Telehealth at a crossroads: Your guide to navigating the 2025 reimbursement changes

On September 30, 2025, key Medicare telehealth rules from the pandemic expire. If Congress doesn’t extend them, we’ll return to pre-pandemic restrictions. These changes will likely affect how you deliver care, where your clients can receive it, and how you get paid. It’s crucial to understand what is permanent, what is ending, and how to prepare.

What’s not changing

First, the good news: Telehealth services for mental and behavioral health are here to stay. Marriage and Family Therapists, Mental Health Counselors, and Rural Health Clinics (RHCs), or Federally Qualified Health Centers (FQHCs) can permanently bill Medicare for mental health telehealth services. Importantly, clients can continue to receive these mental health services from their homes, audio-only (phone calls) are still covered, and there are no geographic restrictions for mental health care.

What is changing

Temporary providers are on track to lose eligibility

This expiration hits some providers harder than others. Occupational Therapists (OTs), Physical Therapists (PTs), and Speech-Language Pathologists (SLPs) face a hard stop; they cannot bill Medicare for telehealth services after September 30, 2025, unless they’re in a rural area (sparsely populated places away from towns and cities) or Health Professional Shortage Areas (communities that doesn’t have enough healthcare providers).

This new rule means these providers will only get paid by Medicare for in-person visits, eliminating their telehealth income from Medicare clients. They will need to make major changes to their schedules and office space to handle the shift.

This also creates challenges for patients in rural areas that don’t meet Medicare’s criteria, as well as those with limited transportation or mobility issues outside of these areas, who may lose access to these essential services entirely.

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) could face even more complexity with a mix of expirations

Starting September 30, 2025, community health centers (FQHCs/RHCs) will lose the ability to provide most non-mental health telehealth services (like regular doctor visits) to clients at home or other remote locations. Clients will need to be physically present at a clinic or other approved site (“originating site”) for these types of telehealth appointments.

Additionally, the temporarily higher payment rates FQHCs/RHCs receive will revert to lower, pre-pandemic levels on December 31, 2025 adding financial pressure to these already strained healthcare providers.

Geographic restrictions will be returning

Medicare will only reimburse telehealth appointments for care provided in rural areas or Health Professional Shortage Areas, unless it’s for behavioral health services, SUD, or dialysis.
But here’s the catch: Medicare’s definition of “rural” is complicated and can change. An area might qualify one year and not the next, creating confusion and barriers to care. As one Rural Innovation blog post put it, “The complexity of rural definitions leads to frustration and wasted time for leaders trying to access federal programs.”

On top of that, telehealth is expensive for rural providers. They need reliable high-speed internet, compliant devices, and staff to manage it all, on top of maintaining a physical office. Even when reimbursement is available, profit margins remain razor-thin, and Medicare’s reimbursement rates often fail to keep up with inflation and rising operational costs. These financial pressures may force some practices to reduce or eliminate telehealth services altogether, particularly as the temporary payment increases expire.

So where can clients receive care?

After September 30, 2025, clients can’t use their home as the “originating site” (where they are during the visit) unless care is for behavioral/mental health, substance use disorder (SUD), or home dialysis (these are permanent exceptions).

Pre-pandemic rules require clients to use only approved sites such as doctors’ offices, hospitals, RHCs, or FQHCs.
That’s not the only way telehealth use is tightening. Medicare will require most telehealth appointments to be done via a two-way video call. The only service that will still be reimbursed for audio only (like phone calls) is behavioral health.

For other types of care, Medicare may make an exception and cover a phone call only if the client is unable or unwilling to use video and is calling from their home. However, the provider’s office must still be technically capable of making video calls for the service to be covered.

How to prepare

You don’t have to wait until September. Start planning now with these steps:

1. Assess your practice’s risk

First, get a clear picture of exactly who and what will be affected in your practice. Start by taking stock of your Medicare clients who currently use telehealth from home for occupational, physical, or speech therapy. Consider how many of them face significant barriers to in-person care, such as long distances, mobility challenges, or lack of transportation.

