Understanding Medicare Telehealth Policy

  • The Center for Connected Health Policy (CCHP) has created this video primer explaining how Medicare policy gets created, who has authority to make changes and the difference between "telehealth" and "communications technology based services (CTBS)".

Essential Billing Resources:

Additional Billing Resources

Medicare Telehealth Flexibilities and Public Health Emergency (PHE) Waivers

During the COVID-19 Public Health Emergency (PHE), CMS implemented several temporary Medicare telehealth waivers to expand access to care. Some were made permanent, while others were set to expire at various points following the end of the PHE on May 11, 2023.  These flexibilities have been temporarily extended several times and technically expired on September 30, 2025.

With the President’s signing of the funding package on Wednesday, November 12, Congress has reinstated Medicare telehealth flexibilities that technically expired on September 30, 2025, making them retroactive to October 1, 2025, and extending them through January 30, 2026.

Below is a summary of the key Medicare telehealth flexibilities now extended through January 30, 2026.

  • Patient Location. Medicare beneficiaries may continue to receive telehealth services without geographic or originating site restrictions, including from their home.
  • Eligible Providers.  All Medicare-eligible providers—including OTs, PTs and SLPs—may continue providing covered telehealth services. FQHCs and RHCs may continue to serve as distance site providers.
  • Audio-Only Services.  Medicare will continue to allow audio-only telehealth for non-behavioral/mental health services when the patient is at home and video is not feasible or consented to.
  • Behavioral Health In-Person Visit Requirement. The requirement for an in-person visit within six months prior to an initial telemental health service—and annually thereafter—remains on hold for most providers.  Exception: FQHCs and RHCs must begin meeting the requirements October 1, 2025 (details below)
  • Hospice Recertification: Telehealth may continue to be used for the face-to-face recertification of hospice beneficiaries.
  • Hospital at Home Program Model: Medicare continues to support the Acute Hospital Care at Home program model, allowing participating hospitals to deliver certain inpatient-level services in a patient’s home.

What Happens After January 30, 2026?  

Unless Congress acts again, these temporary flexibilities will expire on January 30, 2026. Congress may:

  • Temporarily extend the flexibilities yet again, or
  • Make some or all of them permanent.

If Congress does not act, the system will revert to pre-pandemic telehealth requirements. To prepare for that possibility, the following existing MATRC/TRC resources—originally prepared for the September 30, 2025 “telehealth cliff”—remain relevant and will help you understand what would change after January 30, 2026:

For deeper dive guidance, read The Telehealth Policy Cliff: Preparing for October 1, 2025.  These same insights apply as you prepare for January 30, 2026.  Also keep in mind that after January 1, 2026, there will be some changes to Medicare telehealth policy as reflected in the Final CY 2026 Medicare Physician Fee Schedule Fact Sheet (November 2025)

Helpful Tool

How Will This Impact FQHCs and RHCs?

Medical Visit Services via Telehealth (G2025).  The CY 2026 Physician Fee Schedule (PFS) extends through December 31, 2026 the ability of FQHCs and RHCs to bill for non-behavioral health medical visits delivered via telecommunication technology—including audio-only—using G2025.  Payment will continue to be based on PFS-equivalent rates weighted by volume, not on PPS or AIR rates.  CMS considered paying these medical telehealth visits at PPS/AIR rates but concluded that doing so could create additional cost pressures.

Mental Health Visits via Telehealth.  CMS permanently authorized FQHCs and RHCs to provide mental health visits via telecommunication technology beginning in 2022, contingent upon meeting in-person requirements.  While the 2025 PFS had delayed these in-person requirements through 2025, the 2026 PFS now aligns FQHC/RHC policy with Federal statute. Therefore, beginning October 1, 2025:

  • An in-person mental health visit must occur within 6 months prior to the first telecommunication service.
  • Subsequent in-person visits must occur at least every 12 months.
  • A clinician and patient may jointly determine that the risks/burdens outweigh the benefits, in which case the requirement may be waived.

Acute Hospital at Home Waiver Program:  Launched in November 2020 to help address hospital capacity constraints, the Acute Hospital Care at Home waiver program allows eligible hospitals to provide hospital-level care at home.  As of March 1, 2024, participation included:

  • 315 hospitals
  • 131 health systems
  • 37 states

This waiver is now extended through January 30, 2026.

Learn more:

Frequently Asked Questions

  • Do Medicare Advantage plans cover telehealth services?   Yes.  Coverage varies by plan and may include services beyond what is covered under Medicare Fee-For-Services (FFS).  Check with your plan provider for details as the types of services offered are contingent upon each plan's contractual agreement.  Additionally, some Accountable Care Organizations (ACOs) may offer telehealth services that allow primary care doctors to care for patients without an in-person visit, no matter where they live. If your health care provider participates in an ACO, check with them to see what telehealth services may be available.
  • Are Accountable Care Organizations able to provide telehealth services?  Yes, in fact, CMS has provided expanded telehealth flexibilities for ACOs, removing geographic limitations imposed under normal FFS Medicare rules and allowing beneficiaries to receive many telehealth services from their home. Click Here to Learn More
  • Can I still be reimbursed for audio-only services? 
    • Behavioral/mental telehealth services:  May be delivered using audio-only communication platforms, though some of these services may be subject to in-person visit requirements once the PHE waivers expire.
    • For all other (non-behavioral/mental health) telehealth services:
      • The 2025 Physician Fee Schedule permanently changed the regulatory definition of an interactive telecommunications system to include audio-only for delivery of any telehealth service. However, in order to be able to use audio-only certain conditions must be met. Those conditions are:
        • The patient is in their home during the audio-only interaction (this would no longer be allowable should the PHE waivers expire) and
        • The distant site provider must be technically capable of using live video, but the patient isn’t capable or does not wish to use live video.
      • For these services:
        • Billing codes 99441-99443 have been eliminated for 2025.
        • Codes 99202-99215 should be used with the following modifiers to signify that the service was provided via audio-only:
          • Modifier 93 for non-FQHC/RHC distant site providers
          • Modifier FQ when the service is provided by an FQHC/RHC
  • Is there federal legislation in the works intending to make the temporary waivers for Medicare permanent?  CCHP is tracking over 20 active bills aimed at reforming Medicare telehealth reimbursement, many of which propose eliminating some of the most restrictive statutory provisions. Each bill varies in scope and language, addressing different components of Medicare statute. Two of the most comprehensive efforts are:
    • Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act of 2025 (HR 4206/S 1261)
    • Telehealth Coverage Act of 2025 (HR 2263)