The COVID-19 Public Health Emergency reshaped care delivery, bringing telehealth to the center of rehabilitation services. While many temporary flexibilities have since expired, pt telehealth 2025 remains active under an important extension. According to the CMS Telehealth FAQ, April 2025, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) remain eligible to furnish telehealth services under Medicare Part B through September 30, 2025. The HHS Telehealth Policy Updates page emphasizes that while federal rules remain in place, state-level variations in licensure and payer policy still apply, making vigilance critical for compliance.
This guide provides a comprehensive review of eligibility, code coverage from the CMS telehealth list, correct use of modifier 95 and POS codes, documentation requirements, and audit-readiness strategies. It also explores the revenue cycle implications of telehealth therapy and forecasts what might happen when the extension expires.
Eligibility & dates
Medicare has explicitly included PTs, OTs, and SLPs among the disciplines authorized to provide telehealth through September 30, 2025. The extension, granted under the Consolidated Appropriations Act, ensures continuity of care for patients who rely on virtual therapy sessions. CMS operationalized this authority in its April 2025 Telehealth FAQ, which confirms therapists as “qualified distant site practitioners.”
The HHS Telehealth Policy Updates remind providers that coverage by Medicare does not automatically extend to Medicaid or commercial payers, many of which are sunsetting their pandemic-era expansions earlier. Clinics therefore must check both federal and local rules.
PTs/OTs/SLPs included through 9/30/2025
This policy gives therapists in outpatient, SNF, and home health settings a critical window to continue delivering virtual services. By naming PTs, OTs, and SLPs in its FAQ, CMS acknowledged the role of rehab therapy in maintaining patient mobility and functional independence. For providers in rural and underserved areas, this means telehealth remains a viable access channel.
Historical context and legislative background
The trajectory of telehealth therapy coverage illustrates how policy can evolve under pressure. Initially, therapy services were not on Medicare’s telehealth list. It was only after the COVID-19 Public Health Emergency that Congress authorized broader telehealth access, allowing PTs, OTs, and SLPs to provide covered services.
The Bipartisan Budget Act of 2018 laid groundwork by allowing some expansions, but the full breakthrough came in 2020 when the CARES Act and CMS waivers brought therapists into the telehealth fold. Subsequent legislation, including the Consolidated Appropriations Act of 2023, kept extending temporary flexibilities. The current authority runs through September 2025, as explained in the CMS FAQ.
Advocacy from professional associations like the American Physical Therapy Association (APTA) and American Occupational Therapy Association (AOTA) was pivotal. Their lobbying convinced Congress that cutting off therapy telehealth would disproportionately harm seniors and disabled patients who rely on continuity of care.
What codes are on the list
Even though PTs and OTs remain eligible practitioners, not all services qualify. Only CPT and HCPCS codes included on the CMS telehealth list are payable. CMS updates this list annually and sometimes quarterly, depending on legislative or regulatory changes.
Check CMS Telehealth List for payable codes
For pt telehealth 2025, codes such as 97110 (therapeutic exercise), 97112 (neuromuscular re-education), and 92507 (speech therapy) remain on the list. Others, such as group therapy codes, have dropped off. The official CMS telehealth list is the definitive source for what’s payable.
Failing to cross-check codes against the list before billing invites denials. Practices that embed this step into scheduling workflows, similar to how they already confirm benefits and authorizations, experience fewer rejected claims.
Compliance risks and audit trends
The Office of Inspector General (OIG) has flagged outpatient therapy as an error-prone service line, with its audit reporting that over 60% of sampled PT claims did not comply with Medicare requirements. While that report predates the pandemic, the compliance risks extend directly to telehealth because the same coding, documentation, and medical necessity rules apply.
A key risk area is improper use of telehealth codes or modifiers. For example, submitting a therapy service that is not on the CMS telehealth list or failing to append modifier 95 when required can trigger denials or even repayment demands in audits.
Did You Know? CMS’s Payment Integrity Reports consistently identify insufficient documentation as a leading driver of improper Medicare payments, often exceeding 7% of total claims in recent years.
