Telehealth Update
Telehealth is not gone, but the telehealth flexibilities introduced during the COVID-19 pandemic, which significantly expanded Telehealth, expired September 30, 2025. Several bills were introduced to extend Telehealth services but did not pass in Congress. This reverts Telehealth regulations for CMS (Centers for Medicare and Medicaid Services) to pre-pandemic rules. Patients can no longer be at home and must be at the health center for a medical telehealth visit. This affects Medicare patients. Commercial payors have not yet released new telehealth policies but will likely follow Medicare’s regulations.
Effective October 1, 2025, patients must be in a rural area and physically present at an approved originating site, hospital, clinic, or federally qualified health center to receive covered telehealth services. For Medicare patients who do not qualify, CMS recommends obtaining an Advance Beneficiary Notice (ABN) if you provide a Telehealth service to a Medicare patient. This includes:
Physician or Practitioner's office
Hospital outpatient department or critical access hospital
Rural health clinic or FQHC (federally qualified health center)
Skilled nursing facility
Hospital-based or independent renal dialysis center
Mobile stroke unit or CMS approved facility
Patient’s home if the service qualifies for a permanent exception, such as behavioral health services
Community mental health center
Audio-only visits will not be covered. Provider eligibility may be limited, and only certain provider types may be allowed to perform telehealth services. How should your medical practice prepare for this change? Since not all payors follow CMS regulations, it is essential to check with commercial payors to determine if telehealth services will be available in your area.
What Should You Do Now
Review your payor policies
Review current scheduling workflows that include Telehealth
Update practitioners and staff on the Telehealth change
Determine how this change will affect your patients' access to Telehealth
The end of the telehealth flexibilities may significantly impact your practice and your patients. It is crucial to reassess your workflows, compliance, and billing strategies.