CMS telehealth flexibilities scheduled to end Sept. 30, 2025; regulatory waivers to end Dec. 31, 2025

On Sept. 30, 2025, the Centers for Medicare & Medicaid Services is ending the expanded telehealth access and flexibility waivers instituted for Medicare patients during the COVID-19 pandemic. Other CMS regulatory waivers will end Dec. 31, 2025. 

Blue Cross Blue Shield of Michigan and Blue Care Network will continue to follow CMS guidance for telehealth coverage. If the government extends the waivers, we will align.  

Starting Oct. 1, 2025 To receive most telehealth services, patients must be in an office or medical facility located in rural areas or places with health care provider shortages. Federally qualified health centers, or FQHCs, and rural health centers, or RHCs, can serve as distant site providers only for behavioral and mental health services. 

Exceptions exist for: 

• Monthly end-stage renal disease visits for home dialysis
  
• Acute stroke diagnosis, evaluation or treatment
  
• Diagnosis, evaluation or treatment for mental and behavioral health disorders, including substance use disorder. (There are no originating site or geographic location restrictions for mental and behavioral health services.) 

The following providers can no longer bill as a distant site:

• Audiologists
• Occupational therapists 
  
• Physical therapists 
  
• Speech language pathologists 
  

According to Telehealth FAQ Calendar Year 2025,* two-way, real-time audio-only communication technology to furnish Medicare-covered telehealth services is permitted only for patients who are in their homes when certain criteria are met: 

• For non-behavioral or non-mental telehealth: CMS permits two-way, interactive audio-only technology if the distant site provider has the technical capability to use an audio-video telehealth system, and the patient is at home but isn’t capable of, or doesn’t consent to, using video technology. 
• For behavioral or mental telehealth: Providers may use two-way, interactive audio only technology; however, the patients must be in their home. 
  

Hospitals can no longer bill for outpatient therapy, diabetes self-management training and medical nutrition therapy services furnished remotely to patients in their homes. 

Starting Jan. 1, 2026 In-person visit requirements within six months before the initial telehealth treatment, as well as the required subsequent in-person visits at least every 12 months, will apply to RHCs and FQHCs for mental health services provided through telehealth to patients in their homes.

Frequency limits will be reinstated for subsequent inpatient and nursing facility visits and critical care consultations.  
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Cardiac rehabilitation, intensive cardiac rehabilitation and pulmonary rehabilitation services will require in-person clinical supervision by the supervising practitioner. 

To find more information on CMS telehealth requirements, see Telehealth FAQ Calendar Year 2025* and MLN901705,* Telehealth & Remote Patient Monitoring.  

Medicare Advantage telehealth coverage 
Medicare Plus Blue and BCN Advantage members can choose to receive primary care provider and individual sessions for mental health services by telehealth if offered by their providers. Members will incur the same out-of-pocket costs as for in-person visits, when applicable.  

Members also have a supplemental telehealth benefit with fewer restrictions offered through our plan-approved vendor, Teladoc Health®.