For years, Medicare telehealth rules have been defined by the temporary flexibilities established during the COVID-19 Public Health Emergency (PHE). These rules have allowed providers to care for patients in their homes, use audio-only phone calls, and bypass strict geographic limits.
However, this era is coming to a definitive close. Key Medicare telehealth flexibilities for non-behavioral/mental health services were set to expire on September 30, 2025, and have been impacted by the government shutdown.
While legislation like the CONNECT for Health Act of 2025 and the Telehealth Modernization Act has been introduced to make some changes permanent, no significant law has been passed and new legislation is on hold. This means practices must prepare for a return to pre-pandemic restrictions. Here is the latest update from CMS at the time of this post:
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. Additionally, Medicare would not be able to pay some kinds of practitioners for telehealth services. For further information visit: https://www.cms.gov/medicare/coverage/telehealth.
Key Changes Effective October 1, 2025
The expiration of these flexibilities will reintroduce several critical statutory restrictions. The table below outlines what is changing.
| Telehealth Feature | Through Sept 30, 2025 | Starting Oct 1, 2025 |
|---|---|---|
| Patient Location (Originating Site) | Any location in the U.S., including the patient’s home. | Patient must be in a qualified healthcare facility (e.g., rural clinic, hospital) located in a rural geographic area. |
| Audio-Only Services | Permitted for a variety of services, enabling care for patients without video capability. | Largely restricted. Originating sites are expected to have two-way, real-time audio/video capabilities for most services. |
| Provider Licensure | Temporarily waived in some cases; providers could often practice across state lines. | Providers must be licensed in the state where the patient is physically located at the time of service. |
Let’s break down what each of these changes means for your practice.
1. The Return of Originating Site and Geographic Restrictions
The most significant change is the reinstatement of “Originating Site” rules. During the PHE, a patient’s home was considered a valid location for a telehealth visit. After the deadline, this will no longer be the case for most services.
What’s Ending: The ability for a Medicare patient to have a covered telehealth appointment from their own home, regardless of whether they live in a city or rural area.
What’s Returning: The patient must travel to a qualified medical facility (like a rural health clinic or hospital) that is also located in a defined rural Health Professional Shortage Area (HPSA). This will drastically reduce the number of Medicare patients eligible for telehealth.
2. The Loss of Audio-Only Flexibility
Audio-only services have been a lifeline for elderly or low-income patients who lack access to or are uncomfortable with video technology. This flexibility will be severely limited.
What’s Ending: The ability to bill for many non-behavioral health services performed using a standard telephone.
What’s Returning: The expectation that telehealth services will be conducted using interactive, real-time audio and video equipment. This could create significant barriers to care for vulnerable patient populations.
3. Tightening of State Licensure Requirements
The flexibility that allowed providers to see patients across state lines without holding a license in that state is tied to the PHE and will expire.
What’s Ending: Any federal waivers that permitted cross-state practice without a license.
What’s Returning: The strict requirement that a provider must hold an active license in the state where the patient is physically located. Providers must verify their licensure for each telehealth encounter with an out-of-state patient.
What Your Practice Should Do Now
Waiting until September 2025 to plan will create operational chaos. We recommend taking these proactive steps:
Conduct a Patient Impact Analysis: Identify how many of your current Medicare telehealth patients are located in urban areas or their own homes. This will show you the potential volume of services at risk.
Audit Your Telehealth Services: Review your billing from the last 6 months to determine what percentage of your telehealth visits are audio-only. Begin planning for how to transition these patients to video platforms or in-person care.
Verify Provider Licensure: If you have been providing cross-state telehealth, immediately verify that all your providers hold the necessary state licenses. Consider applying for interstate licensure compacts if needed.
Stay Informed: Advocate for permanent telehealth reform, but base your operational plans on the current law. We will continue to monitor legislative activity and provide updates.
The Bottom Line
The “telehealth cliff” is not a speculative future event—it is a scheduled policy change with real-world consequences for patient access and practice revenue. By understanding these reverting restrictions and beginning your transition planning now, you can ensure your practice remains compliant and continues to provide seamless care to your patients.
Need help preparing? The team at Compass Healthcare Consulting is here to help you navigate this transition. We can conduct a telehealth workflow audit, assess your patient population’s risk, and develop a strategic plan to keep your practice ahead of these changes. Contact us today for a consultation.
Helpful Resources:
