It’s early November 2025, and mental health clinicians are supporting clients through seasonal transitions and the emotional strain tied to the ongoing federal government shutdown. In the middle of that disruption, a key Medicare rule went into effect that impacts telehealth for mental and behavioral health providers. The requirement that Medicare beneficiaries must be seen in person to support ongoing telehealth care is now active again.
From what many in the field understand, this timing is not coincidental. During the shutdown, the federal government was unable to extend the post-COVID telehealth flexibilities, and the previous Medicare rule — which requires an in-person visit — automatically resumed. When the government reopens, these flexibilities may return, but for now, clinicians must follow the current policy.
What the Rule Requires
Under the current Medicare telehealth policy for behavioral health (implemented as of October 1, 2025), new Medicare patients must have an in-person visit within six months of their first telehealth appointment. Said another way, you must hold an initial intake appointment in person, and then within six months of that intake you can see them for telehealth appointments. Then, Medicare requires an in-person appointment at least once every twelve months to continue telehealth services, unless a documented clinical exception applies.
For clients seen for the first time after September 30, 2025, this rule clearly applies. For existing Medicare patients, there has been some confusion around whether they must also be seen in person before their first telehealth session after October 1. However, guidance from both professional sources — including Barbara Griswold’s Medicare policy breakdown — indicates that annual in-person visits may be sufficient for established patients, without requiring a new pre-telehealth in-person appointment.
This rule affects psychotherapy, psychiatric services, and behavioral health care delivered by Medicare-covered professionals including psychologists, licensed clinical social workers, psychiatrists, and psychiatric nurse practitioners.
Why This Matters for Providers and Patients
For many Medicare beneficiaries, telehealth has become a vital access point — particularly for older adults, individuals with disabilities, and patients who face transportation barriers or health risks. This shift back to in-person requirements may introduce new scheduling and accessibility challenges for both providers and clients. It also requires clinicians to plan for hybrid care workflows and ensure documentation supports exceptions where safety, mobility, or distance would make an in-person visit unreasonable.
The policy shift also raises uncertainty: because it stemmed from a lapse in renewal rather than an intentional reversal of pandemic-era access, there is a possibility that the government will restore telehealth flexibility when operations resume. Until then, compliance and clear communication are essential.
How to Move Forward
Private practice clinicians should review their Medicare caseload, update intake and telehealth consent language to reflect the current rule, and begin communicating the requirement to any new Medicare telehealth patients. If a patient cannot safely or reasonably attend in person, document the clinical justification. While this policy adds complexity, it does not change the mission: maintaining continuity of care and supporting access for Medicare beneficiaries.
At Phoenix Therapists’ Hub, we believe clarity and connection support both clinician wellbeing and client access. Policy shifts like this can feel destabilizing, especially amid a government shutdown, but therapists do not have to navigate them alone. We will continue monitoring Medicare telehealth guidance and sharing updates to help providers stay informed, compliant, and grounded in their work.
When therapists are supported, clients feel it — and everyone can breathe a little easier.
*To prepare this article, we called Noridian, Arizona’s Medicare contractor, to corroborate the information with what we’d been hearing online. The Noridian representative directed us to this resource (see page 5), which is somewhat convoluted as usual but seems to support Griswold’s assertions.