The Audio-Only Telehealth Access Act of 2025 amends section 1834(m)(9) of the Social Security Act to require the Secretary of Health and Human Services to provide Medicare coverage and payment for telehealth services identified in section 1834(m)(4)(F)(i) when furnished via an audio-only communications system. The text makes that coverage applicable on or after the first day of the emergency period referenced in section 1135(g)(1)(B).
This is primarily an access and payment directive: it forces Medicare to pay for certain services delivered without video, and it does so with retroactive force to the start of the emergency period. The change shifts implementation and payment decisions to CMS, creates immediate billing and documentation work for providers and contractors, and raises questions about payment methodology, program integrity, and whether coverage continues once the emergency period ends.
At a Glance
What It Does
The bill amends 42 U.S.C. 1395m(m)(9) to require Medicare coverage and payment for telehealth services that are listed in 1834(m)(4)(F)(i) when those services are furnished using audio-only communications. The coverage applies to services furnished on or after the first day of the emergency period defined in section 1135(g)(1)(B).
Who It Affects
Medicare beneficiaries who receive care by telephone rather than video, clinicians and suppliers billing Medicare (including Part B providers), CMS and its contractors responsible for claims processing and audit, and Medicare program budget managers. Medicare Advantage plans will also need to reconcile their coverage with Medicare fee-for-service rules.
Why It Matters
It removes a legal barrier that has limited payment for audio-only encounters for specific enumerated services and creates a clear federal payment mandate. That changes access dynamics for patients without video capability and compels CMS to set up billing, coding, payment rates, and oversight for audio-only encounters.
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What This Bill Actually Does
The bill makes a narrow but consequential change to the Medicare telehealth statute. It directs the Secretary to cover and pay for telehealth services that are already identified in the statutory list at 1834(m)(4)(F)(i) when those services are provided by audio-only communications.
The change is targeted — it applies only to the services that are on that statutory list as of the bill’s enactment — and it ties the timing of coverage to the emergency period referenced in section 1135(g)(1)(B).
Because the amendment says coverage applies to services furnished "on or after the first day of the emergency period," the practical effect is twofold: it authorizes retroactive payment back to that start date, and it can be read to make coverage available going forward from that date unless CMS or subsequent law limits it. The bill does not itself define payment amounts, modifiers, or documentation rules; it simply obliges Medicare to provide coverage and payment for the enumerated services when delivered by audio-only means.Implementation will require administrative work.
CMS will need to determine which billing codes correspond to the statutory list, decide how to price audio-only visits relative to in-person and video visits, issue transmittals and manuals to carriers and Medicare Administrative Contractors (MACs), and set documentation and audit expectations. Providers will need guidance on appropriate use, coding modifiers, and medical necessity standards to avoid claim denials or future recovery actions.The bill leaves open several practical questions that affect providers and beneficiaries: whether audio-only services will be paid at parity with video or in-person care, how claims will be identified and audited for program integrity, and whether the list-based restriction will block newly recognized telehealth services from audio-only coverage unless Congress or regulators expand the list.
Those implementation choices will determine both access outcomes for patients without video and fiscal impact for the Medicare program.
The Five Things You Need to Know
The bill amends 42 U.S.C. 1395m(m)(9) to require Medicare coverage and payment for telehealth services identified in 1834(m)(4)(F)(i) when furnished via an audio-only communications system.
Coverage is effective for services furnished on or after the first day of the emergency period referenced in section 1135(g)(1)(B), creating retroactive coverage to that start date.
The statute limits audio-only coverage to services that are on the 1834(m)(4)(F)(i) list as of the date of enactment; services added to the list later are not automatically covered under this amendment.
The bill does not set payment rates, coding modifiers, or documentation standards — it directs coverage/payment but leaves pricing and implementation details to CMS and Medicare contractors.
Because the text requires coverage for services furnished "on or after" the emergency period start, it can be interpreted to require ongoing coverage from that date rather than limiting payment strictly to the emergency window.
