Medicare Telehealth Rules for PTs: The 2025 Cliff Explained

Update (November 2025): Medicare telehealth flexibilities for physical therapists have been extended through January 30, 2026, following Congressional action in November 2025. However, the underlying policy uncertainty remains—without permanent legislation, PT telehealth access faces an uncertain future beyond early 2026.

If you’ve incorporated telehealth into your physical therapy practice since 2020, you’re not alone. During the COVID-19 pandemic, telehealth utilization among Medicare beneficiaries surged to 42% of all medical services, and physical therapists quickly adapted to delivering remote consultations, exercise supervision, and patient education virtually.

But here’s the critical issue: The Medicare telehealth flexibilities that enabled physical therapists to bill for telehealth services are temporary COVID-19 emergency waivers—and they keep approaching expiration with only short-term extensions. As of January 2025, these flexibilities are extended through January 30, 2026, creating yet another “telehealth cliff” that could drastically limit PT telehealth access just weeks from now.

This comprehensive guide explains Medicare’s telehealth rules for physical therapists in 2025, the expiration timeline, billing requirements including the 95 modifier and Place of Service (POS) codes, and what the future holds for PT telehealth beyond the current extension.

The COVID-19 Telehealth Flexibilities: What Changed

Before the COVID-19 Public Health Emergency (PHE), Medicare telehealth was extremely limited for physical therapists. In fact, physical therapists were not recognized as eligible “distant site providers” at all, meaning PTs could not bill Medicare for telehealth services under any circumstances.

Pre-Pandemic Medicare Telehealth Restrictions

The original Medicare telehealth statute (established in the Balanced Budget Act of 1997) imposed three major restrictions:

1. Geographic restrictions: Telehealth was only covered for patients in rural areas (outside Metropolitan Statistical Areas) or in designated Health Professional Shortage Areas (HPSAs)
2. Originating site restrictions: Patients had to be physically located at an approved healthcare facility (doctor’s office, hospital, rural health clinic)—not at home
3. Limited provider types: Only physicians, nurse practitioners, physician assistants, and a few other provider types could serve as “distant site providers” delivering telehealth services

Result: Physical therapists couldn’t bill Medicare for telehealth. Patients couldn’t receive PT via telehealth from home. Telehealth PT simply wasn’t covered by Medicare.

COVID-19 Emergency Waivers (March 2020 - Present)

When the COVID-19 Public Health Emergency was declared in March 2020, CMS issued Section 1135 waivers that dramatically expanded telehealth access:

Waiver #1: Geographic restrictions eliminated

• Patients anywhere in the United States (including urban areas) became eligible for telehealth

Waiver #2: Home as originating site

• Patients could receive telehealth services from their homes (not just healthcare facilities)

Waiver #3: Expanded distant site providers

• Physical therapists, occupational therapists, and speech-language pathologists were added as eligible distant site providers who could bill for telehealth services

Impact: Physical therapy telehealth became viable under Medicare for the first time, enabling practices to serve patients remotely during pandemic lockdowns and beyond.

The Telehealth Cliff: Extension Timeline

The challenge is that these flexibilities were always intended as temporary emergency measures. Congress has repeatedly extended them through short-term legislative actions, creating a pattern of looming “telehealth cliffs” followed by last-minute extensions.

Extension History

What Expires on January 30, 2026?

Unless Congress acts again, the following flexibilities end on January 30, 2026:

1. Physical therapists as distant site providers

   • PTs will no longer be able to bill Medicare for telehealth services

2. Home as the originating site (for non-behavioral health services)

   • PT patients must be located at approved healthcare facilities, not their homes

3. No geographic restrictions

   • Only patients in rural areas or HPSAs will qualify for telehealth coverage

Translation: After January 30, 2026 (without further extension), Medicare telehealth for physical therapy essentially returns to pre-pandemic status—meaning it becomes unavailable for most patients.

December 31, 2025 Deadline: FQHCs and RHCs

An additional deadline affects Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs):

• Through December 31, 2025, FQHCs and RHCs can use telecommunication technology (including audio-only) to furnish medical visits
• After December 31, 2025, this flexibility ends for these specific facility types

Impact for PTs: If you work in or contract with an FQHC or RHC, your telehealth billing may be affected even before the January 30, 2026 deadline.

Billing Medicare Telehealth: Current Requirements (Through January 30, 2026)

While telehealth flexibilities remain in effect through January 30, 2026, specific billing rules must be followed for Medicare reimbursement.

Modifier 95: Synchronous Telehealth Services

Modifier 95 must be appended to CPT codes when services are delivered via synchronous (real-time) telehealth using interactive audio and video technology.

Definition: Synchronous telehealth means the patient and therapist interact in real-time, as opposed to asynchronous “store-and-forward” telehealth (sending videos or messages reviewed later).

