Medicare’s telehealth policies are set for a major shakeup in 2025, and telemedicine providers need to act now. Dr. Leo Damasco and Phoebe Gutierrez explore what these changes mean for physicians, patients, and telehealth companies and discuss strategies to stay ahead.
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Medicare’s telehealth policies are set to change in April 2025, and the shift could leave many telemedicine providers and patients scrambling. The expiration of COVID-era waivers means Medicare will return to pre-pandemic telehealth rules, restricting coverage to patients in rural areas who must visit a clinic or hospital for telehealth services. This change threatens access to care for millions, disrupts telemedicine business models, and leaves providers uncertain about reimbursement.
Dr. Leo Damasco and Phoebe Gutierrez break down the looming policy shift, explain the congressional roadblocks, and discuss what providers can do to prepare. They cover alternative revenue streams such as remote patient monitoring (RPM) and chronic care management (CCM), the regulatory hurdles associated with them, and how telehealth companies should be pivoting now to avoid financial instability.
If you're a physician in telemedicine, a healthcare entrepreneur, or a patient who relies on Medicare-covered telehealth services, this episode is essential listening.
Telemedicine Talks explores the evolving world of digital health, helping physicians navigate new opportunities, regulatory challenges, and career transitions in telemedicine.
🔹 Dr. Leo Damasco – A pediatrician and emergency medicine doctor who transitioned into telemedicine, finding flexibility and new opportunities along the way.
🔹 Phoebe Gutierrez – Former state regulator turned startup executive, now helping companies and physicians build smarter, compliant, and sustainable telemedicine businesses.
Connect with Phoebe Gutierrez: LinkedIn: linkedin.com/in/pkgutierrez
Email: phoebe@telemedicinetalks.com
TELE TALKS EP7
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[00:00:00] Welcome back to telemedicine talks today. We're going to be talking about Medicare changes in 2025. If you're a doctor working in telemedicine right now, especially if you're with a company that relies on Medicare reimbursement, you need to listen to this.
This year, 2025, Medicare's telehealth rules are set to change, and if you're not prepared, you could be looking at fewer patients, decreased reimbursements, and even job instability. And a lot of these telemedicine companies, it's coming up, but they haven't really figured out how to handle this yet.
And a lot of the doctors that are working for these companies have no idea what's coming. As my awesome co host, Phoebe Gutierrez. A healthcare strategist and compliance expert is here to break it down and explain exactly what's happening, how it can affect you and what you can do to stay ahead of these changes.
So we're going to go beyond the basics. We'll cover which revenue streams will still exist, how maybe remote patient monitoring and chronic care management may fit [00:01:00] into this. And really questions that you need to be asking yourself, your employer, or the telehealth group that you work for today. So Phoebe, break it down.
~What, ~what is going on with Medicare and telehealth in 2025?~ Yeah. ~My background is all in the Medicare and Medicaid space. So this is something that I've been tracking for quite some time. And I think it's really interesting because a lot of people are viewing it as a CMS issue or a policy issue.
And it is 100 percent a Congress issue here. Medicare telehealth is covered, regardless of where the patient is today because of COVID waivers that were put into place back in 2020, allowing for some extra flexibility, right? ~Like ~During that time patients couldn't get to doctors, care couldn't be provided, everybody was frickin sick.
And Congress passed, it's called a waiver, and there's lots and lots of waivers that basically say, we're going to ignore this piece of legislation, this piece [00:02:00] of law for the time being, because it's going to benefit the American people for X, Y, and Z reasons. Now that this COVID waiver is set to expire, it's been extended and extended.
It's now looking to expire at the end of March. So effective April 1st, 2025 unless Congress makes some changes, we're going to go back to what's called pre pandemic telehealth rules, which means that Medicare will reimburse. only for patients in rural designated areas. And ~CMS has, ~there are, most people don't know this, but there are actually lists and lists of these designated areas where the federal government actually says there's a rural shortage here, we don't have doctors here.
