July 8, 2025
CMS Updates Mental Health & Substance Use Disorder Telehealth Coverage Guidance
The Centers for Medicare and Medicaid Services (CMS) released a revised version of its Medicare & Mental Health Coverage booklet, incorporating several important updates related to telehealth and digital mental health services.
Notable changes include notating telehealth coverage for:
- Caregiver training,
- Depression screening, and
- Tobacco cessation counseling.
In addition, CMS added new HCPCS/CPT codes eligible for telehealth and outlined coverage criteria for digital mental health treatment (DHMT) devices when used “incident to” behavioral health services. Due to the possibility that the current Medicare telehealth waivers are not extended or changed, the guidance confirms that starting October 1, 2025, Medicare will require:
- An in-person visit within six months before initiating telehealth-based mental health services, and
- Follow-up in-person visits every 12 months.
- For rural health clinics (RHCs) and federally qualified health centers (FQHCs), this requirement is delayed until January 1, 2026, for services delivered to patients in their homes.
- Follow-up in-person visits every 12 months.
CMS does not mention in the document that current permanent federal law still allows Medicare mental health services to be delivered without an in-person visit if the patient is located at an eligible facility in a geographically rural area or a rural health professional shortage area. Providers can check geographic eligibility using HRSA’s telehealth tool.
In-person visit exemptions also remain in place for patients with substance use disorder and co-occurring mental health conditions.
Finally, an exception to the subsequent 12 month in-person requirement described in the 2022 Final Physician Fee Schedule is also not explicitly addressed by CMS in the booklet-specifically that the requirement can be waived if the patient and practitioner agree that the risks and burdens associated with an in-person service outweigh the benefits of an in person visit.
Click Here to Access Medicare & Mental Coverage booklet
Click Here to Use HRSA’s Telehealth Tool
Click Here to View 2022 Final Physician Fee Schedule