Example billing:

• CPT Code: 97110 (therapeutic exercise)
• Modifier: 95 (telehealth service)
• Full code: 97110-95

When to use Modifier 95:

• ✅ Live video consultation with patient via HIPAA-compliant platform
• ✅ Real-time exercise supervision and instruction via video
• ✅ Patient evaluation conducted through interactive video and audio
• ❌ Pre-recorded video sent to patient (not synchronous)
• ❌ Email or patient portal messaging (not synchronous)

Place of Service (POS) Codes for Telehealth

The Place of Service (POS) code indicates where the patient is physically located during the telehealth service.

Most Common POS Codes for PT Telehealth

POS 10: Patient’s Home (Telehealth)

• Use when the patient receives telehealth from their residence
• Most common POS for physical therapy telehealth in 2025

POS 02: Telehealth Provided Other Than in Patient’s Home

• Use when patient receives telehealth from a location other than home (e.g., workplace, temporary residence)
• Medicare recognizes this as valid for telehealth services

POS 11: Office (Generally Avoid for Telehealth)

• Originally used by some practices during the pandemic to indicate virtual visits conducted from the provider’s office
• Many payers (including Medicare) are now denying claims with POS 11 + Modifier 95
• Best practice: Use POS 10 or POS 02 instead

Common Billing Errors with POS Codes

Error #1: Using POS 11 for telehealth

• Claim: 97110-95 with POS 11
• Result: Denied—POS 11 indicates in-person office visit, inconsistent with telehealth modifier
• Correction: Use POS 10 (if patient at home) or POS 02 (if elsewhere)

Error #2: Omitting Modifier 95

• Claim: 97110 with POS 10 (no modifier 95)
• Result: Denied—without modifier 95, payer doesn’t recognize service as telehealth
• Correction: Add modifier 95 to indicate synchronous telehealth

Error #3: Using POS 10 for in-person services

• Claim: 97110 with POS 10 (in-person visit at clinic)
• Result: Potential audit trigger—POS 10 indicates patient’s home
• Correction: Use POS 11 for in-person clinic services (without modifier 95)

Correct Telehealth Billing Examples

Example 1: PT evaluation via telehealth (patient at home)

• CPT Code: 97163-95 (PT evaluation, high complexity, telehealth)
• POS: 10 (patient’s home)
• ICD-10: M54.5 (low back pain)

Example 2: Therapeutic exercise supervision via telehealth (30 minutes)

• CPT Code: 97110-95 (therapeutic exercise, telehealth) × 2 units
• POS: 10 (patient’s home)
• ICD-10: S83.511D (ACL sprain, right knee, subsequent encounter)

Example 3: Manual therapy instruction via telehealth (15 minutes)

• CPT Code: 97140-95 (manual therapy techniques, telehealth)
• POS: 10 (patient’s home)
• ICD-10: M75.100 (rotator cuff tear, right shoulder)

Reimbursement Rates: Facility vs. Non-Facility

Telehealth services are reimbursed at the non-facility rate (same as in-person office visits), which is typically higher than facility rates.

Example (2025 Medicare rates):

• 97110 (therapeutic exercise) - Non-facility rate: $28.46 per unit
• 97163 (PT evaluation, high complexity) - Non-facility rate: $170.04

Key point: Telehealth reimbursement equals in-person reimbursement (no reduction for remote delivery).

Audio-Only Telehealth: Limited Availability for PTs

One of the most confusing telehealth policy areas is audio-only telehealth (telephone-only, without video).

Medicare’s Audio-Only Policy for 2025

The 2025 Medicare Physician Fee Schedule permanently changed the definition of “interactive telecommunications system” to include audio-only communication for any telehealth service, but with strict conditions:

1. Audio-only is only allowed when:

   • The patient is incapable of using video technology (e.g., lacks smartphone, internet access, or technical capability), OR
   • The patient does not consent to video technology

2. Two-way, real-time communication required

   • Must be synchronous telephone conversation, not voicemail or recorded messages

3. Billing requirements:

   • Use Modifier 93 (non-FQHC/RHC providers) or Modifier FQ (FQHC/RHC providers)
   • Use CPT codes 99202-99215 (E/M visit codes)
   • Note: Codes 99441-99443 (telephone E/M codes) were eliminated in 2025

Can Physical Therapists Bill Audio-Only Telehealth?

The short answer: It’s complicated.

CMS’s position:

• Physical therapists are not currently on the approved provider list for audio-only telehealth
• Most PT CPT codes require visual contact with the patient for proper assessment and treatment monitoring

What this means:

• Audio-only PT services (telephone check-ins, exercise instruction via phone) are generally not billable to Medicare
• Video must be used for Medicare telehealth reimbursement

Exception scenario:

• If a patient begins a telehealth session with video and the video connection fails mid-session, you can continue via audio-only to complete the service
• Document the video failure and reason for switching to audio-only

Best practice: Always attempt video-first for Medicare telehealth. Only use audio if video is truly unavailable or patient refuses video.

