Congress has officially extended major Medicare telehealth flexibilities through January 1, 2026, reversing the sudden policy changes that took effect on October 1, 2025. This new extension preserves many of the pandemic-era virtual care rules—allowing providers to continue offering telehealth services without the geographic, originating-site, and audio-only limitations that were previously set to return.
If you’re a provider, billing specialist, or healthcare organization, here is the fully updated 2025–2026 telehealth compliance guide reflecting the latest federal action.
1. Medicare Geographic & Originating Site Flexibilities Extended
One of the most impactful updates:
Medicare patients can continue receiving telehealth services from home in any location through January 2026.
Key points for compliance:
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No rural-only restrictions
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The patient’s home remains an approved originating site
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Urban and suburban beneficiaries keep full telehealth access
2. Audio-Only Telehealth Services Remain Covered (Modifier 93 Required)
Congress extended broad audio-only telehealth coverage, ensuring uninterrupted access.
Providers can continue billing:
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Audio-only E/M visits
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Behavioral and mental health audio-only services
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Other approved phone-based telehealth services
Remember to append modifier 93 on all qualifying audio-only claims.
3. Expanded List of Eligible Telehealth Practitioners Restored
The extension reinstates the full outpatient and rehabilitative provider list, allowing the following to bill Medicare telehealth:
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Physical therapists
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Occupational therapists
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Speech-language pathologists
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Audiologists
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Outpatient therapy providers
4. Behavioral Health Telehealth Flexibilities Continue Unchanged
Behavioral health continues to receive the strongest telehealth protections.
The extension maintains:
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No 6-month in-person evaluation requirement
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No ongoing periodic in-person visits
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Audio-only allowed when clinically appropriate
5. Hospital-at-Home Program Extended Through January 2026
The Acute Hospital Care at Home (AHCAH) waiver is also extended—avoiding program disruption.
Hospitals may continue:
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Delivering inpatient-level care in the home
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Billing under existing AHCAH requirements
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Keeping patients safely in the home setting
6. Medicare Telehealth Claim Holds Lifted
CMS previously instructed MACs to hold telehealth claims after October 1, 2025. With the extension:
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Claims from October 1 forward will be released and paid
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No resubmission needed unless directed by the MAC
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Continue using POS 02, POS 10, and required modifiers
7. Telehealth Policies That Were Already Protected
Several rules remain active regardless of the new extension:
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Telehealth billing for FQHCs and RHCs
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Audio-only behavioral health coverage
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Permanent coverage for specific mental health telehealth services
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Virtual incident-to supervision (when applicable)
8. What the Extension Does Not Do
The extension is temporary and does not:
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Make Medicare telehealth policies permanent
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Set rules for 2026 and beyond
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Guarantee that current flexibilities will remain after January 1, 2026
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Prevent CMS from issuing further updates
9. Action Steps for Providers (2025–2026)
Your updated compliance checklist:
✔ Continue telehealth operations under pre-October 1 workflows
No changes needed in scheduling, documentation, or technology.
✔ Update billing and coding teams immediately
Reinforce POS, modifier, and documentation requirements.
✔ Monitor CMS and MAC communications
Expect sub-regulatory updates tied to the extension.
✔ Notify patients of restored telehealth flexibility
Particularly those previously informed of changes in October.
✔ Prepare for another policy deadline in early 2026
Consider internal contingency plans for potential post-2026 rule shifts.
10. Outlook: Will Telehealth Become Permanent?
Congress continues to debate longer-term telehealth legislation—some proposals extend flexibilities to 2027, while others seek permanent reform.
The January 2026 extension shows strong bipartisan support, but permanent Medicare telehealth policy is still pending.
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