Telehealth Flexibilities End as CMS Transitions Back to Pre-Pandemic Rules

The ability to reach patients where they are is crucial for rural and community hospitals, where access can be an issue. During the pandemic, many of the restrictions on telehealth were lifted to accommodate social distancing.

However, as of October 1, 2025, the Centers for Medicare & Medicaid Services (CMS) has concluded the extended telehealth flexibilities first introduced during the COVID-19 public health emergency (PHE).

What Changed

With the expiration of these temporary provisions, CMS has reinstated most of the pre-pandemic Medicare telehealth requirements. This means:

• Geographic and originating site restrictions once again apply for most non-behavioral and non-mental health telehealth services.
• Only certain types of providers are eligible for reimbursement under Medicare telehealth rules.
• Behavioral and mental health telehealth remain more flexible—patients can continue to receive these services from their homes without location restrictions

What Remains in Place

Some policies from the pandemic era have become permanent or conditionally extended, including:

• Audio-only telehealth for behavioral and certain non-behavioral visits when video isn’t possible.
• Teaching physician participation via virtual presence through the end of 2025.
• Virtual direct supervision allowed through December 31, 2025.
• Continued Medicare coverage for behavioral and mental health services at Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) under their respective reimbursement models.

Remote Patient Monitoring

CMS continues to support remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) as valuable tools for ongoing patient engagement. Providers may continue to:

• Bill for monitoring at least 16 days of patient data per 30-day period.
• Combine RPM with chronic care management services, provided time and effort aren’t counted twice.
• Deliver and document these services under general supervision of the billing practitioner

Claims Hold Notice

Beginning October 1, 2025, the Centers for Medicare & Medicaid Services (CMS) directed all Medicare Administrative Contractors (MACs) to place a temporary hold on claims dated October 1, 2025, or later that involve services affected by the expired Medicare payment provisions under the Full-Year Continuing Appropriations and Extensions Act of 2025.

Due to the ongoing federal government shutdown, CMS will continue processing and issuing payments as usual, except for certain claims related to those expired provisions. No payment delays have occurred so far, as federal law already mandates a minimum 14-day hold on all claims. This current action remains within that statutory timeframe, and providers should continue submitting claims as normal.

What’s Next

Hospitals and clinics should review their telehealth workflows, coding, and billing practices to ensure compliance with the reinstated Medicare requirements. While flexibilities have narrowed, telehealth remains a vital care delivery channel, especially in rural and community hospital settings.

For more information, visit the CMS Medicare Learning Network or contact your MEDHOST Customer Success Executive for support in aligning your clinical and billing systems with current telehealth guidelines.