It’s also critical to identify any clients who rely on phone-only visits, as these will generally not be covered after the deadline. Don’t forget to check on your “dual-eligible” clients who have both Medicare and Medicaid; you’ll want to see if your state’s Medicaid plan might still cover their telehealth needs. Don’t forget to check if some Medicare clients can switch to a different plan.

Lastly, evaluate the impact on your staff. Identify which of your clinicians—OTs, PTs, SLPs, and audiologists—will lose their ability to bill Medicare for telehealth and begin planning how to transition their clients to in-person care. You may have to refer clients who can’t make in-person appointments to eligible providers.

2. Evaluate your financial risk

Next, you’ll have some business decisions to make. Your practice must decide if you will continue offering telehealth services to these clients even without Medicare reimbursement. If you do, establish clear policies, such as limiting the offer to existing clients for a short period, or transitioning them to self-pay. This is where an Advance Beneficiary Notice (ABN) becomes essential. Use ABNs to officially inform clients that Medicare will not pay for a service and that they will be financially responsible if they choose to proceed. This empowers them to make an informed choice while protecting your practice from billing issues.

If you have clients with dual eligibility, you should verify Medicaid coverage before September 2025.

It’s possible that the waivers will lapse, but later return. Even if these policies are brought back, you should assume that you won’t be able to bill retroactively.

3. Secure alternative access points

Your focus can then shift to securing alternative solutions so your clients don’t lose access to care. You can help clients who can no longer get home telehealth find an approved location for their appointment, such as a local hospital or community health center. You can even use the Medicare Telehealth Eligibility Analyzer to see if a specific location qualifies. For those who need help with transportation to in-person visits, explore local transportation resources or community ride programs. While planning this shift, remember to retain telehealth where it’s still allowed.

Remember, behavioral health, Substance Use Disorder (SUD), and dialysis services are permanently covered at home, so you can keep offering telehealth services for these clients as you always have.

And for clients willing to pay out-of-pocket, a clear ABN process will allow you to continue offering them the convenience of virtual care.

4. Communicate early and clearly

Finally, none of this planning works without clear, early, and compassionate communication. Start drafting messages for your clients now, using email, client portals, and signs in your office to explain the changes.

Internally, train your scheduling staff to identify telehealth requests that will no longer be covered and equip your clinicians to manage these sensitive conversations. And for those special cases where a phone call is still permitted, teach your clinicians how to properly document the reason.

5. Advocate for extensions

Our hope is that we will one day see a world where everyone has access to quality therapy and mental healthcare. But ending Medicare’s telehealth extensions will cut off a lifeline for vulnerable clients, especially those who are homebound, have mobility issues, or live in places that aren’t covered by rural exceptions.

This could also be a blow to whole person care. Even if mental health services remain accessible via telehealth, this patchwork of exemptions could make it harder for clients to be treated holistically. This could lead to delayed treatment and fewer multi-specialty clinics.

Protecting this expanded access for vulnerable people requires our collective voice. You can make a powerful difference by contacting your congressional representatives and joining advocacy groups like the American Telemedicine Association (ATA). Share your clients’ stories and explain how telehealth has changed their lives and allows your practice to reach more people. Telehealth is not a temporary fix, but an essential part of the future of healthcare. Healthcare policies should reflect that.

Advocacy meets pragmatism

While behavioral health telehealth has permanent protections, the broader system hangs in limbo. Stay informed through groups like the American Telemedicine Association, but build contingency plans now. Even if Congress acts last-minute, your preparation ensures continuity.

Your next step? Start small. Pull a list of home-based non-behavioral clients this month. Talk to one community clinic about partnerships. Update your consent forms. Every action reduces the chaos you may feel in September.
Telehealth transformed care delivery, but its future hinges on what we do today. Plan like the cliff is coming. Advocate like it isn’t. Your clients depend on both. Let’s keep care accessible, no matter what 2025 brings.