Medicare Telehealth Rules Are Changing—here’s What Providers Need To Know

By Author: infohubconsultancy
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Medicare telehealth regulations are moving through a critical transition phase, and 2025 is a year when providers must stay attentive. The temporary flexibilities that supported patient access during the pandemic will remain available until September 30, 2025, with some extending through December 31, 2025. Starting January 1, 2026, CMS will implement permanent telehealth policies, along with requirements that were previously delayed.
It’s important to note that these rules are still evolving as CMS continues to release updates. The CY 2026 Physician Fee Schedule (PFS) will play a decisive role in shaping final telehealth policies. Since rules sometimes differ between traditional Medicare and Medicare Advantage, providers must verify compliance directly with CMS updates and payer-specific guidance.
In this article, we outline the current flexibilities, upcoming deadlines, and permanent rules, while also discussing how outsourcing billing and coding can support compliance.

Medicare Telehealth Rules: From Temporary Flexibility to Permanent Policy
Medicare telehealth rules are shifting from broad pandemic-era ...
... flexibilities toward long-term standardized policies. These updates can be divided into four categories:
1. Current Flexibilities (Through September 30, 2025)
Coverage and Location
Until late 2025, patients can continue accessing telehealth services from home. Restrictions limiting coverage to rural areas remain suspended, which means beneficiaries in both rural and urban settings have equal access. In addition, all Medicare-eligible practitioners may act as distant-site providers during this period.
Audio-Only Telehealth
Audio-only telehealth is still allowed when video is not feasible or when a patient declines video. This option is especially valuable in behavioral and mental health visits. Providers must have the ability to deliver two-way video if needed, and document the patient’s choice in the record.
Role of FQHCs and RHCs
Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) may continue acting as distant-site providers for both behavioral health and general services through September 30, 2025. After that date, their distant-site status will be limited to behavioral and mental health unless further extended.
2. Delayed Requirements (Effective January 1, 2026)
Behavioral & Mental Health In-Person Visits
Beginning in 2026, patients receiving behavioral health services from home will again require periodic in-person evaluations. CMS will require:
• An initial in-person visit within six months of the first telehealth service.
• At least one in-person visit every 12 months thereafter.
Exceptions may be granted if an in-person visit poses more risk than benefit, but the reason must be clearly documented.
Supervision Policies
Virtual direct supervision, which allows real-time video oversight, will remain available until December 31, 2025. From 2026, CMS will issue updated permanent supervision requirements. Providers should monitor the CY 2026 PFS final rule to confirm the future framework.
3. Permanent Rules Already Finalized
Medicare Telehealth Services List
CMS has permanently expanded its list of approved telehealth services. These include many E/M visits, behavioral health treatments, and certain therapy sessions, which will continue to be covered regardless of patient location.
Audio-Only Behavioral Health Coverage
For behavioral health services, audio-only telehealth has been permanently approved, provided that the clinician has video capabilities and the patient declines or cannot use it.
FQHCs and RHCs for Behavioral Health
Both FQHCs and RHCs have been granted permanent authority to serve as distant-site providers for behavioral and mental health care, ensuring continued access for underserved populations.
4. Proposed or Pending Updates (CY 2026 PFS)
CMS has proposed additional adjustments for the 2026 Physician Fee Schedule, including:
• Expanding the Telehealth Services List further.
• Refining technology requirements for supervision and service delivery.
• Updating reimbursement rules for certain telehealth encounters.
These remain proposals until finalized later in 2025.
Preparing for Telehealth Changes: Provider Action Plan
As Medicare telehealth regulations evolve, providers must prepare now to avoid claim denials, compliance issues, and revenue loss. Key steps include:
• Update Billing & Coding Workflows
Continue using E/M codes (99202–99215) with appropriate modifiers 93, 95, FQ, and G2025 for FQHCs/RHCs.
• Track CMS Updates
Stay current with CY 2026 PFS and legislative changes affecting supervision, covered services, and modifiers.
• Plan Operational Adjustments
Assess staffing, patient flow, and technology investment needs ahead of new reimbursement rules.
• Strengthen Documentation
Clearly record patient/provider locations, modality (video or audio-only), and compliance notes.
• Review Telehealth Platforms
Ensure HIPAA and CMS compliance, including periodic system audits.
• Support Staff & Patients
Offer training and support to ease the transition into updated telehealth workflows.
• Check with Other Payers
Since Medicaid and commercial insurers may follow different rules, verify each payer’s requirements.

Outsourcing Telehealth Billing and Coding Services in India
Managing these evolving policies in-house can strain administrative teams. offshore telehealth billing and coding services in India allows practices to:
• Stay aligned with every CMS update in real time.
• Ensure accurate claim submissions and appeals.
• Reduce denials while improving revenue flow.
• Access 24/7 support and compliance expertise at lower cost.
This approach gives providers a strategic edge by combining cost savings with regulatory accuracy and technology-driven workflows.
FAQs
Q. Do providers working from home use their residential address for billing?
No. Claims must still reflect the provider’s enrolled practice location.
Q. Can telehealth visits take place outside normal office hours?
Yes, as long as they are documented and billed correctly.
Q. Are group practices subject to additional rules?
Group practices must meet the same supervision and billing compliance standards as individual providers.

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