Technology Requirements for Medicare Telehealth

To bill Medicare for telehealth services, your technology platform must meet specific criteria.

HIPAA-Compliant Video Platform Required

Medicare requires:

• Two-way, real-time audio and video interaction
• HIPAA-compliant platform with Business Associate Agreement (BAA)
• Secure transmission protecting patient health information

Compliant platforms:

• ✅ doxy.me (with BAA)
• ✅ Zoom for Healthcare (with BAA)
• ✅ Microsoft Teams for Healthcare (with BAA)
• ✅ SimplePractice Telehealth
• ✅ Proactive Chart integrated telehealth

Non-compliant platforms:

• ❌ Standard Zoom (consumer version without BAA)
• ❌ FaceTime (Apple has not signed BAAs for telehealth use)
• ❌ Skype
• ❌ WhatsApp video

Enforcement note: During the COVID-19 PHE, CMS exercised “enforcement discretion” allowing use of non-HIPAA-compliant platforms like FaceTime. That discretion has ended—you must now use HIPAA-compliant platforms or risk violations.

Documentation Requirements

Your clinical documentation must support telehealth billing:

Required elements:

1. Clear statement that service was delivered via telehealth

   • “Patient was evaluated via HIPAA-compliant telehealth platform (video) while at home.”

2. Technology used

   • “Interactive audio and video telehealth using [platform name].”

3. Patient location

   • “Patient was located at home in [city, state] during the telehealth encounter.”

4. Clinical justification

   • Why telehealth was appropriate for this encounter (e.g., patient mobility limitations, transportation barriers, COVID-19 precautions, remote location)

5. Services provided

   • Detailed description of assessment, interventions, patient response, and plan—same as in-person visit documentation

Red flag: Generic documentation like “Telehealth visit completed” without detail will not support billing in an audit.

What Happens After January 30, 2026?

The January 30, 2026 expiration creates three possible scenarios:

Scenario 1: Congress Extends Flexibilities Again (Most Likely Short-Term Outcome)

Congress could pass another short-term extension (3-12 months), kicking the telehealth cliff down the road once again.

Likelihood: High for another short-term extension, given bipartisan support for telehealth access.

Impact: Continued uncertainty, making long-term planning difficult for practices invested in telehealth infrastructure.

Scenario 2: Congress Passes Permanent Telehealth Legislation

Permanent legislation would add physical therapists to the Medicare telehealth statute, allowing PT telehealth access indefinitely (with or without some geographic restrictions).

Legislation to watch:

• CONNECT for Health Act - Bipartisan bill to permanently expand telehealth access, including PT/OT/SLP services
• Expanded Telehealth Access Act - Another bill addressing telehealth provider types

Likelihood: Moderate in the long term (1-3 years), but unlikely before January 2026.

Impact: PT practices could confidently invest in telehealth as a permanent service line.

Scenario 3: Flexibilities Expire (Worst-Case Scenario)

If Congress fails to act, Medicare telehealth for physical therapy essentially ends on January 31, 2026.

What would happen:

• Physical therapists can no longer bill Medicare for telehealth services
• PT codes return to “non-covered” status for telehealth
• Patients receiving PT via telehealth would need to transition to in-person visits or pay out-of-pocket

Likelihood: Low, given political pressure and patient advocacy, but not impossible.

Impact: Devastating for rural practices, homebound patients, and underserved populations who rely on telehealth access.

State Licensure and Interstate Telehealth

Even if Medicare covers telehealth, you must comply with state licensure requirements.

Physical Therapy Compact

The Physical Therapy Licensure Compact allows PTs licensed in compact member states to practice in other compact states without obtaining additional licenses.

As of January 2025, compact member states include:

• Alabama, Arizona, Arkansas, Colorado, Delaware, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Maryland, Michigan, Mississippi, Missouri, Montana, Nebraska, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming

Non-compact states still require state-specific licensure for telehealth services.

Telehealth Across State Lines

Rule: You must hold an active PT license in the state where the patient is physically located during the telehealth encounter.

Example:

• You’re licensed in California
• Patient is physically located in Nevada during the telehealth call
• Required: You must hold a California license AND a Nevada license (or Nevada compact privilege)

Exception: If both states are Physical Therapy Compact members, your compact privilege allows you to practice across state lines.

Violation risk: Practicing without proper licensure is considered practicing without a license—a serious legal and professional violation.

Commercial Payers and Telehealth Coverage

Medicare isn’t the only payer—commercial insurance policies vary widely on telehealth coverage.

