What dermatologists need to know about ongoing telehealth policies in 2025

By Oliva Barry, Manager, Practice Management, February 1, 2025

Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff discuss important telehealth updates in 2025.

Teledermatology saw a significant surge in adoption during the COVID-19 pandemic, with nine in 10 dermatologists utilizing the technology at its peak. According to a 2022 AAD member survey, usage has slightly decreased since its initial rise, with six in 10 dermatologists continuing to incorporate teledermatology alongside fully open offices. However, this highlights the continued importance of teledermatology as a valuable tool, even as in-person visits have resumed.

This ongoing use of telehealth reflects its lasting value in dermatology, even as the landscape evolves. In alignment with these trends, CMS released the 2025 Medicare physician fee schedule final rule on Nov. 1, 2024, which includes updates on telehealth policies. Below are key telehealth policy updates to help you stay informed and begin preparing your practice for upcoming changes related to telehealth extensions, requirements, billing practices, and more.

Telehealth policies: Permanent changes and extensions through 2025

Medicare enrollment address

CMS will continue to allow clinicians providing telehealth services from home to list their practice address instead of their home address on their Medicare enrollment through 2025. Dermatologists can update or add their practice address by contacting the Medicare Administrative Contractor (MAC) in their jurisdiction via the provider enrollment hotline.

Virtual direct supervision

CMS is permanently allowing direct supervision for a subset of services; more specifically, a supervising clinician may use real-time audio and video telecommunications for services furnished incident to a dermatologist’s or non-physician clinician’s (NPC) professional services. This policy includes services with a PC/TC indicator of “5” (e.g., 96900-96912) and the service described by CPT^® code 99211, as well as other office or outpatient E/M visits for established patients who may not require the dermatologist’s or NPC’s physical presence.

CMS will continue to permit direct supervision for ‘incident to’ services that require oversight by a dermatologist or NPC through real-time audio and video communication in 2025.

Teaching physicians

CMS will continue to allow teaching physicians to use real-time audio/visual technology for virtual supervision of residents in all residency training locations through 2025. This virtual presence will continue to meet the requirement that the teaching physician be present for the key portion of the service. Additionally, the teaching physician and resident do not need to be co-located (patient, resident, and teaching physician at separate locations).

Audio-only telehealth

Starting in 2025, CMS finalized that the definition of “interactive telecommunications system” will include two-way, real-time, audio-only communication for telehealth services. This applies when the dermatologist or NPC located at the distant location has the capability to use video technology, but the patient is either unable or does not consent to video technology. CMS clarified that no additional documentation, other than the appropriate modifier, is required for audio-only services.

Please note, these telehealth flexibilities do not apply to private payers. We encourage practices to check with private payers before providing the service to ensure appropriate reimbursement expectations.

Telehealth policies: Extensions through March 31, 2025

Geographic and location restrictions for beneficiaries

This involves the telehealth flexibilities for geographic and location restrictions, which were introduced during the COVID-19 public health emergency and extended through March 31, 2025, by Congress.

These include geographic and location restrictions on where the services are provided, and limitations on the scope of practitioners who can provide Medicare telehealth services. After March 31, 2025, without congressional action, most telehealth services will be limited to Medicare beneficiaries in rural areas and specific medical settings, with patients no longer able to receive telehealth services from their home (except for behavioral health services). Dermatologists should prepare for a return to pre-pandemic rules on April 1, 2025.

Advocacy efforts

As a result of AADA’s advocacy, CMS will extend certain telehealth flexibilities through 2025, including allowing physicians to use their practice location rather than their home address for telehealth services. This policy extension, strongly supported by the Academy, helps maintain physician privacy in response to longstanding concerns about the public display of physician home addresses.

Despite current uncertainties, the Academy advocates for telemedicine policies that prioritize patient care and ensure fair reimbursement for physicians. For more information on the AADA’s efforts to shape telehealth regulations, visit the teledermatology advocacy priorities page.

Several associations, such as the American Medical Association (AMA) and Medical Group Management Association (MGMA), have confirmed their ongoing efforts to work with Congress to extend important telehealth policies.

Now that you’re familiar with telehealth highlights of the 2025 final rule and the policies set to be reinstated, explore the AAD’s telehealth resources to help ensure compliance with regulations, optimize telehealth workflows, and use the correct billing codes for teledermatology.

AAD telehealth resources

• Visit the telehealth flexibilities through 2025 and policy updates webpage for a concise overview of upcoming changes to telehealth laws and extensions in 2025.

• If you are attending the 2025 AAD Annual Meeting in Orlando, attend the in-person teledermatology session: Leveraging teledermatology to improve patient access to dermatologist-level care, on Sunday, March 9, from 1:00 - 3:00 p.m. ET. Learn more.

• Learn more about the fundamentals of teledermatology by visiting the starting teledermatology page. You’ll find information on teledermatology benefits, methods, patient guidance, compliance considerations, licensing across state lines, and more.

• Visit the Teledermatology Coding and Reimbursement information page for a teledermatology encounters coding flowchart, teledermatology quick coder, guidance on when to decide to report teledermatology encounters, and more.

• Review the AADA’s Teledermatology Standards, which outline the appropriate use of telemedicine and establish guidelines for the Academy to advocate for responsible telemedicine platform technology and telehealth reimbursement.

• Earn CME credit with the online teledermatology course Making Teledermatology Work for You: Practice Integration, Training, and Coding. Learn more by visiting the AAD Learning Center. Developed by the AAD Teledermatology Committee, the course focuses beyond the introduction to telehealth. It offers patient guidance for telehealth visits, clinician and staff guidance, potential pitfalls and how to handle them, as well as information on coding and reimbursement.

As we move beyond the public health emergency, teledermatology continues to be a vital tool in providing dermatologic care. By staying informed and being proactive, you can ensure your practice is prepared for the upcoming policy extensions and changes. With the right preparation, dermatologists can confidently maintain compliance and continue delivering exceptional care to patients.

Additional DermWorld Resources