Audio-only telehealth provides a simple way to bridge the digital gap in many underserved communities in the United States. Some patients do not have steady high-speed internet, devices that support video calls, or experience with video chat. For them, phone visits offer an important way to get mental health care when they need it.
Telehealth rules have changed a lot during and after the COVID-19 public health emergency to meet these challenges.
The Centers for Medicare & Medicaid Services (CMS) now allows mental and behavioral health services to be provided by live, two-way phone calls permanently. This change removes earlier limits that allowed telehealth only in rural areas or special locations. Now, Medicare patients can get these services at home anywhere in the country, which is very important where internet service is poor. About 22 percent of rural Americans still do not have broadband with good speeds, compared to just 1.5 percent in cities.
Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), which mainly serve low-income and rural people, can now provide behavioral health telehealth services from a distance. This is important because these clinics often have few workers and many patients. Using audio-only visits lets them offer mental health care without needing video technology. Medicare pays the same amount for these phone visits as in-person visits, helping clinics maintain their services. These new rules meet the needs of patients who are often older, poorer, or less familiar with digital tools.
Problems like depression, anxiety, and substance use affect underserved groups more, including people living in rural areas or who belong to racial and ethnic minorities. There are not enough mental health providers, which makes the problem worse. Experts predict the United States may be short as many as 86,000 doctors by 2036, with mental health specialists being especially scarce.
Telehealth growth, especially phone-only mental health care, helps solve many problems. It cuts down the need for travel in rural areas and helps those without video devices or stable internet. It also helps patients who feel uncomfortable using video technology. Studies showed that over 56 percent of Medicare users age 65 and older used phone-only telehealth during the pandemic, showing how important the phone is for their care.
Permanent phone-only coverage helps keep the progress made during the COVID-19 pandemic. It allows patients to keep receiving remote mental health services without having to travel or learn new technology they might not have.
CMS’s rules on telehealth change how primary care providers run telehealth services and billing. The Consolidated Appropriations Act of 2021 took away geographic and site limits permanently for behavioral health telehealth, including phone calls. This means FQHCs and RHCs can bill Medicare for these services regularly.
But other telehealth services, including phone visits not related to behavioral health, are covered only temporarily until December 31, 2024, with some parts extended to January 2026. Providers must get ready for rule changes, especially since the “telehealth policy cliff” is expected in late 2025. After September 30, 2025, Medicare will mainly cover phone-only telehealth for mental health and substance use treatments. For most other care, geographic and site limits will return unless new laws are passed.
These upcoming changes mean primary care providers and clinic managers should plan carefully. Some rules, like requiring in-person visits before mental health telehealth, might return, which could make it harder for some patients. Good communication with patients and updated workflows are important to handle these changes.
In late 2023, 12.7 percent of Medicare users used telehealth, almost double the number before the pandemic. More city residents use telehealth than rural ones (27 percent vs. 19 percent), showing ongoing internet access issues. Still, telehealth is important for vulnerable groups such as those with Medicare and Medicaid coverage (34 percent use), people with disabilities (37 percent), and racial and ethnic minorities.
Phone-only telehealth visits are very important because 26 percent of Medicare users do not have broadband or internet devices at home. Behavioral health telehealth visits have grown, and there are fewer missed appointments with virtual care than in-person visits. This helps clinics work better and patients follow their treatment plans.
A study of 35 million records from different medical fields showed that most telehealth visits did not need an in-person visit within 90 days. This proves telehealth can work well and help reduce costs. These facts show the value of telehealth, especially phone-only visits, in supporting ongoing care and meeting mental health needs for underserved people.
States have helped increase telemedicine access. During the pandemic, 22 states passed laws or rules expanding telemedicine insurance, many for the first time covering phone-only visits. This reduced costs for patients and made payment equal for telehealth and in-person visits.
Still, differences in telehealth use remain, often related to income, language, and digital skills. Older adults and patients with mental health conditions especially benefit from phone-only telehealth, which fits with their comfort levels and access.
States and healthcare providers keep collecting data on telehealth’s effects to help make long-term rules. These efforts support ongoing goals to provide fair and accessible care for underserved populations, especially during tough times like economic hardship or living in rural places.
Artificial Intelligence (AI) systems can help by automating simple healthcare tasks like scheduling, reminders, notes, and initial symptom checks using chatbots or voice helpers. This eases the work for clinic staff and healthcare workers, who often face many patients in FQHCs and RHCs. Automation frees mental health providers to focus on complex care decisions during telehealth visits.