Common Commercial Payer Policies

Most commercial payers cover PT telehealth as of 2025, but policies differ on:

Coverage requirements:

• Some require prior authorization for telehealth (but not in-person) visits
• Some limit the number of telehealth visits per year
• Some require telehealth to be “equivalent in scope” to in-person services

Reimbursement rates:

• Most reimburse telehealth at parity with in-person visits (state laws in many states mandate telehealth parity)
• Some reimburse telehealth at a reduced rate (e.g., 80% of in-person rate)

Modifier and POS code requirements:

• Some payers require Modifier 95 (like Medicare)
• Others use different modifiers (GT, GQ) or no modifier at all
• POS code requirements vary (some accept POS 11, others require POS 10 or POS 02)

Best practice: Verify telehealth coverage and billing requirements for each commercial payer you contract with.

Building a Sustainable Telehealth Practice

Given the ongoing uncertainty around Medicare telehealth, how should PT practices approach telehealth strategically?

Strategy 1: Diversify Your Telehealth Patient Base

Don’t rely solely on Medicare telehealth patients. Build a telehealth practice that includes:

• Commercial insurance patients (more stable coverage)
• Workers’ compensation patients (often cover telehealth)
• Cash-pay telehealth services (wellness, injury prevention, sports performance)

Strategy 2: Use Telehealth as a Complement, Not a Replacement

Hybrid model: Most PT services still benefit from in-person treatment, especially hands-on manual therapy and advanced exercise progression. Use telehealth for:

• Initial evaluations or re-evaluations
• Check-ins between in-person visits
• Home exercise program instruction and monitoring
• Discharge follow-up and maintenance programs

Strategy 3: Invest in Technology Wisely

HIPAA-compliant telehealth technology is essential, but you don’t need expensive custom platforms.

Proactive Chart includes:

• Integrated HIPAA-compliant video telehealth
• One-click telehealth session launch from patient schedule
• Automatic telehealth documentation templates (pre-populates modifier 95, POS codes)
• Telehealth billing validation before claim submission

Strategy 4: Advocate for Permanent Telehealth Access

Contact your legislators to support permanent telehealth legislation like the CONNECT for Health Act.

Resources:

• APTA Legislative Action Center (apta.org/advocacy)
• Telehealth.org - Advocacy resources and updates

Proactive Chart’s Telehealth Solution

Proactive Chart makes Medicare telehealth billing seamless and compliant:

✅ Integrated HIPAA-compliant video platform - No third-party tools needed ✅ Automatic telehealth billing codes - Modifier 95 and POS codes populated based on visit type ✅ Pre-built telehealth documentation templates - Includes all required elements for audit defense ✅ Payer-specific rules engine - Validates billing requirements for Medicare and commercial payers ✅ Telehealth compliance dashboard - Tracks telehealth utilization and identifies potential issues

No manual coding. No billing errors. No compliance headaches.

Conclusion: Navigating Telehealth Uncertainty

Medicare telehealth for physical therapists remains in a state of flux, with temporary extensions creating a cycle of “telehealth cliffs” and last-minute reprieve. While flexibilities are currently extended through January 30, 2026, the long-term future depends on Congressional action.

Key takeaways:

• Current deadline: January 30, 2026 for Medicare telehealth flexibilities (subject to further extensions)
• Modifier 95 and POS 10/02 are required for compliant Medicare telehealth billing
• Video is required for Medicare PT telehealth—audio-only is not currently covered for PTs
• HIPAA compliance is mandatory for telehealth platforms (enforcement discretion has ended)
• Permanent legislation is needed to make PT telehealth a stable, long-term service option

Despite the uncertainty, telehealth has proven valuable for patient access, particularly for rural populations, homebound patients, and those with transportation barriers. Physical therapy practices should continue offering telehealth while planning for potential policy changes.

Stay informed. Bill correctly. Advocate for permanent access.

Ready to offer compliant, efficient telehealth services? Learn how Proactive Chart simplifies telehealth billing and schedule a demo today.

References:

• Centers for Medicare & Medicaid Services. (2025). Telehealth FAQ Calendar Year 2025. CMS.gov.
• Centers for Medicare & Medicaid Services. (2024). Medicare Physician Fee Schedule Final Rule CY 2025. Federal Register.
• American Physical Therapy Association. (2025). Medicare Telehealth Resources for Physical Therapists. APTA.org.
• National Consortium of Telehealth Resource Centers. (2025). The Telehealth Policy Cliff: Preparing for 2025. TelehealthResourceCenter.org.

Disclaimer: Telehealth policies are subject to frequent changes. This article reflects the status as of January 2025. Always consult current CMS guidance and qualified billing specialists before implementing telehealth billing practices. State licensure requirements may vary.