Medicare Waiver Expiration & Telehealth FAQs

CCHP has developed a new FAQ to help providers and stakeholders navigate the expiration of Medicare telehealth flexibilities on October 1, 2025, and is designed to address the most common questions CCHP has received through its technical assistance channels in recent weeks.  The FAQ highlights where CMS has offered clear direction, and where additional gaps still remain.  The document addresses some of the most pressing issues and concerns around mental/behavioral health requirements, FQHC and RHC billing, and the implications for Medicaid, Medicare Advantage, and private payers. Its goal is to clarify areas of uncertainty, highlight what CMS has (and hasn’t) said, as well as point providers toward best practices until additional guidance is released.

Questions covered in the FAQ include:

• Do I need to conduct a new in-person visit for behavioral health patients who were established via telehealth before the new Medicare requirements took effect?
• How do I document the exception for the annual in-person mental health visit when the risks or burdens outweigh the benefits?
• How will CMS know if a telehealth service qualifies as “mental/behavioral health”? How should we indicate this when billing?
• Can a Physician Assistant (PA) or Nurse Practitioner (NP) meet the in-person requirement for Medicare mental health telehealth services?
• Can FQHCs and RHCs continue to bill for telehealth (or telecommunications) services for non-behavioral health after September 30, 2025?
• Can FQHCs and RHCs provide mental health services now that the waivers are expired, and are they subject to the in-person requirements?
• Will the end of the Medicare telehealth flexibilities affect Medicaid or other private payers?