And, ~the, ~I think this is where it gets really confusing. So even if a person is in one of those rural areas, They still actually have to go to a clinic or a hospital or a medical office. to get telehealth coverage. Home visits will not be [00:03:00] covered. I think that's silly. That's, defeats the purpose of telemedicine.
Absolutely. And there's a couple exceptions to this, right? For mental health, for example you can still get that in home. Home dialysis check ins for, renal disease, acute stroke care. But again the majority of the people now who are on Medicare, ~who, ~let's say, just need to refill a prescription or want to talk to their PCP they're not going to be able to do that the same way that you and I might on commercial insurance.
And so it really means that, not only ~just ~those in rural areas, but anybody who's in an urban or suburban area. Also is going to lose coverage basically overnight and CMS is already putting out information. They've updated their website, they've sent notifications to patients, basically letting them know like effective April 1st, like we're going to start rescheduling your appointments.
So if you have a telehealth visit that you might ~be, I've ~been waiting for, ~but the specialist, like you gotta, ~you now have to actually physically go [00:04:00] in. And see that doctor that's interesting, right? Because ~so so ~if your patient isn't rural, ~right? ~Or isn't physically sitting in this rural clinic, which could be ~234 ~hours away for this rural patient, which honestly, I think defeats the whole purpose.
So Medicare won't cover that, right? ~It's. That's what, ~that's where we're going to head over if, nothing changed. ~That's a huge shift. ~That's a huge shift. Because I know as a doc, reaching out to these patients, that's one of the big benefits, right? Hey, I'm sitting at my home. I don't have to gather up the kids.
I don't have to drive three hours away and I get my care. So ~that's yeah, no ~that's gonna be interesting. And ~I like, ~I come from a place, like my heart and soul bleeds Medicaid. So for me, it's you're taking the most vulnerable populations in the United States, right?
People who are unemployed, disabled, blind, have, very poor health. And you're saying, sure, we can talk to you. But like you said, Leo, ~like some of the, ~some of these clinics or the nearest doctors [00:05:00] two hours away. And it's not because, like it's again, like the states and the federal government, ~like they, ~they want the providers, but there's also a national provider shortage.
And ~it, again, ~it just creates extra hurdles for a population that is already struggling to stay healthy. ~Oh ~and just think about the convenience of it too. A lot of these populations, they're working two, three jobs at one time and the only time they could get their health care is jumping on during their lunch hour, jumping on in between shifts so forth and so on.
So that's all going to have to change too if this actually goes through. ~No, ~another hit for the patients, which really just sucks ~. No ~let's talk about the doctors working in fully remote telehealth companies. ~You know what? ~How should they start preparing for this? Or how should they start thinking about this change?
Yeah, so I would say that for people that are working with a fully remote telehealth company that primarily supports a Medicare line of business, if that's like their main revenue generating [00:06:00] stream. ~And, ~I would like to say that a lot of them that are dabbling in the Medicare, space, especially like at scale, are operating in this kind of telehealth, ~like this ~capacity, like this is going to directly impact them and their patients and how they are delivering care.
And so I would say there's a couple of questions that I would be very curious to ask when you're talking to these companies, what percentage of their, patient demographic are Medicare beneficiaries? Is the employer, the company that you're working with, are they looking to make any sort of adjustments?
Are they getting ~like ~commercial insurance? Is there any sort of pivot that they're trying to focus on? And then we'll dive into it a little bit later, but like talking a little bit about remote patient monitoring and, chronic care management.
My biggest concern there is there's so many operational implications. That you would need to check all these boxes before that could be reimbursed. My fear is that, a company is going to look at it at ~a ~face value and go, Oh no, like those are actually [00:07:00] reimbursed through separate billing codes.
Therefore, ~like ~we can continue to operate as normal and they're going to forget about some of the initial patient assessments. They're going to forget about some of those other key requirements to actually, complete the medical necessity requirement to really do some of the core documentation pieces on the front end to be able to be reimbursed for those.
While some companies are really hoping Congress fixes this in time it's a little risky. ~And I do think that, ~and if an employer isn't thinking about these things and they're just, again Oh no Congress is gonna pass a resolution and we'll be fine.