Clinics that want to stay audit-ready should leverage internal PROMBS resources like the CMS-1500 Claim Form Guide for claim field accuracy and PROMBS specialties for discipline-specific rules.
Operational Best Practices for Telehealth Therapy Delivery
Even with clear rules from CMS, the gap between policy and practice often shows up in day-to-day operations. Many denials aren’t caused by fraud or abuse, but by preventable oversights such as forgetting modifier 95 or using the wrong POS code. Clinics that establish structured workflows have far fewer compliance headaches.
Scheduling workflows
One best practice is to confirm CPT eligibility against the CMS telehealth list at the time of booking. Schedulers should verify that the planned code is payable by telehealth and note the expected POS (02 or 10) in the appointment record. This prevents the all-too-common scenario where a therapist delivers a service that is ineligible for telehealth reimbursement.
Staff training
Billing accuracy depends on consistent staff knowledge. Training should emphasize how to pair POS 02/10 with modifier 95, how to document patient consent, and how to distinguish between audio-only and video sessions. PROMBS’s CMS-1500 Claim Form Guide provides a line-by-line walkthrough that can serve as a practical reference for billers. For therapy groups with multiple service lines, directing staff to the PROMBS specialties hub ensures everyone understands discipline-specific nuances.
EHR optimization
Another best practice is to build POS and modifier prompts into the EHR itself. One multi-site clinic embedded a rule that automatically flags therapy telehealth visits, reminding therapists to check the cms telehealth list and select the correct POS code. After implementing this change, the clinic reported a 40% drop in telehealth denials.
Internal audits
Regular chart reviews can catch errors before payers do. Clinics that conduct quarterly internal audits, modeled on CMS’s own audit approach, can correct modifier mistakes and retrain staff before denials accumulate. This operational discipline not only safeguards compliance but also improves first-pass yield, a revenue cycle metric that directly affects cash flow.
POS & modifiers where applicable
According to the CMS Telehealth FAQ, therapy services delivered by telehealth must use POS 02 (“Telehealth provided other than patient’s home”) or POS 10 (“Telehealth provided in patient’s home”). Every payable CPT code must also carry modifier 95, which designates synchronous telehealth.
For example, a PT delivering therapeutic exercise to a patient in their living room should code 97110-95 with POS 10. If the patient is at a community center, the correct entry is 97110-95 with POS 02. Leaving off modifier 95 results in the claim being processed as if it were in-person, often at a lower or denied rate.
To reinforce correct coding, PROMBS offers practical explainers like the POS 10 Telehealth Guide and the POS 11 Billing Guide, which help staff avoid mismatched claims.
Revenue cycle impact of telehealth therapy
The way telehealth claims are billed has direct financial consequences. If POS or modifiers are incorrect, services may be denied, downcoded, or paid at a non-facility rate. This adds friction to cash flow and increases AR days.
Consider a clinic that submits 97110 without modifier 95. The claim may be denied, requiring a corrected resubmission, which delays payment by 30–60 days. Worse, if not corrected, it inflates the clinic’s denial rate.
Correct vs Incorrect Telehealth Claim Impact
| Scenario | Claim Example | Payment Outcome |
|---|---|---|
| Correct Claim | 97110-95, POS 10 | Paid at full telehealth rate |
| Missing Modifier | 97110, POS 10 | Denied or underpaid |
| Wrong POS | 97110-95, POS 11 | Processed incorrectly, possible denial |
Practices that proactively integrate billing guides like the CMS-1500 Claim Form Guide and denial reduction strategies like Cut Prior Authorization Denials by 30% can preserve revenue integrity while maintaining compliance.
Documentation & consent
Billing requirements mean little if documentation is lacking. CMS requires notes to include explicit statements about patient consent, modality used, and patient location.
Patient location rules and audio-only limits
The HHS Telehealth Policy Updates specify that Medicare covers therapy telehealth when the patient is at home (POS 10) or another eligible site (POS 02). Audio-only services are severely restricted, most PT codes require real-time video.
For example, documenting “Patient consented to telehealth session from home via Zoom video; duration 30 minutes” creates a clear compliance trail. If audio-only is used for an allowable service, the note should specify, “Audio-only telehealth provided; patient consent documented.”
