Congress has previously extended the Medicare fee-for-service telehealth flexibilities that were originally implemented during the COVID-19 public health emergency in 2020 multiple times, with the latest extension expiring September 30, 2025. While there is broad bipartisan support for these flexibilities, Congress has included the short-term extensions in government funding legislation. Because Congress did not reach an agreement on government funding prior to the expiration of these flexibilities, as of October 1, 2025, the Medicare telehealth flexibilities revert to pre-pandemic limitations:
- Return of geographic and originating site requirement. Medicare patients can only receive non-behavioral/mental health telehealth services from specific originating sites, such as a provider’s office, a hospital, or a skilled nursing facility.
- Limited provider type eligibility. The list of providers eligible to provide Medicare covered telehealth services is limited to physicians, physician assistants, advanced practice registered nurses, certain behavioral health providers, and registered dietitians or nutrition professionals.
- Audio-only telehealth ends. Audio-only telehealth services will only be covered for behavioral/mental health.
- Rural health clinic/federally qualified health center flexibility as distant sites ends. For non-behavioral/mental telehealth, these rural entities may no longer serve as distant sites. However, they may continue to do so for behavioral/mental telehealth.
- Waiver of the mental health visit in-person requirement. For diagnosis, evaluation, or treatment of a behavioral health disorder via telehealth to be covered by Medicare, an in-person visit is required within six months before the initial telehealth visit and every 12 months thereafter, with limited exceptions.
IN DEPTH
The Centers for Medicare & Medicaid Services (CMS) issued an MLN Connects Bulletin on the morning of October 1, 2025, that in summary states:
- When certain legislative payment provisions (extenders) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice typically lasts up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need to reprocess large volumes of claims if Congress acts after the statutory expiration date and should have a minimal impact on providers because of the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.
- Absent congressional action, beginning October 1, 2025, many of the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 public health emergency will take effect again for services that are not behavioral and mental health services. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas, and hospice recertifications that require a face-to-face encounter. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits. In the absence of congressional action, practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage. Practitioners should monitor congressional action and may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of congressional action. Medicare also will not be able to pay certain kinds of practitioners for telehealth services.
What does this mean for you and your patients?
- Continuity of care. Identify patients with upcoming telehealth appointments that may be impacted by a termination of telehealth flexibilities. While there are coverage and billing requirements that you must consider, providers continue to have a professional obligation to provide a continuity of care to patients.
- Patient communications. Consider sending a notice to affected patients (or all patients), and include such notice on the provider’s patient-facing portals or website explaining the impact, including whether there will any changes to a patient’s upcoming telehealth visit (e.g., if it will be converted to phone, move to in-person, or be billed differently) and why. If you choose to continue providing telehealth visits to impacted patients, notify the patient that Medicare may not cover the visit, and that the patient may be financially responsible for the visit. As detailed in the MLN from CMS, consider providing Medicare beneficiaries with an Advance Beneficiary Notice of Noncoverage.
- Reimbursement and cash flow. You may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of congressional action, but you should budget for the added expenses until a reinstatement occurs. It is possible – but not guaranteed – that CMS will apply a retroactive reimbursement policy to telehealth claims submitted on or after October 1, 2025. However, it is not guaranteed that Medicare would pay certain kinds of providers for telehealth services. For further information continue to monitor CMS’s telehealth coverage website. Your approach to reimbursement during the time that the telehealth flexibilities are no longer in effect may have potential fraud and abuse implications that should be carefully considered as well.
- Payor and provider agreement reviews. While Medicare telehealth flexibilities are terminated, most commercial plans (including Medicare Advantage (MA) plans) and Medicaid still provide coverage for telehealth under CMS’s telehealth flexibilities framework. Note, MA plans have statutory authority to deliver any Medicare Part B benefits via telehealth. Therefore, changes in Medicare fee-for-service coverage for telehealth do not automatically result in any changes to coverage of telehealth services provided to MA plan members. However, be mindful that commercial plans and Medicaid may also terminate telehealth flexibilities. You should immediately review your provider and/or plan agreements to identify whether their telehealth reimbursement policy is tied to Medicare and be mindful of any updates to your coverage and reimbursement policies from commercial plans (including MA plans) and Medicaid.
While there has generally been bipartisan support for an extension of the telehealth flexibilities, the timing of an additional extension and the potential for it to be retroactive is unknown. We will continue to keep you updated as things progress. Consider engaging with professional groups or state medical societies to continue to advocate to extend or codify telehealth flexibilities. Coalitions, such as the Partnership for Virtual Care, have been leading the charge on advocacy in this regard.