As of October 1, 2025, many of the temporary telehealth flexibilities introduced during the COVID-19 Public Health Emergency have expired, following the absence of new Congressional action. This means several statutory payment restrictions under Medicare are now back in effect, including:
- Limits on paying for telehealth services delivered to patients in their homes or non-rural areas.
- Requirements for in-person hospice recertifications rather than telehealth encounters.
Certain services remain exempt, including behavioral and mental health, monthly ESRD-related clinical assessments, and telehealth provided by Medicare Shared Savings Program ACOs.
To comply with current law, CMS has directed Medicare Administrative Contractors (MACs) to process and pay only eligible telehealth claims—specifically those that can be confirmed as qualifying under Section 1834(m) of the Social Security Act. Claims tied to mental and behavioral health codes (F01.A0–F99) are being paid when appropriate, while others that don’t clearly meet the criteria are being temporarily held.
To address this backlog and support provider cash flow, CMS will return all held telehealth claims (submitted on or before November 10, 2025, for dates of service on or after October 1) to providers. Returned claims will include messages CARC 16 and RARC M77, and eligible claims may be resubmitted once requirements are confirmed.
See the spotlight on the All Fee-for-Service Providers webpage for information on statutory requirements and revised instructions for the submission of telehealth claims.