Section-by-Section Breakdown
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Short title
Provides the act’s name: the Audio-Only Telehealth Access Act of 2025. This is a standard heading with no operational effect; it signals the bill’s purpose for readers and bill tracking systems but does not change legal obligations.
Mandate for Medicare coverage and payment of audio-only services
Rewrites the first sentence of 42 U.S.C. 1395m(m)(9) to require the Secretary to provide Medicare coverage and payment for telehealth services identified in paragraph (4)(F)(i) when furnished via audio-only communications. In practical terms, this converts an emergency-era flexibility (which may previously have been exercised through waivers or guidance) into a statutory payment requirement for the enumerated services.
Retroactivity to the emergency period start and list-based scope
The amendment ties effective coverage to the first day of the emergency period defined in section 1135(g)(1)(B), making payment applicable to services furnished on or after that date. The coverage is constrained to services that are listed in 1834(m)(4)(F)(i) as of the enactment date, which freezes the set of services eligible for audio-only payment unless the statutory list is later modified.
Delegates implementation, coding, and payment policy to CMS
Because the bill authorizes payment but does not specify rates, placing responsibility on CMS for operationalization, the agency must map covered services to billing codes, decide payment methodology (parity or discounted rates), issue claims-processing instructions to MACs, and set documentation and audit rules. Those downstream choices will determine how providers bill and how claims are adjudicated.
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Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Medicare beneficiaries without reliable broadband or video-capable devices — the bill clarifies that eligible telehealth encounters by telephone can be paid by Medicare, reducing a barrier to care for populations with limited digital access.
- Clinicians who have been providing audio-only care (for example, some behavioral health and primary care providers) — the mandate creates a clearer path to reimbursement for services they already furnish without video.
- Rural health clinics and community health centers serving patients with poor broadband — those providers can more reliably seek Medicare payment for otherwise billable telehealth services delivered by phone.
- Care coordinators and homebound beneficiaries who use telephone-based check-ins — the bill preserves a payment option that supports continuity of care when video is impractical.
Who Bears the Cost
- CMS and the Medicare Trust Funds — broader coverage and retroactive payments will increase administrative workload and may raise program expenditures depending on utilization and payment levels.
- Medicare contractors and MACs — they must update systems, process potentially large numbers of retroactive claims, and implement new audit workflows, creating operational costs.
- Providers unfamiliar with telehealth billing — they face compliance risk and administrative burden to learn new coding, modifiers, and documentation expectations; some will absorb time and cost to retroactively resubmit claims.
- Program integrity units and auditors — expanding audio-only coverage can increase recovery work and investigative burdens if fraud or inappropriate billing rises, requiring more resources for oversight.
Key Issues
The Core Tension
The central dilemma is between expanding access for patients who cannot use video and protecting Medicare’s fiscal integrity and clinical quality standards: the bill mandates access via audio-only channels for enumerated services, but it leaves payment, coding, and oversight details unresolved, forcing a trade-off between rapid access gains and the risk of overpayment, inappropriate use, or reduced care quality.
The bill does relatively little textually — it creates a coverage requirement but leaves crucial implementation choices to CMS. That delegation produces immediate uncertainty: regulators must decide how to identify audio-only claims on the claim form, whether to pay them at the same rate as video or in-person visits, and what documentation satisfies medical necessity.
Those decisions will materially affect access, provider revenue, and Medicare spending.
Two drafting choices in particular create open questions. First, the list-limited approach freezes eligible services to those named in 1834(m)(4)(F)(i) as of enactment, which could leave out services that the clinical community later deems appropriate for audio-only delivery.
Second, the effective-date language ("on or after the first day of the emergency period") authorizes retroactive payments and can be read to create ongoing coverage starting from that date, rather than limiting payment strictly to dates during the emergency. Either interpretation has budget and policy consequences that CMS and the budget scorekeepers will need to resolve.
Finally, without payment-rate language and with increased audit exposure, providers face both reimbursement opportunity and compliance risk — the law creates entitlement but not clarity on how that entitlement is measured or policed.
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