Telehealth policy continues to evolve at both the federal and state levels, and providers across Virginia should expect continued movement in reimbursement and compliance requirements.
In the Commonwealth, we are closely monitoring telehealth-related legislation moving through the 2026 session of the Virginia General Assembly (read our full legislative update here). In addition to state-level proposals, there have been significant federal and Medicaid updates that directly impact billing, supervision, documentation, and virtual service delivery.
Below is a high-level summary of what providers need to know.
Medicare Telehealth Flexibilities Extended Two Years
After a brief partial government shutdown, Congress passed a $1.2 trillion federal funding bill that extends many Medicare telehealth flexibilities through December 31, 2027. The bill was signed into law, averting disruption to federal operations and preventing another abrupt expiration of pandemic-era telehealth policies.
What this means for providers:
- Medicare telehealth flexibilities remain in place for nearly two more years.
- The Acute Hospital Care at Home waiver program has been extended through September 30, 2030.
- Providers can continue offering covered virtual services without immediate concern for sudden reimbursement rollbacks.
While this update provides stability for two more years, it is important to note that this is another temporary extension.
There is growing bipartisan support in Congress for telehealth, and policymakers are expected to pursue stand-alone telehealth legislation rather than continuing to tie these flexibilities to short-term government funding packages.
Virginia Medicaid: DMAS Telehealth Updates and Billing Clarifications
At the state level, the Virginia Department of Medical Assistance Services (DMAS) issued multiple bulletins in late 2025 clarifying telehealth coverage, remote patient monitoring (RPM), and Applied Behavior Analysis (ABA) service requirements.
Here are the key takeaways.
- Remote Patient Monitoring (RPM) Expansion and Clarification
DMAS clarified coverage for remote patient monitoring services, including:
- Expanded RPM use for high-risk pregnant patients, including those with maternal diabetes or hypertension (in alignment with 2025 Acts of Assembly requirements).
- Clarified RPM eligibility for patients with chronic or acute health conditions.
- Updated reimbursable services tables to reflect additional covered codes.
For providers, this signals continued support for remote monitoring as a tool to improve outcomes for high-risk populations. However, documentation and clinical justification remain critical for reimbursement.
To expand RPM for all pregnant and postpartum individuals, HB425, sponsored by Del. Destiny, is currently in committee in the 2026 Virginia General Assembly. The bill expands Medicaid reimbursement for remote patient monitoring services provided via telemedicine to include all pregnant and postpartum individuals. Under current law, coverage is limited to high-risk pregnancies.
- Telemedicine Provider Enrollment Clarifications
DMAS also clarified provider enrollment requirements:
- Licensed health care providers who deliver services exclusively through telemedicine are not required to maintain a physical presence in Virginia to enroll as a Medicaid provider as long as they stay within state licensing laws and regulations.
- Provider groups rendering telemedicine services are not required to maintain an in-state service address to enroll as a Virginia Medicaid vendor or provider group.
This clarification reduces administrative barriers and supports virtual-first practice models serving Virginia Medicaid members.
- Audio-Only and Audio-Video Billing Updates
DMAS updated its telehealth service tables to reflect additional covered codes for:
- Synchronous audio-video visits
- Audio-only visits
- Virtual check-ins
- Remote patient monitoring
Importantly, certain synchronous telehealth codes no longer require modifier 93, reflecting modernization of billing requirements. Providers should review the updated Telehealth Services Supplement and reimbursable services tables to ensure compliance with coding and modifier requirements.
- Applied Behavior Analysis (ABA): Compliance Reinforcement and Telemedicine Requirements
In December 2025, DMAS issued an additional bulletin reinforcing compliance expectations for Medicaid-reimbursed Applied Behavior Analysis (ABA) services, including when delivered via telemedicine. Key compliance themes:
- Initial ABA assessments must be conducted in person by an LBA, LABA, or qualified LMHP; incomplete or non-compliant assessments are not reimbursable.
- Telemedicine-delivered ABA requires clear documentation of clinical appropriateness, including when services will be virtual vs. in-person and how in-person needs will be addressed.
- Only LBAs, LABAs, and Licensed Clinical Psychologists may delegate and supervise non-licensed staff delivering ABA; other LMHPs do not have delegation authority.
- Services provided outside approved scope-of-practice rules or service authorization requirements are subject to payment retraction.
- Clinic- or center-based ABA services must include documented medical necessity in the ISP, along with required family involvement and training.
The bulletin signals increased scrutiny around service authorization, documentation, supervision, and program integrity, particularly for services exceeding 20 hours per week or delivered through telemedicine.
Providers should review policies carefully to mitigate audit and recoupment risk.
Looking Ahead
Telehealth remains a central component of care delivery in Virginia and nationwide. While the extension of Medicare flexibilities through 2027 provides short-term stability, long-term certainty will depend on permanent federal action. At the same time, DMAS clarifications underscore the importance of documentation, scope of practice adherence, and program integrity. There are also several pieces of legislation in the Virginia General Assembly supporting access to care via telehealth across the Commonwealth.
We encourage providers to stay engaged and review the full Medicare and DMAS bulletins linked above for detailed guidance.