When the COVID pandemic hit, many people who had never used telehealth before decided to give it a try—primarily to avoid sitting in waiting rooms full of sick people. Once they learned how convenient and effective virtual visits could be, many stuck with it.

While telehealth usage has declined from its peak during the pandemic, it remains significantly higher than pre-COVID levels. Today, most health plans—whether individual coverage or Medicare Advantage—include telehealth services as a standard benefit.

However, some of the regulations that initially made telehealth broadly accessible are beginning to shift, especially concerning Medicare and HSA-qualified plans. Here’s what health insurance agents need to know in 2025.

Medicare Flexibilities Remain—But Only Temporarily

During the pandemic, Medicare eased rules to simplify telehealth usage. Beneficiaries could receive virtual care from home regardless of their geographic location, and a wider range of providers were permitted to offer telehealth services—including audio-only visits.

As HHS explains, Congress has extended these flexibilities, which were initially set to expire March 31, 2025, through September 30, 2025. As a result, your Medicare clients, including those with original Medicare and a supplement, can still access telehealth conveniently from their homes without meeting geographic restrictions.

However, these provisions aren't permanent. If Congress does not extend the measures again, stricter rules will return beginning in October 2025. Brokers should monitor this closely, particularly for clients who have become accustomed to the convenience of telehealth visits.

HSA-Compatible Plans: Telehealth Waiver Has Ended

A notable change occurred at the end of 2024. During the pandemic, HSA-qualified High-Deductible Health Plans (HDHPs) were temporarily permitted to cover telehealth services before the deductible was met—an important benefit that helped reduce costs for clients who preferred virtual visits. However, this policy quietly expired at the end of 2024.

According to IRS Publication 969, HDHPs can no longer cover most telehealth services until members meet their calendar-year deductible. This change could come as a surprise to clients accustomed to low-cost or no-cost virtual visits who may not know about the rule change.

Brokers should communicate this update to their HSA-eligible clients so they won’t be caught off guard next time they pick up the phone and call a doctor.

Telehealth Coverage for Individual Plans

For both ACA marketplace and off-exchange plans, telehealth services remain widely available. Insurers typically either partner with national telehealth vendors or offer virtual visits through their own provider networks. While billing and reimbursement rules can still vary by state, most clients won’t notice major differences—aside from the recent change affecting HSA-qualified plans.

Bottom Line for Brokers

Even though the rules are shifting again, telehealth is still part of the conversation, and clients will look to you for answers. Here are a few key takeaways to keep in mind:

• Communicate clearly to HSA users: Make sure your clients know the deductible-first rule is back for telehealth under HDHPs. Most will now pay the full cost of their next virtual visit until they meet their deductible. This change hasn’t gotten much attention but could have a big impact going forward.
• Prepare Medicare clients for possible changes: Medicare beneficiaries will continue to have full telehealth access through Q3, 2025, but be ready to explain potential changes if Congress doesn’t act again.
• Review individual plan details: Most individual-market plans still include telehealth, but the specifics vary by carrier and state. Understand what each plan offers so you can guide clients with confidence.

Telehealth may no longer dominate headlines the way it did a few years ago, but it’s still a key part of how care is delivered. As brokers, it’s our job to help clients understand how it works with their coverage—before they get the bill.