Medicare Telehealth for Behavioral Health: Key Rules Effective October 1, 2025

Telehealth has become an essential tool in behavioral health, making care more accessible for patients across Nebraska and nationwide. However, starting October 1, 2025, the pre-COVID Medicare rules will take effect, which providers need to understand. 

While patients can still be seen from home, Medicare has reintroduced requirements for in-person visits and set clearer standards around audio-only care. And because commercial payors typically follow CMS, providers should prepare for similar rules across private insurance plans.

Here’s what’s changing — and what you need to do to stay compliant.

What Changed

• Temporary COVID-era waivers are ending — creating what the National Consortium of Telehealth Resource Centers calls the “Telehealth Policy Cliff”.

• Patients can still be seen from home — the old “rural restriction” has been permanently lifted for behavioral health, according to HHS Telehealth Policy Updates.

• Audio-only visits are allowed in certain circumstances, as clarified in CMS Telehealth FAQs (April 2025).

• The in-person visit rule is active again for both new and ongoing patients.

The In-Person Rule

Medicare now requires providers to build in-person visits into their telehealth workflows:

• New patients or new episodes of care: An in-person visit must take place within six months before starting telehealth.

  • Therapists: A first in-person therapy visit is required (or another Medicare therapist in your group can complete it).

  • Medication management providers: The initial visit must also be in person, done by you or another Medicare med provider in your group.

• Ongoing care: Patients must be seen in person at least once every 12 months. The visit can be with you or a same-specialty colleague in your practice.

• Exceptions: If the risks or burdens of an in-person visit outweigh the benefits, the annual requirement can be waived — but this must be clearly documented.

• Existing patients: There is no “reset.” Current telehealth patients simply roll into the new 12-month cycle after 9/30/25.

For more context on how this requirement impacts mental health, see CCHP’s Telehealth & Medicare Mental Health Services: The In-Person Catch (Aug 26, 2025).

What’s Still Allowed

• Location:  Patients may be at home or another location — there are no longer geographic restrictions.

• Audio-only visits: Permitted when patients are at home, video is offered, but isn’t possible or accepted. Use modifier 93 and document the reason.

How to Comply

Providers have a few options for meeting the in-person requirements:

1. Partner: Arrange for a same-specialty colleague in your group to conduct the in-person visit.

2. Pop-in clinic day: Designate time to see patients briefly in person to satisfy the rule.

3. Annual exceptions: Use the waiver option for annual visits when in-person care is unsafe or unreasonable — but be sure documentation is thorough.

At WiseMind, we make this easier with customized charting templates and AI-powered documentation support that align with compliance requirements. Not only do we provide these services, we also use them in our own offices — so we know they work in real-world behavioral health practice settings.

Billing Quick Hits

• Place of Service (POS): 10 (home) or 02 (other telehealth).

• Modifiers: 95 for audio-video telehealth, or 93 for audio-only.

Stay Ahead of Medicare Telehealth Rules with WiseMind

Behavioral health providers can still offer telehealth visits from home after October 1, 2025. But Medicare now requires an in-person visit before starting care and one every 12 months thereafter (with limited exceptions).

Building systems now — whether through partnerships, scheduling workflows, or documented exceptions — will keep your practice compliant and your patients connected.

Need help adapting your workflows to Medicare’s new rules? Contact WiseMind Innovations to make compliance seamless and keep your focus on patient care.

Disclaimer

WiseMind Innovations researches and monitors healthcare policy closely, but regulations change frequently and interpretation can vary. This article is provided for general informational purposes only and should not be relied on as legal or compliance advice. We encourage all providers to review official CMS Telehealth policy guidance, HHS, NCTRC, and CCHP resources directly before making decisions for your practice.