Medicare Telehealth Update: What You Need to Know About New In-Person Visit Rules for Behavioral  Health Providers

Written By Paul Jonas

Behavioral health telehealth is here to stay—but that doesn’t mean the rules have stayed the same.

As of October 1, 2025, Medicare has rolled out new in-person visit requirements that providers need to understand and plan for. While audio-only services and home-based care are still allowed, these updates change when and how often clients must be seen in person—and the details depend on when telehealth services began.

Sound confusing? We’ll break it down step by step so you know what to expect, what to document, and what you can (and can’t) do going forward.

What’s Staying the Same

Let’s start with the good news:

✅ Behavioral health telehealth is now permanently covered by Medicare
✅ Clients can still receive services from home
✅ Audio-only visits remain billable
✅ No changes to provider eligibility or CPT codes

That means you can continue offering care the way you have been, as long as you meet the new in-person visit rules.

What’s Changing (Starting October 1, 2025)

Here’s where it gets more complicated. Medicare now requires in-person visits based on when the client first started telehealth services.

For New Clients

If a Medicare client begins telehealth on or after Oct. 1, 2025, they must have an in-person visit with someone at your clinic first, and that visit needs to be  within 6 months of starting telehealth. After that it’s one in-person visit every 12 months.

For Existing Clients

There are a few timelines to keep track of:

  • If telehealth service started before Oct. 9, 2023 (during the Public Health Emergency (PHE) + 151-day grace period):
    ➡️ Must have one in-person visit by Oct. 1, 2026

  • Telehealth started between Oct. 9, 2023 and Sept. 30, 2025:
    ➡️ This is a gray area—CMS hasn’t said for sure, but many expect these clients will be treated as established (with the same annual in-person requirement)

  • Telehealth starts after Oct. 1, 2025:
    ➡️ In-person visit required within 6 months before the telehealth start date

What About Exceptions?

There are some circumstances where an in-person visit may not be appropriate. Medicare allows exceptions when it’s clinically inappropriate or poses a significant barrier for the client.

You can use the exception if the client has:

  • Severe psychiatric or medical conditions

  • Mobility challenges or transportation limitations

  • Geographic or health-related barriers

And if you’re unavailable? Another provider in your group and specialty can complete the in-person visit.

But here’s the key: document everything.
We recommend using standardized forms and inserting a clear note in the record to support the exception.


A Bit More Background

Back in the 2023 Physician Fee Schedule, CMS said that patients who began telehealth during the pandemic (or right after) were “established” and didn’t need an in-person visit first.

But now?
➡️ The 151-day grace period is no longer part of the law
➡️ The waiver ended September 30, 2025
➡️ No new guidance (yet) for patients who started telehealth after Oct. 9, 2023

Most experts expect CMS to grandfather these clients as established—but until we get clarification, providers should prepare for either outcome.

What Should Providers Do Now?

Here’s how to stay compliant and avoid surprises:

  1. Audit your current Medicare telehealth clients
    Sort by start date to identify who needs in-person visits

  2. Schedule in-person visits early
    Don’t wait until the deadline—get clients in before you’re overwhelmed

  3. Document exceptions thoroughly
    Use clear language, standardized forms, and track them in your EHR

  4. Communicate with your team
    Make sure front desk, clinicians, and billing staff are all on the same page

  5. Communicate with clients
    Use email, portal messages, or signage to explain what’s changing and why

Final Thoughts

Medicare’s telehealth policy is finally settling into something more permanent, but it comes with strings attached. By understanding the timelines, documenting exceptions, and preparing early, your practice can avoid billing issues and keep care uninterrupted.

To help us work through this blog oast we have to give a big thanks to The Center for Connected Health Policy (cchpca.org). They gave us some great context and offer many informative newsletters and presentations on telehealth and specifically this change including:


At Breezy, we’re here to help you stay on top of compliance without getting buried in paperwork.

Paul Jonas https://breezybilling.net
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