Key Takeaways

• Unless Congress acts, Medicare telehealth flexibilities put in place since the COVID-19 pandemic will expire Sept. 30, 2025. Many services and settings that are reimbursable today will no longer qualify for Medicare reimbursement.
• CMS has proposed new rules for 2026, but providers must prepare now to comply with more restrictive standards. Delaying preparation could mean lost revenue and compliance exposure.
• Providers should review their operations now and plan accordingly.

The widespread use of telehealth has become routine — but many of the flexibilities that enabled it are temporary. Without Congressional action, the Medicare telehealth waivers and flexibilities that health care providers rely on will end Sept. 30, 2025. Health care providers should be prepared for these significant changes. 

During the COVID-19 pandemic, waivers were implemented to facilitate fast adoption and Medicare coverage for telehealth services in medical and behavioral health. Some waivers related to regulatory requirements, which Centers for Medicare and Medicaid (CMS) control, while others waived statutory requirements, that only Congress could change.

Although CMS has proposed certain changes to the regulatory requirements under its purview, key statutory flexibilities expire on Sept. 30, 2025. Congress will have to act to keep them — and the likelihood of a last-minute extension or permanent adoption before then seems increasingly unlikely.

If and until Congress acts, any telehealth services furnished after Oct. 1, 2025 must comply with the Medicare coverage guidelines then in effect — meaning providers who delay in preparing for the end of the statutory waivers risk losing telehealth revenue. Importantly, state Medicaid agencies and commercial payors are not required to follow Medicare statutes and rules. Providers will need to track those payor requirements separately and be prepared to operate under differing payor guidelines for the time being.   

Key Changes Effective Oct. 1, 2025:

Below is a summary of the upcoming changes impacting both medical and behavioral health providers:

Action Items for Providers:

Providers should act now to mitigate compliance and revenue risks. Here’s what providers can do to prepare now and stay ahead of the change:

• Review current telehealth use and identify services that may no longer qualify for Medicare reimbursement after Sept. 30, 2025.
• Determine what patients and services will no longer be covered under Medicare under these changes. Plan for needed operational changes to continue effective patient care within the new coverage guidelines.
• Develop plans for transitioning patients back to in-person care or to care from an approved originating site location.
• Adopt a clear communication strategy for staff and patients so they understand the changes coming. This should also include updating patient consents to reflect the policy and coverage changes. 
• Monitor CMS and Congressional action, as additional legislation could extend or make permanent the current telehealth flexibilities.