Additional Contributors
Medicare beneficiaries and healthcare providers received welcome news with the passage of H.R. 7148, the Consolidated Appropriations Act of 2026. Signed on February 3, 2026, the law extends telehealth flexibilities through December 31, 2027. These extensions ensure continuity of care for patients and give providers additional time to prepare until the flexibilities are permanently extended.
This article summarizes the major updates, upcoming changes, and key considerations for clinical, operational, and compliance planning.
What Telehealth Flexibilities Did Medicare Extend Through 2027?
Through December 31, 2027, Medicare patients may continue receiving telehealth services from any location in the United States—including their homes—regardless of rural status or originating site restrictions.
What Changes Take Effect in 2028 for Medicare Telehealth?
A broader range of practitioners may also continue furnishing telehealth; however, beginning January 1, 2028, physical therapists, occupational therapists, speech-language pathologists, and audiologists will no longer be permitted to bill for telehealth services rendered to Medicare beneficiaries.
Also starting January 1, 2028, most patients will once again need to be located in a rural area and at a medical facility to receive telehealth services, except for behavioral health care.
What are the Telehealth Requirements for Behavioral Health Services?
Telehealth from any location (including the patient’s home) continues permanently for behavioral health services, and the use of audio-only technology will continue to be permitted through December 31, 2027. On January 1, 2028, audio-only technology will continue to be permissible for behavioral health when video is not possible or the patient does not consent, and only if the provider has audio–video capability available. These guidelines apply to both new and established patients. Provider documentation specifying these circumstances will be important to include in the telehealth visit note.
Starting January 1, 2028, Medicare will require most beneficiaries to have an in‑person visit within six months before the patient’s first mental health telehealth service and an in-person visit every 12 months thereafter. If the original provider of the telehealth service isn’t available, an in‑person visit can be performed by a different provider in the same group and specialty.
Important exception:
Patients who begin receiving mental health telehealth services on or before December 31, 2027, are considered established and do not need the initial 6‑month in‑person visit. They must only complete the annual in‑person requirement.
How Should RHCs and FQHCs Bill for Medicare Telehealth Services?
For non‑behavioral health telehealth, rural health clinics (RHCs) and federally qualified health centers (FQHCs) may continue billing HCPCS code G2025 through December 31, 2026. A patient’s home (or any location) may serve as both the distant site and the originating site when services are delivered by an RHC or FQHC.
Behavioral health services delivered via telehealth by RHCs or FQHCs continue to be paid under the All-Inclusive Rate and the Prospective Payment System, respectively.
The in-person requirement for home-based behavioral health telehealth does not apply to these facilities until at least January 1, 2028.
What Operational Changes Should Providers Review Now?
Place of Service (POS) codes:
Providers should use POS 02 for telehealth outside the patient’s home and POS 10 for telehealth in the patient’s home. Medicare does not require the use of modifier 95 when reporting services billed with POS 10. Providers are advised to review the policies of individual commercial payers to determine whether modifier 95 is required when billing services with POS 10. As of January 1, 2024, home-based Medicare telehealth is paid at the non‑facility rate. While many commercial payers follow Medicare guidelines for the POS, it is important to confirm the appropriate POS requirements with each payer to ensure accurate claims submissions.
Supervision rules:
Beginning January 1, 2026, Medicare permanently allowed for virtual direct supervision provided via real‑time audio/video for services without a 010 or 090 global surgical indicator for certain services including incident-to services, diagnostic tests, and pulmonary/cardiac rehabilitation, and certain outpatient hospital services.
Frequency limits:
Medicare permanently removed frequency limits for subsequent inpatient visits, nursing facility visits, and critical care consultations furnished via telehealth beginning January 1, 2026.
Provider practice locations:
Practitioners may deliver telehealth from home, and most do not have to list their home address if they also have a physical practice location. Providers whose only practice locations are their homes must list them but can mark them as a telehealth‑only administrative addresses to prevent public display. They may also request that the Centers for Medicare & Medicaid Services (CMS) suppress their street address and/or phone number from public directories.
Newly Added Medicare Telehealth Codes
The following codes have been added to the list of covered telehealth services:
- 90849: Multiple family group psychotherapy
- G0473: Group behavioral counseling
- G0545: Inherent complexity, inpatient/observation visit for confirmed infectious disease by ID specialist
- 92622 & 92623: Auditory osseointegrated sound processor programming
Submitting Requests to Add Telehealth Services
Providers may request that CMS add or modify services on the Medicare Telehealth Services List by submitting documentation no later than February 10 of each year. Requests received by this date will be reviewed and potentially included in the following year’s physician fee schedule (PFS) rulemaking.
- Include all supporting documents you want CMS to consider—such as clinical evidence, rationale, or professional recommendations.
- Understand that anything you submit becomes public because it is part of the federal rulemaking process.
- Visit CMS’s telehealth webpage for instructions on where and how to submit requests, and the current Medicare Telehealth Services List.
Looking Ahead
While it is not possible to confirm, we anticipate further shifts may continue to occur related to permanent legislative measures for telehealth services. By the time an extension or a permanent fix is under review by Congress, the historical cost trending data will include almost seven years. Hopefully, this will allow the Office of Management and Budget (OMB) to project costs with more accuracy, which may result in a permanent change.
Telehealth is effectively becoming a standard component in the healthcare industry, so reversing course is becoming even more unlikely. Providers, however, should review their internal processes related to telehealth on an annual basis to remain compliant. Contact PYA’s experts for assistance in ensuring your processes are compliant, and learn more about our services for telehealth and virtual care providers.
Additional source: www.cms.gov/files/document/telehealth-faq-updated-02-04-2026.pdf
