The landscape of telehealth services is rapidly shifting as key regulatory flexibilities introduced during the COVID-19 public health emergency (PHE) begin to expire. Healthcare providers, policymakers, and patients alike need to stay informed about these upcoming changes, as they could significantly impact how virtual care is delivered and reimbursed. Although some extensions temporarily delayed the full return to pre-pandemic restrictions, recent legislative developments signal a return to more stringent rules, raising questions about the future of telehealth accessibility and compliance.
Overview of Expiring Telehealth Flexibilities
On October 1, certain critical telehealth provisions, initially introduced as emergency measures during the PHE, officially lapsed. The Centers for Medicare & Medicaid Services (CMS) had issued various waivers during the pandemic to facilitate expanded access, some of which received extensions through the Full-Year Continuing Appropriations Act, 2025 (CAA). However, legislative efforts to prolong these measures further, including through a stop-gap government funding Continuing Resolution by the House Committee, failed to pass, leading to their expiration.
The flexibilities that ended on October 1, after their temporary extensions, include several significant provisions:
- Definition of “Originating Site”: The CAA had broadened the term to encompass any location within the United States, including a patient’s home. This definition determines where a patient must be located to qualify for telehealth services delivered via telecommunications. The expiration means that the traditional requirement—patients being in designated rural or healthcare facilities—will once again apply, potentially limiting access for some individuals.
- Definition of “Practitioner”: The scope of providers authorized to deliver telehealth services was expanded to include qualified occupational therapists, physical therapists, speech-language pathologists, and audiologists. Before the PHE, only a limited set of practitioners such as physicians, nurse practitioners, and clinical social workers were eligible. The retraction of this expansion could restrict the variety of licensed professionals able to offer telehealth care.
- Rural Health Clinics (RHC) and Federally Qualified Health Centers (FQHCs): The authorization allowing these clinics to provide and be reimbursed for telehealth services has been extended temporarily but is set to revert to previous restrictions, potentially reducing service availability in underserved areas.
- In-Person Visit Requirement for Mental Health Services: The CAA had delayed the mandate for physicians or practitioners to conduct an in-person assessment within six months before initial telehealth mental health services. Its expiration reestablishes the need for such in-person visits, which could complicate access for patients in remote or rural settings.
- Audio-Only Telehealth: The temporary allowance for coverage of services provided solely through audio communication technology will end, likely reducing options for patients with limited internet access or advanced devices.
- Recertification for Hospice Care: The use of telehealth for face-to-face recertification encounters prior to hospice eligibility renewal is also ending, affecting how hospice providers verify patient status.
- Hospital-at-Home Programs: Flexibilities enabling acute care delivery at home under hospital-at-home models are extended for now but face eventual reassessment as regulations tighten.
CMS has started to issue updated guidance reflecting these changes, emphasizing that the statutory restrictions that governed Medicare telehealth services before the pandemic will once again apply starting October 1, 2025. The MLN Booklet on Evaluation and Management Services has been revised to clarify these upcoming restrictions, which will impact many providers and patients.
CMS and The Future of Telehealth Policy
In addition to these regulatory updates, CMS released a special edition MLN Connects Bulletin on October 1, 2025, announcing measures like temporary claims holds for certain legislative payment extenders. These holds, lasting up to ten business days, are designed to prevent payment errors and avoid reprocessing large volumes of claims if Congress acts post-expiration. However, the bulletin was later removed from the CMS website without explanation, leaving some uncertainty about the agency’s future stance.
Without further legislative action, many restrictions that previously limited telehealth to rural areas and required in-person visits will reapply, potentially restricting care access for beneficiaries relying on virtual services. Practitioners providing services outside the scope of Medicare coverage might need to advise patients about possible non-coverage by issuing notices of noncoverage, and should monitor Congressional developments closely. Certain provider categories could also become ineligible for Medicare telehealth reimbursement, which could significantly affect service delivery.
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There remains bipartisan support for extending telehealth flexibilities, but legislative efforts are uncertain, and the timing of any future extensions remains unclear. CMS’s recent rescinding of guidance indicates a cautious approach. Healthcare providers should evaluate their compliance strategies and adapt practices to the evolving regulatory environment, ensuring they are prepared for the reimposition of pre-pandemic restrictions.
Broader Implications for Healthcare
The upcoming regulatory shifts highlight the importance of understanding how telehealth is integrated into overall healthcare delivery. As technology continues to advance, the integration of artificial intelligence (AI) in medical systems is transforming patient care. To explore the current role of AI in mainstream healthcare, visit this resource.
Furthermore, the advantages of incorporating AI into medical practices extend beyond compliance; they can improve diagnostic accuracy, streamline workflows, and enhance patient outcomes. For insights into how AI benefits healthcare systems globally, see this analysis.
In clinical settings, AI tools assist healthcare professionals with decision-making, imaging analysis, and personalized treatment plans, ultimately benefiting both physicians and patients. For more details on AI’s practical applications in clinics, refer to this overview.
As countries worldwide strive for improved health outcomes, understanding which nations lead in healthcare quality remains vital. For a comparative look at global health systems, explore this report.
The evolving telehealth landscape underscores the necessity for healthcare providers to stay informed about regulatory changes while leveraging technological advancements to enhance patient care amid shifting policies.