As the telehealth landscape continues to evolve, staying informed about Medicare guidelines is crucial for delivering consistent, high-quality mental health care. At Help Therapy, we are committed to supporting our providers through these transitions—ensuring you can continue to offer top-tier care with minimal disruption.
In-Person Visit Requirements (Effective April 1, 2025)
Established Patients
Annual Requirement: An in-person visit is required at least once every 12 months.
Waiver Period Exception: Patients who began telehealth during the waiver period (ending March 31st) are not required to have an immediate in-person visit.
New Patients
Visit Window: For new patients, an in-person visit must be completed within six months before or after initiating telehealth services.
Exceptions & Alternatives
Medicare provides flexibility when in-person visits are impractical:
Exceptions for Annual Visits: If an in-person visit creates undue hardship (e.g., travel challenges or medical conditions), document the reason in the patient’s records.
Alternative Provider Support: If an in-person visit is required but you are unable to conduct it, another provider in the same group practice may perform the visit.
Help Therapy’s Group Practice Support: Providers can collaborate within our network to fulfill visit requirements. Contact providerrelations@helptherapy.com if interested.
Documentation Best Practices
Proper documentation is vital to ensure compliance and to safeguard both providers and patients. Beyond noting that an in-person visit may be impractical, it is important to document the clinical reasoning behind this decision. According to the CY 2022 CMS PFS final rule, this detailed documentation should include:
Risk-Benefit Agreement: Document if both the patient and practitioner agree that the benefits of an in-person, non-telehealth service are outweighed by the risks and burdens for a given 12-month period.
Specific Risks and Burdens: Clearly note scenarios where an in-person service might be detrimental, such as:
Disruption in Service Delivery: An in-person visit could interrupt or complicate ongoing care.
Potential Worsening of the Patient’s Condition: The visit might exacerbate existing conditions or trigger new issues.
Undue Hardship: This includes significant travel difficulties or hardships imposed on the patient or their family—especially if the patient lives out of town or in another state.
Maintenance Level of Care: In cases where the patient is in partial or full remission and only requires ongoing, maintenance-level care.
Risk of Disengagement: If there is a clinical judgment that requiring an in-person visit may lead to the patient discontinuing effective care.
By thoroughly recording these factors, providers can justify exceptions to the in-person visit requirement for both established and new patients while mitigating audit risks.
Next Steps for Providers
Comprehensive Documentation: Document all exceptions and patient agreements meticulously to support compliance and mitigate audit risks.
Leverage Group Practice Support: Utilize available group practice resources when in-person visits are needed and you are unable to conduct them personally.
For more information, refer to the APA Telehealth Requirement Article or consult your local Medicare Administrator.
Questions? We’re here to help—reach out anytime!
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