Telehealth has remained a vital tool in delivering patient care since the COVID-19 pandemic, offering increased flexibility and access—particularly for primary care and family medicine. In 2025, the Centers for Medicare & Medicaid Services (CMS) is continuing to support virtual care delivery through key updates included in the 2025 Medicare Physician Fee Schedule (PFS) Final Rule and recent federal legislation.

This overview outlines the major telehealth policy changes for 2025 that will impact family medicine and preventive care delivery.

Continued Telehealth Flexibilities Through September 2025

Thanks to the American Relief Act of 2025 and subsequent appropriations legislation, several pandemic-era Medicare telehealth waivers have been extended through September 30, 2025. These include:

• No geographic restrictions: Medicare beneficiaries across all geographic locations—rural and urban—may continue to access telehealth services.
  
  
• Home as the originating site: Patients may receive care from their homes rather than traveling to a designated healthcare facility.
  
  
• Expanded provider eligibility: Nurse practitioners, physician assistants, clinical psychologists, and other eligible practitioners may continue to provide and bill for telehealth services.
  

Additionally, for mental and behavioral health services, CMS has delayed the implementation of in-person visit requirements (such as initial or periodic follow-ups) until after September 30, 2025. This extension allows providers to continue delivering behavioral healthcare virtually without interruption.

These temporary extensions are essential for practices that rely on virtual visits for chronic care management, mental health services, and preventive counseling.

New Telehealth Services for 2025

The 2025 PFS final rule includes new additions to the Medicare Telehealth Services List that support family medicine and caregiving:

• Caregiver Training Services (CTS): Provisionally added to the telehealth list. These services include remote education for caregivers on topics such as wound care, infection prevention, mobility assistance, and behavioral strategies. They are especially relevant for clinicians supporting family members who manage complex home care responsibilities.
  
  
• Pre-Exposure Prophylaxis (PrEP) Counseling and Safety Planning: Now permanently billable via telehealth. These services enhance access to HIV prevention and are increasingly integrated into primary care settings.
  
  

Further, audio-only communication remains permissible for certain services—especially behavioral health—when video is not feasible. This supports continued care for patients with limited internet access or technical barriers.*

CMS has also extended virtual supervision flexibilities through December 31, 2025. Teaching physicians may continue to supervise residents remotely, including during telehealth encounters.

Preventive Services and Longitudinal Care

Preventive care remains central to CMS’s broader goal of supporting whole-person care, and telehealth continues to play a key role in that strategy:

• Complexity Add-on Code (G2211): Effective in 2025, this code allows providers to reflect the additional resources required to manage longitudinal, complex relationships with patients. However, G2211 cannot be billed alongside annual wellness visits (AWVs), Initial Preventive Physical Exams (IPPEs), or other stand-alone preventive services. This corrects some earlier misconceptions.
  
  
• Annual Wellness Visits (G0438 and G0439) and the IPPE (G0402) remain temporarily eligible for telehealth through September 30, 2025, under the extended public health emergency flexibilities. These visits continue to cover risk assessments, preventive screenings, and care planning—many of which can be effectively addressed through virtual platforms.

Looking Ahead: Potential Reinstatement of Pre-Pandemic Restrictions

Unless further legislative action is taken, most of the temporary telehealth flexibilities will expire after September 30, 2025. This could result in a return to:

• Geographic restrictions limiting telehealth to rural areas
  
  
• Facility-based originating site requirements
  
  
• Reduced access to audio-only telehealth, particularly for non-behavioral health services*
  
  

CMS has requested public feedback to help shape future telehealth policy. Practices that rely heavily on virtual care should monitor legislative developments and participate in advocacy efforts to ensure continued access.

Final Thoughts

The 2025 CMS telehealth updates reinforce the agency’s ongoing commitment to accessible, patient-centered care—particularly in the domains of family medicine and prevention. While many of the flexibilities remain temporary, they offer continued support for remote care delivery through at least the third quarter of 2025.

Providers should take full advantage of these opportunities to integrate telehealth into routine practice workflows while preparing for possible policy changes in late 2025.

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