Medicare Telehealth Update

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With the government reopening, the Centers for Medicare & Medicaid Services (CMS) has released updated guidance on telehealth coverage. Telehealth providers are being directed to submit any claims held during the shutdown and continue submitting claims as usual through January 30, 2026. This means most traditional Medicare telemedicine coverage has been extended until that date.

Unless Congress takes further action, these pandemic-era flexibilities are set to expire on January 30, 2026. Please review the official document we’ve included for more details. We will keep you updated as Medicare policies continue to evolve.

Telehealth FAQ Calendar Year 2026 Updated 11/14/25

Q1: Do Medicare beneficiaries need to be located in a rural area and in a medical facility in
order to receive Medicare telehealth services?
A1: Through January 30, 2026, beneficiaries can receive Medicare telehealth services anywhere
in the United States and territories. Starting January 31, 2026, except for behavioral health
services, beneficiaries will generally need to be in a medical facility and in a rural area to receive
Medicare telehealth services.

Q2: Are there any restrictions on the types of practitioners who can furnish Medicare telehealth
services?
A2: Through January 30, 2026, an extended range of practitioners may bill for Medicare
telehealth services. Starting January 31, 2026, physical therapists, occupational therapists,
speech-language pathologists, and audiologists can no longer furnish Medicare Telehealth
services.

Q3: Can outpatient therapy, diabetes self-management training and medical nutrition therapy
services be furnished remotely by hospital staff to beneficiaries in their homes?
A3: CMS is continuing to align payment policies for outpatient therapy services, diabetes self-
management training and medical nutrition therapy services furnished remotely by hospital staff
to beneficiaries with policies for Medicare telehealth services. Therefore, through January 30,
2026, hospitals may bill for these services. Starting January 31, 2026, hospitals may no longer
bill for these services when furnished remotely by hospital staff to beneficiaries in their homes.

Q4: How does CMS make payment for telehealth services furnished in RHCs and FQHCs? Can
Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) continue to serve
as distant sites for the provision of telehealth services?
A4: Any behavioral health service furnished by an RHC or FQHC on or after January 1, 2022
through telecommunications technology is paid under the All Inclusive Rate (AIR) and
Prospective Payment System (PPS), respectively. Through December 31, 2026, RHCs and
FQHCs may continue to bill for non-behavioral health services furnished through
telecommunications technology by reporting HCPCS code G2025 on the claim. The home may
continue to serve as a distant site for beneficiaries receiving telecommunications services
furnished by RHCs and FQHCs.

Q5: Will in-person visit requirements apply to behavioral health services furnished by
professionals through Medicare telehealth? What about behavioral health services furnished
remotely by hospital staff to beneficiaries in their homes, or behavioral health visits furnished by
RHCs, and FQHCs where the patient is present virtually?
A5: Section 1834(m) of the Act requires an in-person, non-telehealth visit within 6 months prior
to the first mental health telehealth service, effective after January 30, 2026. As was finalized in
the CY 2022 PFS, payment for behavioral health services furnished through certain
telecommunications technology while the patient is at home may be made only if the physician
or practitioner has furnished an item or service in-person to the patient, without the use of
telehealth, for which Medicare payment was made (or would have been made if the patient were
entitled to, or enrolled for, Medicare benefits at the time the item or service is furnished) within 6
months prior to the initial telehealth service. After the first mental health telehealth service in the
patient’s home, there must be an in-person, non-telehealth service within 12 months of each
mental health telehealth service—but to allow for limited exceptions to the requirement. These
in-person visits may be performed by a physician or practitioner of the same specialty within the
same group practice as the physician or practitioner who furnishes the telehealth service, if the
physician or practitioner who furnishes the telehealth service is not available. While section
1834(m) of the Act requires an in-person, non-telehealth visit within 6 months prior to the first
mental health telehealth service, we do not believe this requirement applies to beneficiaries who
began receiving mental health telehealth services in their homes prior to January 31, 2026. In
other words, if a beneficiary began receiving mental health services on or before January 30,
2026, then they would not be required to have an in-person visit within 6 months; rather, they
will be considered established and will instead be required to have at least one in-person visit
every 12 months. Regarding behavioral health services furnished remotely by hospital staff to
beneficiaries in their homes, we are continuing to align our policy with requirements for
Medicare telehealth services billed under the PFS. For behavioral health visits furnished by
RHCs and FQHCs where the patient is present virtually, in-person visit requirements will
continue to not apply until at least until January 31, 2026.

Q6: Can beneficiaries continue to receive audio-only telehealth services? Are audio-only
telehealth services permitted in all originating sites?
A6: Under current law, beneficiaries may continue to receive audio-only telehealth services in
their homes through January 30, 2026. Starting January 31, 2026, physicians and practitioners
may use two-way, real-time audio-only communication technology for behavioral health services
furnished to a patient in their home, provided that the furnishing physician or practitioner is
technically capable of using audio-video communication technology and that the beneficiary is
not capable of or does not consent to using audio-video communication technology. Audio-onlycan be used for both new and established patients. Beneficiaries who are receiving remote mental
health services, as defined in the CY 2023 and 2024 OPPS Final Rules, furnished by hospital-
employed staff in their homes may also receive these services via audio-only communication
technology.

Q7: What are the current guidelines for virtual presence for teaching physicians who furnish
telehealth services involving residents?
A7: In the CY 2026 PFS final rule, we established that beginning January 1, 2026, we are
continuing to allow teaching physicians to have a virtual presence in all teaching settings, but
only for services furnished as a Medicare telehealth service. This will continue to permit teaching
physicians to have a virtual presence during the key portion of the Medicare telehealth service
for which payment is sought, through audio/video real-time communications technology, for all
residency training locations.