Last week the Centers for Medicare and Medicaid Services (CMS) published an updated Telehealth FAQ for Calendar Year 2025. Without congressional action to extend telehealth flexibilities, an in-person, non-telehealth visit within six months prior to their first mental health telehealth service with an annual in-person requirement for established patients is required. CMS states it does not believe this requirement applies to beneficiaries who began receiving mental health telehealth services in their homes prior to Oct. 1, 2025. That is to say, if a beneficiary began receiving services on or before Sept. 30, 2025, then they would not be required to have an in-person visit within six months and would be considered an established patient required to have at least one in-person visit every 12 months. As a reminder, statutory requirement exempts telehealth services for someone with an SUD or co-occurring diagnoses from this requirement.