Telebehavioral Health Endures Post-Public Health Emergency (PHE)
Population Health Alliance
The industry’s only multi-stakeholder professional and trade association solely focused on population health.
In May, we asked, What’s the Outlook for Telehealth? and identified some potential warning signs – but also optimistic projections. Since the end of the COVID-19 public health emergency (PHE) on May 11, 2023, telehealth has seen significant regulatory and operational shifts. Several temporary flexibilities granted during the PHE have been extended, while some have reverted to pre-pandemic norms. In particular, telebehavioral health has benefitted from permanent changes to Medicare, including the following:
What Are Some Trends in Telehealth Use?
This Medicare Telehealth Trends Report, based on Medicare FFS Part B Claims data (January 1, 2020 – September 30, 2023, Received by February 15, 2024), shows a steady decline in the percentage of Medicare users with a telehealth service. The following graph is from the CMS report:
However, despite the overall downward trend, telehealth services for behavioral and mental health have been resilient, partly due to easing access to these services, supported by the many permanent policy changes. This is especially true since these services can now be delivered without geographic restrictions, and audio-only telehealth remains an option for these cases.
While telehealth utilization for most other specialties has decreased to single digits, this analysis (November 2023) by EpicResearch shows that mental encounters via telehealth peaked at 65% of all encounters during the 2nd quarter of 2020 and remained steady at 36.8% in the 3rd quarter of 2023. In comparison, telehealth utilization by internal medicine and family medicine was much lower in the 2nd quarter of 2020 (39% and 31.1%, respectively) and dropped to 6% in the 3rd quarter of 2023.
What about other specialties?
Interestingly, but not surprisingly, specialties such as cardiology, endocrinology, and dermatology are also integrating telehealth, especially for follow-up consultations and chronic disease management, albeit at lower utilization than mental health.
A Doximity report (2023) based on a survey of over 1,200 physicians using its platform across nine specialties (i.e., not primary care). The top 10 specialties using telehealth based on adoption rates were Endocrinology, Urology, Gastroenterology, Rheumatology, Neurology, ENT, Nephrology, Cardiology, Dermatology, and Pulmonary.? The most common use case for telemedicine was for routine follow-up encounters to discuss lab and test results or to explore treatment options. The latter was most common among oncologists.
领英推荐
What does the recent Physician Fee Schedule Proposed Rule have for telehealth?
On July 10, 2025, CMS released the Calendar Year 2025 Physician Fee Schedule (PFS) proposed rule with updates for the Medicare PFS. It includes several provisions pertinent to telehealth services. You can download an Excel (or CSV) file from the CMS website here (zip file) for a complete list of CMS's proposed changes related to telehealth services. Here’s a list of services that CMS has proposed adding to telehealth:
For a summary of the proposed changes, see CMS’ Fact Sheet here.
Epstein Becker Green's (EBG) post provides an additional overview of policy activity (as of November 2023), including an anticipated greater focus on fraud, enforcement, and interstate licensure compacts to facilitate cross-state practice by physicians, nurses, psychologists, counselors, and nurse practitioners.
So, What’s the Future Outlook for Telehealth?
Ongoing regulatory adjustments and the permanent integration of certain flexibilities will likely shape the future of telehealth. Telebehavioral health has become an accepted modality of care delivery for approximately 35-40% of encounters. If the policy support continues and patients view telehealth as complementary to in-person encounters, telehealth will remain an essential component of the healthcare delivery system, especially for behavioral health services.
PHA Supports Telehealth Expansion
The Population Health Alliance (PHA) supports the continued expansion of telehealth. When provided by highly qualified professionals, it is an essential modality of care for various conditions across disparate geographies and specialties. Telehealth is also an appropriate complement to in-person care when it makes clinical and logistical sense.
PHA supports providing telehealth across state lines without requiring an initial, in-person encounter.
Join Us!
If you are a PHA member and want to join our Integrated Behavioral Health Workgroup, please email me at?[email protected]. If you are not a PHA member, please?join?today.? Attend the PHA Innovation and Adoption Summit in Washington DC on October 23 &24 and hear Neeraj Gandotra, MD Chief Medical Officer, SAMHSA, deliver the keynote on Integrated Behavioral Health and Substance Use Disorder Treatment.
Michael S. Barr, MD, MBA, MACP, FRCP. Senior Director, Population Health Improvement Population Health Alliance