At the close of 2024, Congress passed, and President Biden signed into law, the American Relief Act, 2025 (the “Act”), linked HERE, which extends certain Medicare telehealth flexibilities through March 31, 2025. These waivers, first implemented during the COVID-19 pandemic, were previously set to expire on December 31, 2024. Below is a brief summary of key provisions, including implications for Maine providers.
Extended Telehealth Waivers
Geographic & Originating Site Flexibility
Patients can continue to receive telehealth services from their homes, without the usual geographic restrictions.
Expanded Distant Site Practitioners
Any Medicare-eligible provider (e.g., physical therapists, mental health counselors) may furnish telehealth services.
FQHCs & RHCs as Distant Sites
Federally Qualified Health Centers and Rural Health Clinics remain authorized to serve as telehealth providers—a major benefit in Maine’s rural communities.
Audio-Only Coverage
Reimbursement for audio-only telehealth services continues, critical for patients with limited internet access.
Behavioral Health In-Person Requirements
The waiver delaying in-person visit requirements before and after tele-mental health services remains in effect.
Acute Hospital Care at Home
Hospitals may keep utilizing “hospital at home” models to deliver inpatient-level care remotely.
Waivers Not Extended
Cardiac & Pulmonary Rehab via Telehealth
Coverage for these services, if provided in a patient’s home, expired on December 31, 2024.
HDHP First-Dollar Coverage
High Deductible Health Plan safe harbor for telehealth ended for plan years beginning on or after January 1, 2025.
Next Steps and Recommendations
Review In-House Telehealth Protocols
Confirm that your organization’s policies are up to date with both federal and Maine state regulations.
Train Clinical Staff
Continue educating staff about proper coding and documentation for telehealth services, including audio-only visits.
Ensure a thorough understanding of in-person visit requirements for mental and behavioral health patients once the waiver ends.
Prepare for Potential Changes
While the current extension lasts until March 31, 2025, providers should stay alert to any further legislative activity.
If Congress does not act before that deadline, Medicare’s telehealth coverage will revert to more stringent pre-pandemic rules.
Have a plan in place to comply with pre-pandemic rules if the waivers are not extended, and educate staff in advance about the potential change.
Communicate with Patients
Inform existing and prospective patients about their telehealth options, coverage, and any future changes that might affect them after March 2025.
Conclusion
The Act’s extension of Medicare telehealth waivers offers a temporary reprieve for Maine’s health care providers, preserving significant expansions that have become essential for delivering care in rural communities and throughout the state. As the new Congress considers whether to make these rules permanent or further extend them, Maine providers should remain vigilant about compliance requirements at both the federal and state levels.
For questions about how these telehealth developments impact your practice or organization, we encourage you to contact a Kozak & Gayer attorney.
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