I think to me those are some red flags. I have many of my Dearest friends, actually, that are working at CMS, and the vibe at CMS, for lack of better words, is that they don't know what's happening. And they are, in this place of we have to do what we need to prepare, because if Congress doesn't pass something, we are going to be screwed.
as ~like ~the federal agency that governs this [00:08:00] and reimburses it. To their angle, they are trying to be as proactive as possible so they could ~You know, ~handle care coordination, make sure people really aren't, let's face it, people are going to be impacted, they're doing their kind of due diligence.
I have to say that a company that's also not operating under that same kind of ~like ~mindset really, might have a big wake up call because even , one week of a delay where this doesn't, you know, get extended could have so many implications downstream to a company. Yeah, so if you're a doctor working in a Medicare heavy company, I'd just ask your folks, what are you doing?
What are we doing to prepare for this? Do we have a plan yet? And what you're telling me then is if their answer is Oh no It's going to be okay. Everything's happening. We don't have a plan. Then, take a nice little soul search, deep breath and say, Hey, that's a little red flag.
What do I need to do to protect myself and prepare myself just in case [00:09:00] definitely don't want to be reactive at the very last minute. So you mentioned a couple of things. You mentioned, RPM, remote patient monitoring and CCM, chronic care management.
So these two modalities of care have been gaining traction in Medicare. Can you describe just real quick kind of what they are and, how have they been gaining traction in Medicare? And with these changes, how are our doctors and the businesses going to be able to bill for these?
Absolutely. So I think there's a couple reasons why both RPM and CCM are so big in the Medicare and Medicaid space. What I alluded to earlier, this is a really vulnerable population. The majority of people who are, on, besides just being aged, from the Medicare population.
But there are people who have, again, poor habits, potentially. Have some chronic diseases. And historically, it's been really hard to have really good quality, for health plans, for example. Which, I used [00:10:00] to audit them and come down on their quality metrics.
So for them, it's like, how can we actually make sure that, we're telling this one person they need to take these drugs. We're telling this one person they need to do certain things. With RPM, they can now monitor them. They can follow up if certain things are dipping and changing.
And so it's been a game changer on the quality side for health plans. And this again is ~a, it's ~billed separately outside of the telehealth billing codes. And so it will remain as a covered benefit. My piece is figuring out the process to going forward of that medical necessity of like how a person is eligible and meets the criteria for RPM.
I just personally think that's going to be a space that's going to be regulated more and more mainly because of. And then I think like the second is chronic care management, which is, just like the ongoing care coordination, getting their care team around, a person who has [00:11:00] again, like multiple illnesses, multiple conditions, and like really trying to make them.
Healthier. And again, you have to think about how much this is costing taxpayers from a not doing anything. The majority of people who are getting RPM and getting CCM are people who have constant ED visits in and out of the hospital are really ~You know, ~costing a lot of money, and so these two programs, again, ultimately are cost savings.
That's the way, CMS, whenever they do their billing, it's always around, ~can it, ~is it going to increase access? Is it going to improve quality and is it going to save us money? But again, both of those have such strong implications around how they're operationally managed. And how some of the initial assessments are done in order to qualify.
I think, they're going to be, again they continue to be really great options for people on Medicare. It's not going to change the fact that there's still a huge demographic and a huge [00:12:00] population that doesn't need those services and are just like, can I talk to my freaking doctor via a video visit?
~But again, those are two things that, that will remain intact. ~But again, there's lots of operational questions that I would have for an organization that is leaning into them. That's an interesting question. That's an interesting thought. I didn't think about that before because, if you're a doctor right now working in the RPM CCM space, that it's highly regulated.
You know that, you've been trained that yes, you need these steps, you need to, meet certain criteria to actually bill for that. And now if these changes do come about, I see where the fraud comes in, where somebody could say, Hey, this is RPM, but it's really just a way to get telemedicine services.
