcare, playing a pivotal role in transforming care delivery and meeting the evolving needs of diverse patient populations.

In the realm of mental and behavioral health care, telemedicine has dismantled long-standing barriers that previously hindered access to care. Stigma, particularly in smaller or close-knit communities, often prevents individuals from seeking mental health services, due to concerns over privacy and judgment. By offering a confidential, convenient platform for care, telemedicine reduces these obstacles and makes mental health services more accessible. Virtual visits not only offer a private environment for therapy, but also create a less intimidating space for individuals to engage in their care, promoting openness and willingness to seek help (Coombs et al., 2021).

For rural populations, where transportation challenges often limit access to healthcare, telemedicine has proven transformative. Patients can now connect with providers from the comfort of their homes, eliminating the need for lengthy travel or costly arrangements. This increased accessibility has resulted in more consistent engagement with care, ensuring that patients can continue to receive the therapy necessary to manage conditions like anxiety, depression, and PTSD. Telemedicine facilitates regular, uninterrupted sessions, which are critical for maintaining the continuity of care that is essential for these individuals' mental well-being (Coombs et al., 2021).

By bridging geographic and logistical gaps, telemedicine has expanded access to vital services and reinforced the continuity of care, enabling patients to stay actively engaged with their treatment plans. As telemedicine continues to evolve, it is poised to remain an integral part of the healthcare landscape, improving care delivery and patient outcomes across a broad range of conditions.

Telemedicine’s Role During and After the COVID-19 Pandemic

The COVID-19 pandemic dramatically accelerated the adoption of telemedicine, as the need for alternative care delivery methods became essential in response to social distancing mandates and lockdowns. Research highlights the extent of this surge, with a New York hospital system seeing a dramatic rise in telemedicine visits, from fewer than 500 per month to nearly 83,000 during the height of the pandemic (Lau et al., 2020). This shift was not merely a matter of convenience but a critical lifeline, ensuring continuity of care when in-person visits were restricted due to the public health crisis.

A study involving 14 healthcare providers from 11 different service agencies in a southeastern state revealed several insights into these rapid adaptations (DeHart et al., 2024). The findings were grouped into three major themes: 

  1. Dynamic Adaptations: Providers embraced hybrid services, streamlined workflows, and collaborative decision-making to ensure continuous patient care. 
  2. Regulatory and Insurance Adjustments: Policies were relaxed, particularly regarding reimbursement for telemedicine services, enabling greater financial sustainability for virtual care. 
  3. Patient Engagement: Telemedicine significantly impacted patient engagement, fostering greater openness to virtual care, increasing family-level accessibility, and contributing to reduced no-show rates.

As the pandemic's immediate effects subside, the temporary regulatory and reimbursement flexibilities introduced during this period are set to expire at the end of 2024 unless extended by Congress (CMS, 2024). This looming uncertainty poses a risk to continued access to telemedicine services, especially for rural populations and individuals with mobility challenges. Ongoing legislative discussions will determine whether telemedicine will maintain its prominent role in healthcare delivery or return to pre-pandemic limitations, potentially disrupting the gains made in accessibility and care continuity.

Reimbursement Implications Post-Pandemic

As we transition into 2025, telemedicine reimbursement faces significant changes, particularly with new and deleted CPT codes, in addition to Medicare’s new policies, and the looming expiration of temporary pandemic-related flexibilities. These updates will impact providers’ ability to deliver care remotely, especially for vulnerable populations who depend on telemedicine services. Below is an overview of key developments to understand how telemedicine reimbursement and coding are evolving.

New and Deleted Telemedicine Codes for CY 2025

New Telemedicine Codes: For CY 2025, several new CPT® codes will be introduced to reflect emerging healthcare needs, including services for mental health and remote patient monitoring. These new codes include: 

98000-98007: Synchronous audio-video telemedicine visits, requiring a medically appropriate history and/or examination.

  • For New Patients:
      • 98000: Requires straightforward medical decision-making or 15-29 minutes
      • 98001: Requires low medical decision-making or 30-44 minutes
      • 98002: Requires moderate medical decision-making or 45-59 minutes
      • 98003: Requires high medical decision-making or 60-74 minutes
        • 75+ minutes or longer, use prolonged services code 99417 (Non-Medicare) or G2212 (Medicare)
  • For Established Patients:
    • 98004: Requires straightforward medical decision-making or 10-19 minutes
    • 98005: Requires low medical decision-making or 20-29 minutes 
    • 98006: Requires moderate medical decision-making or 30-39 minutes
    • 98007: Requires high medical decision-making or 40-54 minutes 
      • 55+ minutes or longer, use prolonged services code 99417 (Non-Medicare) or G2212 (Medicare)

98008-98015: Synchronous audio-only telemedicine visits (require >10 minutes of medical discussion).

