Medicare telehealth rules are undergoing a significant transition, and 2025 is the year providers must remain vigilant. The temporary flexibilities that have supported patient care since the pandemic will remain in effect through September 30, 2025, with some provisions continuing until December 31, 2025. Starting January 1, 2026, permanent Medicare telehealth policies will take effect, alongside certain delayed requirements.

It is important to note that Medicare telehealth rules may continue to evolve as CMS issues updates, and final decisions are subject to the CY 2026 Physician Fee Schedule (PFS) rulemaking process. Some requirements vary between traditional Medicare and Medicare Advantage, so providers should always confirm with official CMS resources and payer-specific guidelines.

In this blog, we will not only explain the Medicare telehealth rules but also highlight what providers need to know.

Medicare Telehealth Rules

Medicare telehealth rules are moving from temporary flexibilities toward finalized and proposed long-term policies. These updates can be understood across four editorial categories such as:

Current Flexibilities (Through September 30, 2025)

• Coverage and Location Rules

Until September 30, 2025, Medicare beneficiaries may continue receiving telehealth services from their homes. The usual geographic restrictions that limit coverage to rural areas remain waived which means that patients in both rural and urban areas can access telehealth equally. In addition, all eligible Medicare practitioners may serve as distant-site providers during this period. This continuation allows practices to maintain broad access to telehealth while preparing for future adjustments.

• Audio-Only Telehealth Services

Audio-only visits remain permitted when patients cannot use video technology or when they decline video after being offered it. These services are vital for behavioral and mental health visits, where video may not always be necessary or comfortable for the patient. CMS requires that the provider must have the capability to furnish a two-way video service, and the patient’s choice or limitations must be documented in the medical record.

• Role of FQHCs and RHCs

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) may continue to act as distant-site providers for both behavioral/mental healthservices and non-behavioral services through September 30, 2025. This provision has been vital for increasing access to care in underserved and rural areas. However, their distant-site role will be limited to behavioral and mental health care only, not general telehealth visits after September 30, 2025, unless further extended by Congress or CMS.

Delayed Requirements (Effective January 1, 2026)

• Behavioral and Mental Health In-Person Visits

Beginning January 1, 2026, Medicare will reinstate the requirement for patients receiving behavioral or mental health services from home also to have periodic in-person evaluations. Specifically, an initial in-person visit must occur within six months of the first telehealth service, followed by at least one in-person visit every 12 months thereafter. CMS has noted exceptions may apply in cases where the risk of an in-person visit outweighs the benefit, provided that the rationale is documented in the medical record.

• Supervision Policies

The option for virtual direct supervision, where supervising practitioners may oversee services via real-time two-way video instead of being physically present, has been extended through December 31, 2025. CMS will transition supervision rules into their permanent form from January 2026 onward. Though the continuation of virtual supervision is strongly supported, providers must monitor CMS final updates in case modifications are made in the CY 2026 Physician Fee Schedule.

Permanent Rules Already Finalized

• Medicare Telehealth Services List

CMS has permanently expanded the Medicare Telehealth Services List to include many services that proved safe and effective when delivered virtually. These include select evaluation and management (E/M) visits, behavioral and mental health treatments, and certain therapy and counseling services. These services will remain permanently covered under Medicare telehealth regardless of geographic location or patient setting.

• Audio-Only Telehealth Coverage for Behavioral Health

CMS has permanently approved the use of audio-only technology for behavioral and mental health services delivered to patients in their homes. This ensures equity for patients who lack reliable broadband or compatible devices, provided the practitioner can offer video services and the patient declines or is unable to use them.

• FQHCs and RHCs as Distant-Site Providers for Behavioral Health

FQHCs and RHCs have been granted permanent authority to serve as distant-site providers for behavioral and mental health services. This ensures that patients in rural and underserved areas continue to have stable access to essential mental health care via telehealth.

Proposed or Pending Changes (CY 2026 Physician Fee Schedule Rule)

CMS has also proposed several additional changes in the CY 2026 Physician Fee Schedule (PFS). Among the proposals are:

• Expansion of the Medicare Telehealth Services List to include more specialties and service types, building on data from the PHE period.
• Refinements to technology requirements for supervision and service delivery, including clearer rules for virtual presence.
• Payment policy updates that may affect how certain telehealth encounters are reimbursed in the future.

These proposals are not final and remain subject to the formal rulemaking process. Providers should track CMS updates closely in late 2025 when the final CY 2026 PFS rule is released, as it will determine which of these proposals move forward into permanent policy.

What Providers Need to Know

As Medicare telehealth rules change in phases, providers must stay prepared to avoid billing errors, claim denials, and compliance risks. With each deadline approaching, the focus should be on updating processes, training staff, and keeping patients informed.

• Update Billing and Coding Workflows

Billing teams should continue using E/M codes (99202 – 99215) and apply correct modifiers such as 93, 95, and FQ as outlined in the latest CMS MLN guidance. In fact, services may be billed using G2025 for FQHCs and RHCs when applicable.

• Monitor CMS Final Rules and Legislative Updates

The CY2026 PFS proposals provide guidance, but final policies may introduce changes in supervision, covered services, or coding rules. Providers must actively track CMS announcements to remain compliant and financially secure.

• Plan for Financial and Operational Adjustments

Telehealth changes affect revenue, staffing and patient flow. Practices should assess how payment refinements and service restrictions will impact their operations, invest in telehealth technology and allocate resources accordingly.

• Strengthen Documentation Practices

Accurate documentation is key to avoiding audits and claim denials. Providers should ensure visit notes clearly state the location of the patient and provider, modality used (audio-only or video), and compliance with CMS requirements.

• Review Telehealth Technology and Security Standards

Practices should confirm that their telehealth platforms meet HIPAA and CMS security standards. With evolving compliance checks, providers must keep software updated and conduct periodic risk assessments.

• Evaluate Provider and Patient Readiness

Not all patients or clinicians adapt easily to new telehealth requirements. Practices should offer training sessions, quick guides, and technical support to ensure both staff and patients can navigate updated workflows smoothly.

• Coordinate With Payers Beyond Medicare

Commercial insurers and Medicaid programs may not align fully with Medicare’s permanent rules. Providers should verify policies across all payers to avoid confusion and missed revenue opportunities.

Outsourcing Telehealth Billing and Coding Services in India

With Medicare telehealth rules changing in 2025 and 2026, providers will face ongoing updates in coding requirements, billing modifiers, and reimbursement criteria. In fact, managing these changes internally can be overwhelming for in-house teams, especially as deadlines approach and compliance risks increase. The solution of offshore telehealth billing and coding services in India allows providers to deal with these shifts smoothly, as dedicated teams stay updated on every CMS change and apply them correctly to claims in real time.

Beyond simply reducing costs, outsourcing telehealth billing and coding service providers in India delivers strategic advantages that align with Medicare’s evolving telehealth framework. These billing partners combine regulatory expertise with technology-driven workflows to offer 24/7 support for efficiently handling claim submissions, appeals, and compliance audits. Therefore, providers can safeguard revenue, reduce denials, and stay prepared for finalized and upcoming Medicare telehealth policies by partnering with specialists.

FAQs

Q. Will Medicare telehealth rules change for providers working from home?

Ans. Providers must continue to use their enrolled practice location on claims, not their home address.

Q. Can telehealth visits be scheduled outside regular office hours?

Ans. Providers may offer extended-hour telehealth visits if documented and billed correctly.

Q. Do group practices face special requirements for telehealth billing?

Ans. Group practices must ensure supervision and billing compliance just like individual providers.

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