Updated: 10/3/2025. For the most recent information about the telehealth cliff and how to prepare, visit the Telehealth Resource Center.
At the onset of the COVID-19 pandemic, Congress and federal agencies moved quickly to relax restrictions on telehealth. Providers were allowed to see patients across state lines, prescribe medications via telehealth, and bill Medicare and Medicaid at parity with in-person visits. These flexibilities removed long-standing barriers and allowed millions of patients to continue accessing care safely.
Since those policy changes, telehealth has expanded access, particularly for rural and underserved patients, making care more convenient and reducing barriers like travel, transportation, and caregiving needs. In South Dakota, physicians and health systems report significant benefits: Sanford Health, for example, now provides virtual care in 78 specialties, has saved patients millions of miles in travel. And VTN has seen first-hand how telehealth has helped to expand care for young students, older adults, and those in need of mental health services across Virginia’s rural communities.
Since 2020, Congress has repeatedly extended telehealth flexibilities, but as of September 30, 2025, many of those extensions have expired, bringing the industry to what many call the “telehealth cliff”—the potential loss of these flexibilities unless lawmakers act.
What the Telehealth Cliff Means for Providers
Providers should be aware that:
- In most cases, providers will no longer be reimbursed for telehealth visits delivered to Medicare beneficiaries in their homes. Pre-pandemic rural and facility restrictions would return.
- Audio-only telehealth may no longer qualify for reimbursement in most cases.
- The Hospital-at-Home model that allows patients to receive acute care at home will be disrupted. CMS has released guidance specifically stating, “For all hospitals with active AHCAH waivers, all inpatients must be discharged or returned to the hospital on September 30, 2025.”
- Occupational therapists, physical therapists, speech-language pathologists, and audiologists will lose telehealth eligibility.
The American Physical Therapy Association joined more than 350 providers and patient groups in urging Congress to extend telehealth waivers, noting that “telehealth services have proven to be an effective option, especially for rural and underserved communities.”
Additional flexibilities set to expire in December 2025:
- FQHCs and RHCs lose their status as eligible distant site telehealth providers for medical visits
- Virtual supervision & direct supervision via telehealth (clinical supervision, residents, rehab services, etc.) will require in-person presence again for many services.
- Flexibilities for remote prescribing of controlled substances, but waivers that end sooner may impact the telehealth-based care for providers prescribing controlled substances.
In short, without action, telehealth access will decline, leading to challenges for both patients and providers.
“The good news: there was no opposition in the House to the bill/continuing resolution that included these waivers, so bipartisan support remains strong. Most are confident the flexibilities will be restored once Congress reaches a budget deal—hopefully sooner rather than later, and not as drawn out as the last shutdown,” Kathy Wibberly, PhD, Director of the Mid-Atlantic Telehealth Resource Center shared in a recent post.
How Providers Can Prepare
While much remains uncertain, there are several steps providers can take to soften the impact of the telehealth cliff:
- Evaluate telehealth utilization. Look at how many of your patients rely on telehealth, what services they use, and which payer types are involved. This helps gauge the scale of impact.
- Audit technology platforms. Ensure your telehealth systems are HIPAA-compliant and ready to meet stricter security standards if temporary waivers end.
- Clarify licensure requirements. If you’ve been seeing patients across state lines, confirm where you may need additional licenses or participate in the Interstate Medical Licensure Compact.
- Revisit prescribing policies. Align your workflows with DEA rules for remote prescribing of controlled substances and identify when in-person visits will be required.
- Educate staff and patients early. Communicate possible changes clearly and proactively by notifying patients, preparing providers and schedulers, and sharing updates across multiple channels.
- Prepare and provide alternative care options for patients who can’t attend in person, such as eligible originating sites or partner locations that can serve as telehealth access points. Use the Medicare Telehealth Payment Eligibility Analyzer to confirm which sites qualify for reimbursement.
- Budget for shifts in reimbursement. Plan for the financial impact if telehealth visits are no longer reimbursed at the same rate as in-person visits.
- Explore hybrid care models. Consider how to balance in-person and virtual care to preserve access while adapting to new regulations.
The key is to stay proactive and communicate with patients and staff to minimize disruptions.
Legislative Action and What’s Ahead
Several bills are still under consideration in Congress to extend or make permanent telehealth flexibilities. Proposed legislation like the Telehealth Coverage Act and CONNECT for Health Act of 2025 would safeguard Medicare coverage for a range of services, preserve audio-only options, and extend cross-state access. As of now, these measures are still pending, leaving providers and patients in limbo.
Providers are preparing as best they can, but without legislative certainty, the future remains unclear. Lawmakers must act soon to preserve key telehealth policies – not just as a temporary fix, but as a permanent foundation for modern, equitable health care.
For the latest updates on all active bills, visit the Center for Connected Health Policy’s Pending Legislation Tracker.
Additional Resources:
- Virginia Medicaid Announces Telehealth Flexibility Continues (10/3/25)
- The Telehealth Policy Cliff: Preparing for October 1, 2025 (MATRC)
- Medicare and Mental Health Coverage, a guide on telemental health in-person requirements now in effect (CMS)