Telehealth Update: We’re Going to Need Congressional Approval

As we’ve covered again and again over the past five years, providers are once more facing the prospect of a telehealth “cliff” if Congress does not take action to extend the Medicare flexibilities for telehealth services that have been in place since March of 2020. While news is focused on the pending government shutdown, providers and Medicare beneficiaries who have come to rely on the COVID-era waivers and other flexibilities that greatly increased the availability of telehealth are facing the prospect of significantly reduced access to virtual care as of October 1, 2025. Here is a quick review of what telehealth providers and their patients stand to lose if Congress does not act to extend coverage: 

Originating Site/Geographic Limitations: 

• Current Status: Medicare beneficiaries can receive telehealth services from any location, including their home, regardless of where they live.
• Over the Cliff: With limited exceptions, beneficiaries will only be able to receive telehealth services from specific originating sites, such as a provider’s office, a hospital, or skilled nursing facility, and only if they are located in a rural professional health shortage area, in a county not included in a Metropolitan Statistical Area, or within a federal telehealth demonstration project. Although certain beneficiaries, including those with end-stage renal disease, substance use disorder, and certain mental health disorders will be able to receive telehealth at home if certain requirements are met, reinstatement of the pre-pandemic originating site requirements and geographic limitations will greatly limit access to care for the many Medicare beneficiaries facing transportation challenges, limited mobility, and other barriers to in-person care.

Expansion of Eligible Practitioners: 

• Current Status: Physical therapists (PT), occupational therapists (OT), speech therapists (SLP), audiologists, and any other health care provider eligible to bill Medicare can provide telehealth services to Medicare beneficiaries.
• Over the Cliff: The list of eligible providers will be limited to physicians, physician assistants, advanced practice registered nurses, certain behavioral health providers, and registered dietitians or nutrition professionals. PTs, OTs, SLPs, and audiologists, all of whom often play a key role in rehabilitation, and the Medicare beneficiaries who rely on them to maintain independence, will need to adjust their care plans to allow for in-person treatment, which could result in limited access and reduced adherence to these important therapy modalities.

In-Person Requirement for Mental Health:

• Current Status: Mental health providers do not need to see a Medicare beneficiary in person prior to providing behavioral health services via telehealth.
• Over the Cliff: In order for diagnosis, evaluation, or treatment of a behavioral health disorder via telehealth to be covered by Medicare, an in-person visit will be required within six months prior to the initial telehealth visit and every 12 months thereafter, with limited exceptions. This change will impose additional burdens on Medicare beneficiaries seeking treatment for behavioral health treatment, compounding challenges related to stigma and a scarcity of behavioral health providers. 

Coverage of Audio-only Services:

• Current Status: Medicare covers audio-only services that meet the standard of care.
• Over the Cliff: Audio-only services will only be covered if the patient receives services from home and the patient cannot or will not use video. Providers must be technically capable of using audio-video technology and should be sure to document the circumstances surrounding the provision of audio-only services when the above scenarios arise. 

Although there are multiple bipartisan bills proposing to temporarily or permanently extend the telehealth flexibilities, the most likely scenario for avoiding the cliff is another short-term extension in whatever government funding bill Congress (hopefully) passes before the end of month. We will continue to follow this and other telehealth-related developments, but as of this writing, Congress doesn’t have the votes.

Subscribe To Viewpoints