During COVID-19, Congress temporarily allowed Medicare to pay for telehealth visits much more broadly including visits at home, in cities (not just rural areas), and for many types of clinicians. Those special rules have been extended several times, but Congress did not act again before they expired on October 1, 2025.
So now, as of October 1, 2025, the old, Medicare telehealth rules are back in place and they are more limited.
What changed on October 1, 2025
Without new legislation:
· Medicare generally cannot pay for telehealth visits if the patient is at home or not in a rural area.
· Hospice recertification visits must again be done in person, not via telehealth.
· Most telehealth visits outside of mental health or dialysis are not covered under current law.
What’s still allowed under current law
CMS (Medicare) can still pay for:
1. Behavioral and mental health telehealth services (like therapy, psychiatry, substance-use treatment).
2. Monthly telehealth check-ins for dialysis (ESRD) patients.
3. Telehealth provided by certain Accountable Care Organization (ACO) clinicians under special rules that already allow broader use.
What CMS is doing now:
CMS is reviewing and filtering telehealth claims to make sure only the allowed ones get paid:
· They’re automatically paying claims they can clearly identify as mental-health-related (based on billing codes).
· They’re holding back other telehealth claims they can’t confidently classify as legal under the new restrictions even if they might be OK.
This is why many clinicians haven’t been paid yet for telehealth visits done after Oct 1, 2025.
What happens next:
To clear the backlog and get money flowing:
· CMS will return (not deny) the held telehealth claims that were submitted before November 10, 2025 and cover services on or after October 1, 2025.
· Providers will get return codes “CARC 16” and “RARC M77” which basically mean “return for correction or resubmission.”
· Providers can then resubmit claims that meet the current law (for example, mental health, dialysis, or ACO-qualified services).
What this means for patients and clinicians:
· Patients: If your doctor did a telehealth visit recently, they might have to re-bill Medicare — so you may see billing delays or corrected claims later.
· Clinicians: They must now double-check if the telehealth visit qualifies under the old, pre-COVID rules before resubmitting.
· Behavioral health services are least affected — those continue to be covered broadly.
· Most other telehealth services, unless in a rural area or ACO, now require in-person visits again for Medicare payment.
