Medicare Update as of 11/1/2025

The following information comes from Barbara Griswold, LMFT., author of Navigating the Insurance Maze; The Therapist’s Complete Guide to Working With Insurance – And Whether You Should, 10^th edition.  Barbara has provided many webinars for Zur pertaining to notes, treatment plans and insurance matters. Learn more about Barbara her courses and her contributions to the field. 

Since Congress did not pass a bill extending or eliminating the in-person visit requirement for Medicare telehealth sessions, all Medicare telehealth providers must be aware of the following requirements:

All NEW Medicare telehealth clients that you see for the first time after October 1, 2025: Medicare requires you to see them in-person at least one time prior to initiating telehealth sessions. At this point, there do not seem to be any exceptions to this rule. Thereafter, you must see them in-person at least once annually – if the law is not altered or eliminated by that time.  There will likely be some exceptions to the annual meeting rule.

If you CANNOT see a new Medicare telehealth client in-person before intake, the client must sign a Medicare Advanced Beneficiary Notice of Non-Coverage (ABN). An ABN is typically used when Medicare is not expected to pay for a service, to inform clients that they will need to pay for the sessions themselves.  

For EXISTING Medicare telehealth clients, that you saw prior to 10/1/25: The rules have recently been clarified as of 10/1/25. The Center for Medicare and Medicaid Services (CMS) updated their Telehealth FAQs to confirm:

“While section 1834(m) of the [Social Security] Act requires an in-person, non-telehealth visit within 6 months prior to the first mental health telehealth service, we do not believe this requirement applies to beneficiaries who began receiving mental health telehealth services in their homes prior to October 1, 2025. In other words, if a beneficiary began receiving mental health services on or before September 30, 2025, then they would not be required to have an in-person visit within 6 months; rather, they will be considered established and will instead be required to have at least one in-person visit every 12 months.”

Read Medicare’s complete updated Telehealth FAQs here, and a readable summary from the Center for Connected Health Policy here. (And if you aren’t on the CCHP newsletter list, it is highly recommended that you subscribe here.)

Before proceeding, be sure to verify all information with your regional Medicare Administrative Contractor (MAC).  A list of MACs and contact information can be found here. Be prepared for long wait times.  Be sure to document what you are told.