Telemedicine (aka telehealth) is the practice of medicine using electronic communication and information technology between a healthcare provider in one location and a patient in another location, essentially a remote or virtual encounter. Telemedicine has been in use for longer than we might imagine. One of the earliest examples of the use of video communication for medical purposes occurred at the University of Nebraska in 1959. Clinicians established a two-way television setup to transmit information to medical students across campus, and five years later linked with a state hospital to perform video consultations.¹ Historically, telemedicine was seen as a tremendous benefit, in particular, for providing better healthcare access to rural communities that lacked physicians and medical facilities and healthcare resources.
With the onset of the COVID-19 pandemic, telemedicine use increased dramatically to provide medical care safely and remotely to patients. Initially, there was a learning curve for physicians to adopt telemedicine if they had not been using it prior to the pandemic. Overall, healthcare providers were able to quickly implement the use of telemedicine as part of their provision of medical services and consultation.
Telemedicine continues to be a mainstay of providing healthcare access and medical services to patients. During the pandemic, the federal government and Centers for Medicare and Medicaid Services (CMS) waived certain regulatory requirements that allowed for easier deployment of telemedicine services. For example, a telemedicine encounter did not require an in-person office visit as a prerequisite to conduct future telemedicine visits with patients.
At the end of 2024, congressional passage of the American Relief Act extended the deadlines of many of these waivers to March 31, 2025.² On March 15, 2025, Congress enacted a government funding package, H.R. 196, “Full-Year Continuing Appropriations and Extensions Act, 2025,“ that included a six-month extension of current Medicare telehealth waivers through September 30, 2025.³
Highlights of the Extensions of Telehealth Access Options
Some of the telehealth flexibilities have been made permanent, while others are temporary. Current telehealth policies allow the following:4
Medicare patients can receive telehealth services for non-behavioral/mental healthcare in their home through September 30, 2025.
There are no geographic restrictions for originating site for Medicare non-behavioral/mental telehealth services through September 30, 2025.
Telehealth services can be provided by all eligible Medicare providers through September 30, 2025.
Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can serve as Medicare distant site providers for non-behavioral/mental telehealth services through September 30, 2025. For an encounter furnished using interactive, real-time, audio and video telecommunications technology, or for certain audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology services, payment to RHCs and FQHCs are subject to the national average payment rates for comparable services under the physician fee schedule (PFS) through December 31, 2025.
An in-person visit within six months of an initial Medicare behavioral/mental telehealth service, and annually thereafter, is not required through September 30, 2025. For FQHCs and RHCs, the in-person visit requirement for mental health services furnished via communication technology to beneficiaries in their homes is not required until January 1, 2026.
Non-behavioral/mental telehealth services in Medicare can be delivered using audio-only communication platforms through September 30, 2025. Interactive telecommunications systems may also permanently include two-way, real-time, audio-only communication technology for any telehealth service furnished to a patient in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system, but the patient is not capable of, or does not consent to, the use of video technology.
Risk Management Best Practices
As waivers for telehealth provision of medical services have been extended in several cases, diligent adherence to sound risk management and patient safety best practices that were expanded and enhanced during the pandemic should continue.
The following risk management best practices serve as a checklist to ensure that healthcare providers are optimally engaging with patients using telemedicine platforms:5,6
- Provide ongoing training and support to staff and providers to ensure all telehealth providers are comfortable and proficient in telehealth technology and protocols.
- Clearly communicate with patients how to access and use the telehealth platform.
- Conduct a thorough assessment of the patient's technology and internet connection to ensure a successful telehealth appointment.
- Maintain a secure HIPAA-compliant platform for all telehealth appointments. Patients should be made aware of how information will be protected during telemedicine consultations, including secure communication channels and data encryption measures.
- Verify and authenticate, at each encounter, the patient’s identity and location.
- Verify, at each encounter, the patient’s readiness to proceed in a setting that is private and conducive to uninterrupted communication.
- Obtain informed consent from the patient for telehealth services. The informed consent process for telemedicine consultations should include the disclosure of potential risks and limitations of remote healthcare delivery.
- Establish protocols for handling emergencies or technical difficulties during a telehealth appointment.
- Follow up with patients after their telehealth appointment to ensure they received the care they needed.
- Ensure that all documentation and communication related to telehealth appointments are securely stored and compliant with privacy regulations.
- Step up your “webside manner.” This will ensure your patients have an optimal virtual experience and best possible medical outcomes from their telemedicine appointment with you:
- Prepare: You want your patient to have the utmost confidence in you. Know in advance why your patient is scheduled. Read the chart before your video encounter. Have a plan of action.
- Time: Avoid rushing. Your patient will feel unimportant, and you are likely to miss important clinical details. Schedule the appropriate amount of time for each patient. Allow time for questions and be aware of “the doorknob phenomenon,” when patients have a tendency to leave out critical information until the end of the visit.
- Collaborate: Guide your patient through the visit. Have the patient adjust lighting and camera, if needed, for closer inspection. Demonstrate and coach your patients to assist you with their physical examinations. Have patients use their thermometers, blood pressure cuffs, and other medical tools to gather additional clinical data.
- Continuously evaluate and improve telehealth processes and technology to provide the best possible care to patients.
- Develop a comprehensive telemedicine policy that includes the best practices outlined previously. In addition, include telemedicine prescribing guidelines and reimbursement and billing procedures.
- Comply with current state and federal guidelines, statutes, and regulations governing telemedicine.
- Consult your professional liability carrier for specific questions related to the provision of telemedicine services and coverage issues.
Overall, a comprehensive telemedicine program and policy should provide clear guidelines and procedures to ensure safe, effective, and ethical delivery of healthcare services through remote technology.
Brad Dunkin, MHA, is a Senior Risk Management and Patient Safety Specialist. Questions or comments related to this article should be directed to BDunkin@CAPphysicians.com.
¹History of Telemedicine: The Now and the Future of Healthcare,
https://evisit.com/resources/history-of-telemedicine#:~:text=The%20firs….
²Fact Sheet: American Hospital Association (AHA), February 2025
https://www.aha.org/fact-sheets/2025-02-07-fact-sheet-telehealth-waivers
³H.R.1968 - Full-Year Continuing Appropriations and Extensions Act, 2025, CONGRESS.GOV, March 15, 2025
https://www.congress.gov/bill/119th-congress/house-bill/1968
4Telehealth Policy Updates, Telehealth.hhs.gov, March 20, 2025
https://telehealth.hhs.gov/providers/telehealth-policy/telehealth-polic…
5Risk Management and Patient Safety News: Telemedicine Risk Management Strategies, Cooperative of American Physicians, 2018
6Telemedicine Webside Manner: Putting Your Best Face Forward, Cooperative of American Physicians, December 18, 2020. https://www.capphysicians.com/articles/telemedicine-webside-manner-putt…