Telehealth Flexibilities Expire: What Changed on October 1, 2025

Introduction

The telehealth landscape in the United States entered a major turning point on October 1, 2025, as many of the pandemic-era Medicare telehealth flexibilities expired. These flexibilities, first granted during the COVID-19 public health emergency, expanded access to virtual care for millions of Americans and enabled providers to serve patients across geographic and technological boundaries.

Now, with those temporary provisions lapsing, Medicare telehealth rules have largely reverted to pre-COVID standards—but the situation remains fluid, with active congressional discussions about reinstating or extending key waivers.

Here’s a complete guide to what changed, what remains uncertain, and how providers can stay compliant in this new phase of telehealth regulation.

1. Geographic and Originating Site Restrictions Reinstated

As of October 1, 2025, Medicare once again requires that telehealth patients be located in eligible rural or underserved geographic areas at the time of their visit.

The patient’s home no longer automatically qualifies as an approved “originating site” for most non-behavioral telehealth services.
Covered telehealth visits must typically originate from a Medicare-approved facility, such as a physician’s office, hospital, or rural health clinic.

➡️ Impact: Patients in urban and suburban areas may lose access to Medicare-covered telehealth visits unless Congress acts to restore the home-based provisions.

2. Audio-Only Telehealth Narrowed to Behavioral Health

The broad audio-only telehealth allowances (telephone visits) that applied to most services during the pandemic have expired.

As of October 1, only behavioral and mental health telehealth visits can typically be delivered via audio-only communication, and even then, documentation must justify the lack of video capability.
Providers must continue using modifier 93 to designate audio-only encounters.

➡️ Impact: Non-behavioral audio-only visits (e.g., primary care check-ins) are no longer billable to Medicare.

3. Expanded Provider Eligibility Rolled Back

Between 2020 and September 2025, many non-physician practitioners—including physical therapists, occupational therapists, speech-language pathologists, and hospital-based outpatient therapists—were temporarily allowed to bill Medicare for telehealth.

That flexibility expired October 1, 2025.

➡️ Impact: Only core Medicare-recognized practitioners (physicians, NPs, PAs, CNMs, CRNAs, CNSs, clinical psychologists, and clinical social workers) may continue furnishing telehealth.

4. Behavioral Health Requirements Shifted

While behavioral health telehealth remains more flexible than other specialties, a key rule returned October 1:

Patients must have an in-person visit within six months before the first telehealth appointment and periodically thereafter, unless a qualifying exception applies.
Audio-only telehealth remains allowed when clinically appropriate and when patients cannot use video.

➡️ Impact: Mental health and substance-use providers should ensure documentation reflects compliance with in-person visit requirements.

5. Hospital-at-Home Waiver Expired

The Acute Hospital Care at Home (AHCAH) waiver—allowing hospitals to deliver inpatient-level care at home—also ended October 1, 2025.

Hospitals participating in this model had to either discharge home-hospital patients or transition them back to inpatient care unless Congress authorizes a new extension.

➡️ Impact: Health systems that invested in home-hospital programs are now facing operational and reimbursement uncertainty.

6. Medicare Payment and Claims on Hold

Because CMS’s authority to pay for many expanded telehealth services expired alongside the waivers, the agency issued guidance to temporarily hold telehealth claims for services furnished on or after October 1, 2025.

Medicare Administrative Contractors (MACs) are holding claims for approximately 10 business days pending congressional or CMS clarification.
Providers are urged to monitor official CMS communications before resubmitting held claims.

➡️ Impact: Expect short-term payment delays for telehealth visits billed after October 1.

7. What Remains in Place

Not every telehealth policy disappeared. The following remain active or partially protected:

✅ Behavioral and Mental Health Telehealth – Certain flexibilities made permanent by previous legislation continue.
✅ Telehealth for FQHCs and RHCs – These centers may continue billing telehealth visits through early 2026.
✅ POS and Modifier Use – Continue using POS 02 (non-home telehealth) and POS 10 (home telehealth) appropriately.
✅ Audio-Only Modifier 93 – Required for qualifying phone-based services.

8. The Termination Decision: Final or Ongoing?

While many flexibilities technically expired, the termination is not yet fully finalized—and active discussions continue:

Congressional Action Underway: Bills such as the Telehealth Modernization Act (H.R. 5081) propose extending many of the waivers through 2027.
Potential Retroactive Relief: Lawmakers may act to retroactively reinstate certain flexibilities if a budget agreement or healthcare funding bill passes.
CMS in a Holding Pattern: CMS is awaiting congressional direction and may issue further interim guidance to mitigate coverage gaps.

➡️ Bottom Line: The rollback took effect October 1, but the policy landscape remains fluid. Providers should monitor federal updates closely over the coming weeks.

9. Action Steps for Providers

Step	Why It Matters
Verify patient eligibility and originating site status	Avoid denials by confirming compliance with geographic restrictions.
Stay alert for new congressional or CMS updates	Telehealth rules may change again retroactively.
Review payer policies individually	Commercial insurers may maintain broader telehealth coverage.
Educate staff and patients	Communicate which visit types remain covered via telehealth.
Document all telehealth encounters thoroughly	Especially for behavioral health or audio-only cases.

10. Looking Ahead

Telehealth is not going away—but it is entering a new regulatory phase.
The lapse of federal flexibilities highlights the need for permanent telehealth legislation that reflects modern care delivery realities.

Healthcare leaders should continue to:

Engage in advocacy for long-term telehealth reform.
Maintain hybrid models blending virtual and in-person care.
Keep billing and compliance teams updated as policies evolve.

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