So yeah, that's interesting. So yeah, I could see how the regulations are getting tighter and people are going to start looking into how they actually apply for this, in, in a microscope. So that's huge. So now, ~now, so ~preparing for these gaps, right? Even if Congress fixes this, right? Even if they say, Oh, what a horrible idea. And they wake up and see it's actually a [00:13:00] horrible idea. There could be a temporary gap in coverage, right? What can doctors do now to protect themselves? How can we prepare, as the boots on ground docs doing this?
I think that the biggest things are really to just stay informed on the rules and to make sure that, again, you're tracking those key dates. ~I think that from a Now, again I want to just super emphasize that ~None of this is going to be illegal, right? A lot of doctors are like, Oh my gosh is it non compliant?
Can I not do it? No, you can totally still do it, right? I'm a Kaiser member. I can totally still do a telehealth visit. There's nothing about the operational flow of doing a telehealth visit for Medicare patients after April 1st. What the federal government is saying is that we're not going to pay you.
So do what you want, but we are no longer authorized to reimburse you for the work that you've done. So the biggest thing is if you're operating like by yourself and your primary kind of like revenue stream let's say you have a private practice and you're treating ~medicaid. I'm, sorry ~medicare, beneficiaries you just want to make sure [00:14:00] that you understand those implications that Likely you're not going to be reimbursed for those services even if there is a pause for two days three days five days so that's one big thing to factor into the second I think would be just again like always Trying to diversify the companies that you're working with.
You're working with a company, again, who mainly is saying Oh no, ~we're gonna just we're doing, ~we do RPM. We are totally good. I would say try to ask some of those questions and understand, like, How are their operations changing with the implementation or, I guess the delay on extending this waiver ~again ~those are like the big things that I always say and again I think ~one, ~one question that I've been getting a lot has just been like, why exactly is this even happening?
And, I always try to explain to doctors from a person who wrote the California telehealth policy, and I've done these things. I understand how it works on the other [00:15:00] side. You have to think, and again I put myself into the mind of a regulator and a policymaker.
And there's a couple reasons why this seems so outdated and so many steps backwards. And it's, you have to think about back in the days there was a huge belief that in rural areas there was those were the only areas where there was access issues. And I think, ~again ~we have realized that I'm in a very populated area.
I couldn't get a specialist visit if my life depended on it, probably. I think~ there's been, ~over the years it's just been harder and harder to get into the doctor. And then, on the flip side, I think that they viewed it as telemedicine was an emergency type of situation, right?
No, if we're gonna pay you, the federal government taxpayers are gonna pay for these services. At the very least, you're gonna go see that doctor in person, because it's gonna benefit you. Yeah. And I think, again, COVID has taught all of us. Even probably before [00:16:00] COVID, that if we can get the same kind of like standard of care from home as, driving across town and getting out of our car and taking the day off we should be allowed to seek care that way.
And again, that's a fact, right? That's a fact. We know that the majority of care that we provide over telemedicine meets the standard of care. ~And even you're right. ~And even the patients not in rural areas. Yeah, they have access. So you're right. These definitions seem very outdated, seem very behind the times.
Yeah, and ~I do, ~I do think it's a huge bipartisan issue, right? I think on both sides of the aisle maybe it's the one thing we're all agreeing on in politics today. But it's, it is a little bit of that. I think everybody is rallying around and going we need to extend this.
There's going to be huge implications. And, I always like to say~ my, ~my mom is a dual eligible. That's what it's called if you get Medicare and Medicaid. And for years, I've had to cart her to doctor's appointments and [00:17:00] take her here and there and really help her. And like for the first time, like her being able to access these services from home hasn't just made her life easier, but my gosh, it's made like the caregiver's life easier, too.
Absolutely. No, you're right that whole ripple effect, right? Because yeah, a lot of these people aren't mobile. They depend on other people to get them around. And you have lives, you have work to go to, you have your own kids to, shuttle around as well. You're basically just a living taxi, right?
And it's tough. I personally am looking forward to see this get changed, hopefully. Hopefully I think it's for the better, but assuming nowadays is dangerous, right? And that's the whole point. ~You, ~we just can't assume that this is what's happening.