Clinics should train staff to apply modifier rules consistently across all services, referencing PROMBS resources like Mastering Modifiers 59, 25, and 91 for multi-service encounters.
Telehealth Billing Checklist
| Element | Requirement | Example |
|---|---|---|
| Eligibility | PT/OT/SLP covered through 9/30/2025 | “Telehealth session by PT, eligibility confirmed via April 2025 CMS FAQ.” |
| CPT Code | Must appear on the CMS telehealth list | 97110 ✓, 97530 ✗ |
| POS + Modifier | POS 02 or 10 + modifier 95 | POS 10, CPT 97110-95 |
| Documentation | Location, consent, modality, audio-only if applicable | “Patient at home; video session via Doxy.me; consent obtained.” |
Patient Access, Equity, and Quality Considerations
Telehealth for therapy is not only a billing issue, it’s also a lifeline for patients who might otherwise go without care. The HHS Telehealth Policy Updates page emphasizes that telehealth reduces barriers for patients in rural or underserved communities, where transportation challenges often lead to missed appointments. For older adults and those with mobility limitations, accessing therapy from home is not just convenient, it’s essential for maintaining functional independence.
Equity gaps
Despite its promise, telehealth also highlights disparities. Research summarized by KFF shows that Medicare beneficiaries with lower incomes and limited digital literacy are less likely to use video-based services, relying instead on audio-only encounters. Since most PT and OT codes require video, this creates an access gap for patients without broadband or smart devices. Therapists should be proactive in documenting when a patient cannot use video and ensure that services are billed only if they are allowable under current rules.
Audio-only challenges
CMS’s April 2025 FAQ confirms that only certain therapy-related codes are payable via audio-only telehealth. While behavioral health has broader flexibility, PT, OT, and SLP codes usually require synchronous video. Providers must explain this limitation to patients up front, both to set expectations and to avoid compliance pitfalls.
Quality of care
Access is only meaningful if quality is preserved. Clinics should track outcomes for telehealth patients and compare them against in-person benchmarks. PROMBS encourages clinics to integrate functional status assessments into both in-person and telehealth workflows to demonstrate that quality is not being compromised. Linking this documentation discipline to payer expectations reduces audit risk and strengthens the case for permanent telehealth coverage.
Did You Know? According to CMS utilization data analyzed by Health Affairs, more than 10 million Medicare beneficiaries used telehealth visits in 2023, and therapy accounted for a growing share of those encounters.
By weaving equity considerations into their compliance strategy, clinics not only reduce denials but also build patient trust. Documenting patient consent, noting barriers to video access, and explaining modality choices are all essential steps that protect both compliance and the therapeutic alliance.
Future outlook for PT telehealth beyond 2025
What happens after September 30, 2025? Unless Congress acts again, PTs, OTs, and SLPs will fall off the eligible provider list for telehealth. According to policy analyses from KFF and articles in Health Affairs, lawmakers remain divided on whether to make therapy telehealth permanent.
CMS has signaled in its rulemaking that it prefers Congress to decide. If no extension passes, therapists may lose telehealth eligibility, forcing a return to in-person services only. On the other hand, bipartisan bills introduced in 2024 suggest strong support for permanence.
Clinics preparing now should build dual workflows: one for continued telehealth under current policy, and one for a potential rollback in October 2025. EHR vendors are already adding predictive flags for compliance, and payers are piloting AI-driven reviews of telehealth claims.
Conclusion
The path forward for pt telehealth 2025 is clear through September 30, 2025, but uncertain beyond that date. PTs, OTs, and SLPs can continue to furnish telehealth as long as services are on the CMS telehealth list, billed with POS 02 or 10 and modifier 95, and documented with patient consent and modality. By leveraging the CMS Telehealth FAQ, April 2025 and HHS Telehealth Policy Updates, alongside internal tools like the CMS-1500 Claim Form Guide and PROMBS specialties, providers can ensure compliant, revenue-safe billing.
Whether therapy telehealth becomes permanent or lapses after 2025, clinics that embed compliance into scheduling, billing, and documentation will stay audit-ready, protect revenue, and sustain access for patients who need therapy most.
