As September comes to a close, many telehealth providers anxiously await news to determine whether key Medicare coverage provisions will be renewed or lapse, leading to a return to pre-pandemic era rules. Should Congress decline to renew these coverage rules, providers can expect to see narrower reimbursement requirements for telehealth services - which can open your practice up to compliance issues, MAC audits, and thousands in potential clawbacks. This article outlines the key changes providers can expect next month and strategies to prepare your practice.

This article is part of a series on Medicare coverage of telehealth services. For more information, check out our article on Medicare’s coverage of telehealth in 2025.

How did we get here?

During the COVID-19 pandemic, Congress recognized the need for relaxing Medicare’s reimbursement requirements for telehealth to allow enrollees the ability to access providers virtually, passing a number of laws aimed at expanding access to health care services. These changes were designed to provide temporary relief by eliminating geographic and “originating site” requirements, relaxing the initial in-person visit requirement, and expanding the providers and types of services covered by Medicare, including audio-only services. These relaxed requirements resulted in an explosion in telehealth usage, and their popularity led Congress to continue to renew these flexibilities long after the pandemic.

Since the end of the pandemic, Congress has continued to renew these flexibilities for a few months at a time. But with the newest sunset date less than a week away, providers are left to wonder whether we will soon see the other side of the telehealth coverage cliff. Without further action from Congress, these flexibilities will expire on October 1, leaving many providers to scramble to adapt to a new normal.

What rules are expected to expire on October 1, 2025?

Should Congress allow these flexibilities to expire, providers can expect a return to Medicare’s pre-pandemic coverage requirements.

1. Return of Geographic/Originating Site and Modality Requirements: Accessing telehealth services may become substantially more burdensome for enrollees living in remote areas. Prior to the pandemic, Medicare enrollees were required to travel to receive care at designated originating sites, including clinics and FQHCs. This will require eligible enrollees to travel to distant sites, eliminating coverage for services rendered at the enrollee’s home. Many Medicare enrollees, particularly those in urban or suburban areas, can expect to lose coverage entirely.
2. Restrictions on Available Providers and Services: The COVID-19 era telehealth flexibilities allowed providers who were previously ineligible to bill for telehealth services - including physical therapists, occupational therapists, and speech pathologists - to see Medicare patients for the first time. The pandemic also saw an expansion of covered services, including nursing home and emergency care. Without congressional action, many providers will lose their eligibility to bill for telehealth or see further restrictions placed on billable services. Further, audio-only telehealth services will no longer be covered, meaning providers will need to ensure that synchronous A/V mediums are used for each visit.
3. Reinstating the In-Person Visit Requirement: Patients can expect to be required to attend a visit with a new provider in-person before any telehealth services will be covered. Providers who treat patients in remote or rural areas will be particularly impacted, and will need to work closely with patients in the transition to these new rules.

How can my practice prepare?

With the sunset date for these flexibilities looming, providers should work quickly to review their internal policies and procedures to ensure a smooth transition in October. A thorough review of billing and coding policies will be key to identify which services can be properly billed. Ensuring all employees are trained on these new rules will be essential to avoid billing errors or irregularities. Providers should also take the time to educate patients on these new changes. Determine which patients stand to be impacted by these changes and work closely with each patient to create a feasible transition plan to ensure continuity of care. This includes informing patients that certain services, including audio-only care, may no longer be available.

Health Law Alliance: Your Trusted Telehealth Experts

Reimbursement requirements for telehealth are constantly changing. At Health Law Alliance, we help providers navigate what can feel like a sea of complicated rules and regulations, particularly with payor audits on the rise. Whether you need help identifying your practice’s risks or developing policies and procedures that help you practice confidently, Health Law Alliance is here to help.