  • For New Patients:
      • 98008: Requires straightforward medical decision-making or 15-29 minutes
      • 98009: Requires low medical decision-making or 30-44 minutes
      • 98010: Requires moderate medical decision-making or 45-59 minutes
      • 98011: Requires high medical decision-making or 60-74 minutes
        • 75+ minutes or longer, use prolonged services code 99417 (Non-Medicare) or G2212 (Medicare)
  • For Established Patients:
    • 98012: Requires straightforward medical decision-making or 10-19 minutes
    • 98013: Requires low medical decision-making or 20-29 minutes 
    • 98014: Requires moderate medical decision-making or 30-39 minutes
    • 98015: Requires high medical decision-making or 40-54 minutes 
      • 55+ minutes or longer, use prolonged services code 99417 (Non-Medicare) or G2212 (Medicare)

98016: Brief communication technology-based services with established patient (e.g., virtual check-in), and 5-10 minutes of medical discussion

These new codes are designed to accommodate the growing demand for virtual care in specialties such as behavioral health, primary care, and neurology. If during the encounter, audio-video connections are lost and only audio is restored, it’s appropriate to report the service that accounted for the majority of the time of the interactive portion of the service. For services that are asynchronous (i.e., not live in real-time), see the Online Digital Evaluation and Management Services (99421–99423).

Deleted Telemedicine Codes: As part of updates to the CPT code set, the original audio-only telemedicine codes (99441–99443) will be deleted effective January 1, 2025. These deletions are intended to reduce redundancy and align with the introduction of new, streamlined codes that better capture the scope and coherency of telemedicine services. Providers will need to utilize updated coding structures to accurately report audio-only and other telehealth services moving forward.

Changes in Policies

Medicare Telemedicine Policies for CY 2025: Medicare’s telemedicine policies for 2025 continue to evolve with key updates. Notably, Medicare has chosen not to recognize the new telemedicine codes 98000–98015, and will not be eligible for reimbursement. Instead, providers must continue to use standard Evaluation and Management (E/M) codes (e.g., 99202–99215) along with the appropriate modifier (e.g., 95 for audio-visual, or 93 for audio-only) and place of service for most telemedicine services. Additionally, Medicare has decided to recognize the new brief virtual check-in CPT code 98016, which will replace HCPCS Level II code G2012, set to be deleted for redundancy. 

Another significant update is the permanent expansion of telemedicine coverage for behavioral health services, improving access to mental health care, especially for patients in underserved areas. Other services remain provisional, with ongoing evaluation. Telemedicine services for eligible distant-site practitioners working from home will continue through 2025, with further reviews to follow.

Commercial Payer Variations: While commercial payers have been more flexible during the pandemic, many are now tightening their requirements for telemedicine services. Variations in coverage, particularly for specialties like behavioral health, are becoming more common, and payers may introduce new coding, documentation standards, and reimbursement models. Providers should stay informed about payer-specific updates.

State-Level Legislative Trends: State-level telemedicine adoption remains varied, with some states moving toward permanent policies while others implement more restrictive regulations. Providers must stay updated on state-specific legislative trends to navigate different rules for service delivery and reimbursement.

Looking Ahead: Opportunities, Challenges, and Advocacy for Telemedicine

As telemedicine continues to evolve, its role in value-based care models is set to expand, particularly in managing chronic conditions, enhancing care coordination, and improving access to preventive care. Virtual visits offer providers a unique opportunity to improve patient outcomes and reach underserved populations. However, achieving equitable access remains a significant challenge, especially with the expiration of pandemic-era flexibilities and the reimplementation of geographic restrictions.

To unlock telemedicine’s full potential, sustained innovation in policy and technology is essential. Legislative efforts must focus on permanently solidifying telemedicine flexibilities, such as geographic waivers and audio-only services, while addressing barriers like broadband disparities. Technological advancements, including seamless platform integration and improved infrastructure, will further support the accessibility and sustainability of telemedicine in underserved areas.

Providers must also adapt to evolving telemedicine policies and codes. Investments in staff training, technology upgrades, and streamlined documentation processes will be critical for staying compliant with new regulations and minimizing billing challenges. As payer guidelines shift, particularly regarding geographic restrictions and reimbursement policies, providers need to proactively align their practices to optimize reimbursement and deliver high-quality care remotely.

Telemedicine has proven transformative in areas like mental health, where it reduces barriers such as stigma, travel, and provider shortages. Its continued growth across specialties underscores the need for advocacy to ensure its long-term viability. Healthcare professionals should engage with legislators to expand coverage, maintain critical flexibilities, and address systemic challenges, such as internet access in rural areas.

By remaining informed, advocating for equitable access, and embracing innovation, providers can shape telemedicine's future and thrive in an evolving healthcare landscape. The ability to revolutionize healthcare delivery depends on sustained collaboration among policymakers, technology developers, and healthcare providers to ensure telemedicine remains a valuable and viable tool for all.

References

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