Virginia Telehealth Network

November 2025 Updates to Medicare Telehealth Policy

Recently, legislative and regulatory changes brought updates to Medicare telehealth policy, including a short-term government funding deal extending key telehealth flexibilities and lasting adjustments released in the 2026 Medicare Physician Fee Schedule (PFS) final rule.

Shutdown Deal Extends Temporary Telehealth Flexibilities

As part of the agreement that ended the government shutdown, Congress approved and the President signed a continuing resolution, which extends key telehealth flexibilities through January 30, 2026, according to Telehealth.org.

The extended flexibilities include:

  • Waiving the location requirements (geographic and type of site)
  • Expanded list of eligible telehealth providers
  • Allowing federally qualified health centers (FQHCs) and rural health clinics (RHCs) to be eligible telehealth providers
  • Delaying the prior in-person visit for mental health when certain permanent telehealth policy requirements are not met
  • Delaying the prior in-person visit for mental health provided via telecommunications technology for FQHCs and RHCs Allowing of audio-only for telehealth services
  • Extending the use of telehealth to conduct a face-to-face encounter for recertification of eligibility for hospice care
  • Extending the Acute Hospital Care at Home Initiative

The reinstated telehealth waivers apply retroactively to September 30, 2025, making previously uncovered telehealth visits during the shutdown eligible for payment – except for mental health services, which already were covered during the waiver lapse period. Because Center for Medicaid & Medicare Services (CMS) returned claims submitted between October 1 and November 10 that weren’t clearly identified as mental health, providers can resubmit those claims, as well as any they previously held, for reimbursement.

This short extension brings temporary stability, but it only delays the next “telehealth cliff” to January 30, 2026.

“While we are encouraged by this extension, lawmakers must deliver a long-term, stable telehealth policy that gives patients, providers and health systems the certainty they deserve,” Chris Adamec, executive director of the Alliance for Connected Care, told Healthcare IT News. “Short-term, and even year-to-year, extensions are no longer sustainable for a care model that is now central to how America delivers healthcare.”

Telehealth Updates in the 2026 Physician Fee Schedule

On October 31, CMS released the 2026 Physician Fee Schedule (PFS) final rule, outlining several key changes impacting telehealth services. The newly released PFS brings a mix of expanded flexibility and some barriers for providers.

Updates for FQHCs and RHCs

Under the 2026 PFS final rule, CMS had required FQHCs and RHCs to have a prior in-person visit before providing mental health services via telehealth starting October 1, 2025. However, the continuing resolution extending telehealth waivers through January 30, 2026, delays this requirement as federal law takes precedence over the CMS rule.

For non-mental health services delivered by FQHCs and RHCs via telehealth, the new waiver timeline simply means these services again will be considered “telehealth visits” after January 30, but reimbursement and billing remain unchanged, as they continued to use G2025 at the same rate even during the shutdown.

Telehealth Expansions

The final rule also brings telehealth expansions in facility-based care. CMS has eliminated frequency limits on telehealth in hospitals and skilled nursing facilities (SNFs) and will now allow virtual direct supervision where required. Additionally, CMS finalized a permanent policy allowing the “direct supervision” requirement to be met through real-time, two-way audio-video technology. This allows supervising practitioners to be virtually present rather than physically on-site for many services. It is important to note that audio-only communication does not meet this standard.

CMS also confirmed that services like Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) are inherently non-face-to-face and are not subject to Medicare’s telehealth regulations and finalized the addition of several new codes to the Medicare Telehealth Services List for 2026. These include:

HCPCS 90849: Multiple-family group psychotherapy

HCPCS G0473: Group behavioral counseling (for 2-10 people)

HCPCS G0545: Inherent visit to an inpatient

HCPCS 92622 & 92623: Diagnostic analysis, programming, and verification of an auditory osseointegrated sound processor

Navigating the Changes

While the short-term extension of telehealth flexibilities provides breathing room, the telehealth policy landscape remains in flux. Providers should continue to monitor claims processing closely. As the January 30, 2026, deadline approaches, further action from Congress will be needed to secure the long-term stability of telehealth services for Medicare beneficiaries.

For more information about the 2026 Physician Fee Schedule, view the final ruling here or view the fact sheet prepared by the Center for Connected Health Policy. For updates on pending legislation, visit the Center for Connected Health Policy website.