The New York Telehealth Cliff Is Coming: What Residential Providers Must Know by 10/25

It took nothing short of a public health emergency (PHE) to expand telehealth services in the United States. During the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) and Department of Health and Human Services (HHS) relaxed telehealth requirements across the board for: location, provider, and cross-state licensure. With no penalties for using Zoom and other non-HIPAA-compliant platforms, and parity for telehealth and in-person visits.

On October 1, 2025, these flexibilities are set to expire. That means big shifts in how you document, bill, and prove your services, especially if you rely on telehealth.

For residential providers in New York, that could mean big changes to how you deliver care, get reimbursed, and stay compliant.

We’ll answer the questions you have about what this means for behavioral health residential treatment centers and ways you can prepare.

Before we dive in, a quick note: This is a dynamic situation, and changes may impact Medicaid and Medicare beneficiaries differently. The best way to stay ahead of which services will be reimbursable is to monitor federal and state updates. (We’ve included helpful resources throughout.)

We’ve Been Here Before: New York Telehealth Landscape 2023-2025

Since the PHE’s official end was declared in 2023, both the federal government and New York State have taken steps to keep telehealth in play before.

• In January 2024, CMS approved New York’s Section 1115 waiver amendment, known as the NY Health Equity Reform (NYHER), which included funding for New York’s telehealth infrastructure.

• In March 2025, Congress passed a Continuing Resolution extending key Medicare telehealth flexibilities through September 30, 2025.

• Two months later, the House Energy and Commerce Committee approved an amended version of the Telehealth Modernization Act (H.R. 7623), which could lock in more long-term protections.

Thanks to these actions, behavioral health residential treatment centers have continued to use telehealth for psychiatry, therapy, and care management with confidence (including audio-only services).

In fact, many providers we’ve worked with in New York say audio-only visits are critical, especially for older adults or clients without stable Wi-Fi. If those go away, access to services drops.

And while telehealth has been documented as a benefit to rural providers, urban and suburban agencies across New York have also seen telehealth allow them to reach more people, more consistently, across every demographic group.

Current Legislation to Watch

At the state level, two Senate Bills are under review by the New York State Senate Health Committee:

• S354 (NY State Senate): Would expand the types of healthcare services covered by telehealth and set clearer reimbursement guidelines. Monitor S354 updates here.

• A4512 (NY Assembly): Would allow school districts to set up school-based telehealth mental health clinics. Monitor A4512 updates here.

• (Pending) The Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act of 2023: This bill (H.R. 4189 / S. 2016) could lock in telehealth flexibilities for good, and it has strong bipartisan support. Monitor H.R. 4189; S. 2016 updates here.

All of this leads to one big moment: October 1, 2025. Here are the answers to your biggest questions:

The 2025 New York Telehealth Policy Cliff: FAQ

1. Question: Will current telehealth workflows still be reimbursable after September 30, 2025?

What will happen to billing Fees for Service (FFS) like Medicare and Medicaid FFS, particularly to audio-only and services delivered from home or residential settings?

Answer: As of September 30, 2025—barring any new legislation—many flexibilities are expiring, including Medicare and Medicaid waivers. That means:

• Audio-only visits may no longer count

• Providers may have to be on-site again

• Some staff (like LCSWs or peers) may not qualify under older rules

Why it matters: If reimbursement disappears, so does your ability to deliver care the way you’re doing it right now.

2, Question: Do New York State Medicaid rules override federal changes?

Answer: They can. New York has its own Medicaid telehealth policies, but many of these piggyback off of federal waivers. NY Medicaid and the Office of Minority Health (OMH) may respond to federal expirations quickly, but there are no guarantees.

Why it matters: You need to know which rules will stay in place, change, or need state-level legislative support.

3, Question: What documentation and compliance updates will be required if federal place-of-service and/or provider restrictions return?

Answer: You may need to specify the patient’s originating site, confirm authorization to provide telehealth services, and make updates to your informed consent forms, billing codes, and place-of-service (POS) codes.

Why it matters: You want to keep your audit risk low and avoid as many claim denials as possible.

4. Question: Will behavioral health clinicians still be able to use audio-only visits, especially for clients with limited tech access?

Answer: This is up in the air, but after September 30, 2025, audio-only services will be permitted if the patient is at home and either cannot use or declines video technology.

Also, see “What’s Not Changing” below.

Why it matters: For clients with limited tech access, this could mean missed care or treatment drop-off.

5. Question: What do we need from our EHR vendor or telehealth platform to prepare for post-2025 rules?

Answer: To prepare for potential changes, providers should ensure that their EHR and telehealth platforms can:

• Accurately capture and report place-of-service codes.

• Support documentation requirements for telehealth encounters, including modality used and patient consent.

• Adapt to changes in billing codes and reimbursement structures.

• Maintain compliance with HIPAA and other privacy regulations.

Why it matters: You don’t want to fall out of compliance or lose billing accuracy, because the rules change faster than your system can keep up.

What’s Not Changing: Telebehavioral Health for Medicare Beneficiaries

While many federal telehealth flexibilities are expiring this fall, one key rule will stay for mental and behavioral health services under Medicare:

Patients can continue receiving behavioral and mental care via telehealth from anywhere, including their homes, without geographic or location restrictions.

According to CMS guidance, this applies to services used to diagnose, evaluate, or treat:

• Mental health disorders
• Substance use disorders

This means residential behavioral health programs can continue using telehealth for therapy, psychiatric care, and SUD treatment, even if other flexibilities go away.
Just make sure the service meets Medicare’s behavioral health definitions. Read the CMS guidelines.

Coming soon for Medicare clients: The Audio-Only Telehealth Access Act: Introduced in March 2025, this bipartisan bill could make audio-only telehealth permanent for Medicare.

How AWARDS EHR Helps Residential Providers Stay Ready:

AWARDS EHR is built for the complex challenges of residential behavioral health. We’ve worked with providers navigating audits, onboarding new IOP programs, shifting to mobile crisis, and juggling housing with SUD and Medicaid billing—all at once. The tools inside AWARDS were built around those exact challenges:

• One place to manage in-person and virtual care
• Built-in documentation fields that match Medicaid rules
• Tracking by visit type, service duration, provider credentials, and consent
• Real-time reporting for audits, funding requirements, and state reporting

Your Next Steps: Navigating New York Telehealth

The telehealth landscape is shifting, and community-based providers are going to feel it first. To stay ahead and avoid disruptions to your residential service, you’ll want to:

• Monitor guidance to see which flexibilities will be retained at the state level.
• Engage with coalitions like Medicaid Matters NY or provider associations advocating for continued telehealth access.
• Ensure you have processes and systems built for what’s next:
  • Work with your EHR vendor to ensure your billing systems can quickly adapt to coding and documentation changes.
  • Communicate changes ahead of time: Update your team and clients of any changes that may impact them (forms, coding, other processes).

You’ll need a system that tracks place of service, supports consent + modality reporting, and adapts fast when billing rules change. AWARDS EHR does all three.