Preparing for Possible Upcoming Telehealth Changes: What Small- and Mid-Sized ABA Agencies Need to Know

This article is intended as information only. Please don't consider it legal advice. ABA Compliance Solutions doesn't provide legal services. While we strive to offer accurate and up-to-date information, we always suggest consulting with an attorney for advice tailored to your specific needs.

If you’re running a small- or mid-sized ABA agency, you might be wondering how possible upcoming telehealth changes could affect your practice. While you likely don't bill Medicare for your services, it's important to know that commercial healthcare insurance companies often follow Medicare's lead when setting their policies. So, any shifts in Medicare’s telehealth rules could eventually trickle down to the insurance plans you bill for the ABA services you provide your clients.

The good news?

With a little preparation, you can minimize disruptions and continue delivering great care.

Overview of Upcoming Possible Telehealth Changes
One of the biggest changes on the horizon is the potential rollback of telehealth flexibilities introduced during the COVID-19 pandemic. Starting April 1, 2025, Medicare coverage for telehealth services might return to pre-pandemic rules that limit where clients can receive telehealth care. Specifically, the Centers for Medicare & Medicaid Services (CMS) is considering phasing out place of service (POS) codes 02 and 10, which currently identify telehealth services delivered outside traditional healthcare settings. You use POS 02 to indicate that you provided telehealth services to a client while that client was outside their home, and POS 10 to show that you delivered telehealth ABA services to your client while they were in their home.

If CMS eliminates POS codes 02 and 10, your clients would likely need to be located at an approved healthcare facility, such as a clinic, hospital, or other designated medical site, to receive telehealth ABA services from you. This change would mark a return to pre-pandemic rules, which generally didn't cover telehealth services provided to clients in their homes or other non-clinical settings. 

Since private insurers often align their policies with Medicare, these changes could mean adjustments in telehealth reimbursement and coverage criteria for ABA services.

How to Prepare for These Changes
Fortunately, there are steps you can take now to stay ahead of the game. Here are three key ways to prepare:

1. Review How Your Agency Uses Telehealth
• Take a close look at how often your agency provides telehealth services.
  • The more telehealth ABA services your agency provides, the more you're going to want to plan ahead for changes that may be coming.
• Identify clients who may be most affected if telehealth options become limited.
  • For those clients who rely heavily on telehealth ABA services from you, begin to think about how you might transition their care to in-person direct services, supervision, and parent coaching either in the client's home or local community, or in a center.
• Consider which providers rely most on telehealth and how their roles might shift if more sessions move to in-person.
  • For clinicians in your agency who deliver a significant portion of their ABA services via telehealth (including program supervision and family coaching ABA services), begin planning how you might need to support them if their ability to use telehealth as a medium either went away or became significantly limited.
2. Keep Tabs on Insurance Companies' Telehealth Policies
• Review the telehealth policies of the insurance companies you work with.
• Stay updated on any upcoming changes by checking for policy announcements every one to two of weeks.
• Remember that most insurance companies announce policy updates at least 30 days in advance, giving you some time to adjust, especially if you've alreayd been thinking about and planning for these possible changes.
3. Create a Contingency Plan
• Map out how your agency would respond if telehealth coverage is reduced.
• Explore hybrid service models that combine telehealth with in-person sessions.
• Assess how reduced telehealth reimbursement might impact your budget and plan accordingly.
• Communicate with clients and families early so they know what to expect and how changes may affect their services.

Conclusion
We know the thought of telehealth changes might feel overwhelming, but preparing now can help you avoid disruptions and continue providing exceptional care. By reviewing your telehealth usage, monitoring insurance policies, and planning for different scenarios, you’ll be better equipped to navigate these changes confidently. And remember—we’re here to help you stay informed and adapt as the healthcare landscape continues to evolve. Please don't hesitate to reach out if you think we can help.