It's coming down the pipeline there's confusion about what's going on, and we need to be ready and be proactive instead of reactive if this does hit, right? Yeah, and I would say one thing that I would also just try to emphasize is the one major reason [00:18:00] why, Medicare and Medicaid have dragged their feet on telehealth policy is because they don't have the bandwidth or the workforce to effectively monitor and oversee that there's not a ton of fraud.
Commercial insurance has a lot more means. in terms of, covering some of these bases. And when you go into some of these federal programs, you're just, you're looking at like difference. And a lot of times a regulator will go if we can't effectively monitor it and make sure those funds are being used in the appropriate way, then like for us, our due diligence is we're going to make a policy decision saying it's not allowed.
And I think again, ~like it, ~it is going to ~harm, ~harm patients. But once ~You know, if ~it is extended, and I have fingers crossed here that it will be I do anticipate that health plans, a lot of the Medicare Advantage plans, providers, there's gonna be a lot more in terms of how you're documenting, [00:19:00] how you're making sure that the medical necessity, standard of care I think there's gonna be so much more that's gonna fall onto the shoulders of doctors.
That are already stretched thin when it comes to doing the admin side. And ~like ~my anticipation is I would just again prepare everybody wants it to be extended, but once it does, ~they're ~the paper trail is going to start and there's going to be a lot more, ~like ~questions there.
Yeah. And right now, working in the telemedicine space, I think the documentation is easy. A lot of times because it's cash pay and there's not necessarily those strict rules, but yeah. Once, ~if ~this gets extended, then yeah, we may be seeing a lot more. Hey, you need two ROSs and, just click the box and making sure that we meet medical necessity, meet the correct MDM, things like that.
~Great. ~Check box and making sure I get coded right now. for the doctors on the front lines, doing telemedicine, really doctors in general, what can we do? What do you think we could do to help push this along or, play our role into making sure that, ~yeah, ~this may get [00:20:00] extended?
I think there's really like a few things. ~Again, ~you can, talk to your policymakers and your lawmakers in your state. You can talk to your local, Department of Health, that's where I came from. The California Department of Health. And you can just ask questions.
~Where, ~what are you doing about the policy? How are you anticipating, some of these changes? And try to get in their mind. Really advocate for yourself, advocate for patients. Talk to the companies that you're working with and understand those operations ~just again. ~So in theory, ~if they, ~if your caseload completely drops, you'll have ~some, ~at least a little bit of visibility into, what the company is planning.
And if you need to also do some planning on your own. And ~then again, ~ultimately, ~it's ~I would say, try to work for some other companies that have other lines of business, commercial insurance you can do a state specific Medicaid company ~I, again ~I'm in California, where telehealth is a policy decision, and California is taking those payments on.
You're [00:21:00] gonna find trouble in states that rely a lot more on the federal government for their funding. ~Again, ~you could maybe look at diversifying. And working with other companies. But those are, some of the tips that I've told a lot of the physicians that, ~I ~I consult for now.
No, this is definitely valuable information. Thank you so much. Now, one last thing, one last piece of advice. ~What do you got? Oh, man. She'll edit this out, right? Yeah, we'll cut this out. Nevermind. Okay. No. I'll, one, Okay. ~ ~Oh I took a dab. I totally winged all of this. No, that's awesome. ~I think like my biggest piece of advice is just to continue to stay prepared.
Stay informed. Really stay up to date on the rules. Ask questions, inform your patients, right? Do your due diligence as a physician. You don't have to do it, but, patients are gonna really appreciate if you give them a heads up on some of these changes. Try to explain it to them in layman's terms, because, let's be real they're not gonna understand the reason of why these things are being rolled back when they've had access to this for the last five years.
So I would just say be a good physician, ~be, ~communicate effectively and just [00:22:00] really try to stay up on the rules so that you can stay ahead of the curve. Awesome. Awesome. No, thank you so much. Now, if you have further questions for Phoebe, want to discuss this further, check out telemedicine talks.
com. Contact us. Via the email info at telemedicinetalks. com or phoebe directly at phoebe at telemedicinetalks. com. We would love to hear from you and see y'all later
~I didn't throw that in. That's going to be funny. .~