AI-powered tools can review patient data from telehealth visits and remote monitors to spot early warning signs of mental health problems. This helps care teams act quickly and improve outcomes. AI can also help decide the level of care patients need, reducing unnecessary visits or hospitalizations.
Coding and billing for telehealth under CMS rules can be complicated. AI tools can help make sure coding is correct for telehealth services like Advanced Primary Care Management (APCM) and mental health telehealth codes. This lowers errors, ensures proper payment, and keeps clinics following the rules. This matters a lot for FQHCs and RHCs with small administrative teams.
AI chatbots and virtual helpers can explain telehealth service choices to patients, guide them in setting up phone or video visits, and offer mental health education. This helps patients who struggle with digital skills feel more comfortable using telehealth.
AI and automation make it easier to manage scheduling and follow-up across care models that mix in-person, video, and phone visits. Good workflow integration smooths movement between types of visits, helping patients with mental health conditions who need frequent check-ins.
Clinic leaders, owners, and IT managers need to get ready for permanent phone-only telehealth coverage for mental health. They should:
As healthcare moves toward value-based care focusing on managing chronic and behavioral health conditions, telehealth—especially phone-only—will be important for reaching underserved groups. Clinics that use flexible, technology-supported telehealth will better serve patients and handle rule changes smoothly.
This summary of current federal rules, research, and technology shows how permanent phone-only telehealth coverage helps mental health care in primary care for underserved communities. With ongoing rule updates and resource investments, providers can keep and grow access to needed behavioral health care through telehealth that is easy to use and centered on patients.
The 2025 proposed CMS rules emphasize accountable and value-based care, including a new Advanced Primary Care Management (APCM) model with HCPCS G-codes removing time-based billing, revisions to RPM and CCM codes for FQHCs and RHCs, permanent audio-only telehealth coverage, new digital mental health treatment codes, updated cardiovascular risk assessments, and recommendations for social needs services.
The APCM model introduces three non-time-based HCPCS G-codes, bundling elements of existing care management and technology services. Physicians and NPs can bill for comprehensive primary care oversight beginning in 2025. The goal is to simplify billing, encourage value-based care adoption, and improve care delivery by covering all patient primary care needs with new incentives for advanced care management.
Non-time-based APCM codes allow providers to bill based on comprehensive service delivery rather than minutes spent. This flexibility supports integrating AI technologies to automate routine tasks, enabling clinical staff to prioritize complex care. It fosters efficient workload management and incentivizes quality outcomes over quantity, aligning with value-based care principles.
In 2025, FQHCs and RHCs will move away from unique G0511 coding, using standard Medicare care management CPT codes at national non-facility rates. This aims to improve transparency and payment accuracy but may reduce revenue ceilings regionally. However, it potentially rewards core primary care more through APCM codes, encouraging expanded remote care services.
CMS seeks greater transparency and accurate payment reflecting patient service. The G0511 code reportedly incentivized limiting care management time to 20 minutes per patient. Removing it may lower some reimbursements but increases billing flexibility for RPM and CCM add-on codes. It encourages more precise, patient-centered care documentation and payment alignment.
AI can automate repetitive care management tasks, such as monitoring and documentation, allowing clinicians to focus on complex decision-making. In the APCM model’s non-time-based framework, AI enhances efficiency, improves workload distribution, and provides actionable insights, helping FQHCs meet comprehensive care requirements and adopt value-based care more effectively.
CMS proposes permanent coverage for real-time, bidirectional audio-only telehealth when patients cannot or do not consent to video. Extensions for virtual direct supervision and delayed in-person visit requirements for mental health services boost telehealth accessibility, benefiting underserved populations often served by FQHCs and RHCs.
Starting in 2026, APCM performance will be tracked via the Value in Primary Care MIPS Value Pathway (MVP). This introduces metrics tied to value-based outcomes, enabling providers to shape care delivery models and demonstrate improved patient-centered care. Early adopters have opportunities to influence future evaluation criteria.
FQHCs and RHCs are urged to start implementing remote care as soon as possible. Partnering with experienced remote care organizations can streamline billing complexities and operational workloads. The proposed rules affirm that RPM and CCM services remain lucrative, and remote care offers enhanced patient outcomes and reimbursement opportunities.
CMS recognizes remote care as integral to future healthcare, encouraging transition to value-based models with new care management codes. The agency is still refining optimal payment strategies for diverse patient populations. Remote care, supported by AI and telehealth, is seen as essential for improving access, efficiency, and patient outcomes, especially in resource-limited settings like FQHCs.
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