As of October 1, 2025, many of the Medicare telehealth flexibilities that were introduced during the COVID-19 public health emergency are no longer in effect. These temporary changes had been extended multiple times by Congress, most recently through September 30, 2025. Despite widespread bipartisan support, Congress did not reach a deal to extend the flexibilities further before the deadline.
Now, without congressional action, Medicare’s telehealth rules have reverted to their pre-pandemic status. These changes affect providers, patients, billing practices, and future planning.
What are Key Changes?
- Geographic and Originating Site Rules Return: Non-mental health telehealth services can no longer be delivered to patients in their homes. Instead, patients must be at specific locations like a provider’s office, hospital, or skilled nursing facility — and they must be in rural areas.
- Fewer Eligible Providers: Only specific provider types can bill Medicare for telehealth: physicians, PAs, APRNs, certain behavioral health professionals, and dietitians.
- Audio-Only Telehealth Restricted: Audio-only visits are now only covered for behavioral or mental health services. All other telehealth must be video-based.
- FQHCs and RHCs Can No Longer Act as Distant Sites: For non-mental health services, Federally Qualified Health Centers and Rural Health Clinics can no longer serve as the distant site for telehealth.
- In-Person Visit Requirement for Mental Health Telehealth: For mental health care via telehealth to be covered, an in-person visit is now required within six months before the first telehealth appointment and annually thereafter, with limited exceptions.
How Does This Impact Me?
- Review Your Appointments and Care Plans: Identify patients with upcoming telehealth visits that may no longer be covered. Make arrangements for alternative care, such as converting visits to in-person or checking other coverage options.
- Communicate with Patients: Let affected patients know about the changes. Post notices in your patient portal or website. If you continue providing telehealth that is not covered, give patients an Advance Beneficiary Notice (ABN) to inform them they may be responsible for the cost.
- Plan for Reimbursement and Cash Flow: Decide whether to hold claims for non-covered services or risk denials. Budget for possible delays. If Congress acts later, retroactive payment is possible but not guaranteed.
- Check Other Coverage Sources: Medicare Advantage and Medicaid may still cover telehealth services. Review your contracts and check whether their policies are linked to Medicare fee-for-service rules.
CMS Response and Claims Hold
The Centers for Medicare and Medicaid Services (CMS) issued guidance directing Medicare Administrative Contractors to place a temporary claims hold up to 10 business days for services impacted by the change. This is to avoid reprocessing claims if Congress acts late. Providers can still submit claims during this time, but payments won’t be issued until the hold ends.
Advocacy and Looking Ahead
While Congress may still act, the timing and scope of any future extension are uncertain. Join professionals or advocacy groups to support efforts to preserve and expand telehealth access.