Medicare Telehealth Flexibilities Restored and Extended Through January 30, 2026

The proposed CR extends Medicare telehealth flexibilities (Sec. 6208), which were previously extended by the Consolidated Appropriations Act of 2023, through January 30, 2026. These flexibilities include the following: 

• Medicare beneficiaries to continue to receive telehealth services at any site, regardless of type or location, including the beneficiary’s home (i.e., lifting geographic restrictions and maintaining an expanded list of originating sites to include patients’ homes); 

• Audio-only non-behavioral telehealth visits allowed for certain non-behavioral services when appropriate 

• Expanded provider eligibility for general telehealth (i.e., occupational therapists, physical therapists, speech-language pathologists, and audiologists) 

• Federally Qualified Health Centers and Rural Health Centers as distant-site providers 

• Delayed in-person visit requirements for behavioral telehealth visits 

Retroactive Payments: 

• Any telehealth claims that were put on hold since the lapse in funding will now be paid retroactively, starting from October 1, 2025.  

• Additionally, claims that were previously paid at a lower rate because the geographic adjustments had expired may also be reprocessed and corrected once CMS issues instructions. 

• CMS is expected to release detailed guidance for submission or adjustment of claims. 

Next Steps for Your Practice and Revenue Cycle  

• Ensure your team knows that the Telehealth rules have reverted to the pre-October 1 guidelines and are extended to January 30, 2026. 

• Update scheduling and clinical teams that Medicare telehealth from the patient’s home allowed. 

• Update patient messaging letting them know telehealth is available until the end of the extension. 

• Compile a list of all traditional Medicare telehealth encounters provided between October 1, 2025 through November 13, 2025. 

• Determine if these claims were denied due to telehealth policy changes, or paid at lower amount due to geographic/originating site restrictions. 

• Monitor your Medicare Administrative Contractor (MAC) for specific instructions on to adjust, resubmit, or allow the MAC to auto-reprocess impacted claims.  

Ensure documentation meets Medicare Telehealth Requirements

Telehealth visits must meet the same documentation standards as required prior to October 1, 2025. These include, 

• Location of patient and provider, 

• Documentation of technology used (audio-only or audio/video), 

• Time or MDM details for E/M level of complexity 

• Notation of patient consent for telehealth. 

Prepare for the Next Telehealth Cliff 

For clinicians, this proposed short extension may provide some reprieve. However, the brevity of the extension means that clinicians, patients, and telehealth stakeholders would once more be in an uncertain position as the new year begins. Essentially, if the proposed CR passes the House in its current form, the U.S. will face another telehealth cliff on January 30, 2026. Telehealth advocates are already pushing for permanence through a handful of proposed legislation. If enacted, this stopgap measure would avert further disruptions but place renewed pressure on Congress to pass long-term telehealth legislation such as the CONNECT for Health Act or the Telehealth Modernization Act in early 2026.