For FQHCs, RHCs, and community health centers, the past few months have brought a level of operational uncertainty that feels all too familiar. Many clinics entered the fall already strained by workforce shortages, tighter budgets, increased patient demand, and escalating administrative requirements. Now, the sudden rollback of Medicare telehealth flexibilities has added yet another layer of disruption—one that hits directly at access, reimbursement, and the practical realities of daily workflow. Front-end teams are unsure what can be scheduled, billing teams are monitoring potential returned claims, and clinicians are left trying to maintain continuity for patients who relied on virtual care, especially those with transportation or mobility barriers.
Healthcare practices delivering telehealth services to Medicare beneficiaries have been navigating rapid policy whiplash this fall—and the turbulence isn’t over yet. Since the expiration of key COVID-era waivers on October 1, 2025, organizations have seen returned claims, unexpected denials, and confusing remittance messages. CMS and MACs have implemented temporary claims holds, and CMS has now confirmed that its systems have been unable to accurately identify all payable telehealth claims..
Here’s what happened—and what you need to do next.
The Policy Reset No One Wanted
Congress was widely expected to extend the telehealth flexibilities put in place during the early pandemic. Instead, many of those flexibilities expired on October 1, 2025, reinstating pre-pandemic statutory restrictions. This means:
- Geographic restrictions are back. With the exception of behavioral/mental health services, Medicare patients must generally be located in a rural area or HPSA (Health Professional Shortage Area) to receive covered telehealth.
- Location restrictions are back. Originating site rules again apply. Only designated locations—such as physician offices, hospitals, RHCs/FQHCs, SNFs, community mental health centers, and certain special exceptions—qualify.
- Scope-of-practice limitations have reset. Physical therapists, occupational therapists, speech-language pathologists, and several other practitioner types are no longer eligible Medicare telehealth providers.
Behavioral and mental health telehealth remains largely protected, including the use of audio-only technology. For most provider types, an in-person visit is required every six months after the initial telehealth service. For FQHCs and RHCs, this in-person requirement for behavioral health is delayed until January 1, 2026, providing a short transition window.
Important nuance for FQHCs and RHCs: Non-behavioral telehealth services billed via G2025 can continue through December 31, 2025. After that, statutory restrictions will fully apply unless extended by new legislation.
Claims Holds, Releases, and Returned Claims
At the start of the shutdown in October, CMS directed MACs to temporarily hold certain claims while awaiting potential legislative action. Once no extension occurred, claims holds continued for some service types. CMS has acknowledged that MAC systems cannot reliably distinguish allowable versus non-allowable telehealth claims under the reinstated rules. As a result, practitioners may see:
- CARC 16 – Missing/incomplete information
- RARC M77 – Invalid place of service
CMS advises that providers who choose to resubmit must:
- Confirm compliance with Section 1834(m) of the Social Security Act
- Append modifier GY to indicate statutory exclusion
- Issue an Advance Beneficiary Notice of Noncoverage (ABN)
Claims billed with modifier GY will be denied—but may then be appealed.
Practical Next Steps for Practices
- Review all Medicare telehealth workflows against the reinstated geographic, originating site, and practitioner requirements.
- Obtain ABNs for any telehealth services that no longer meet Medicare coverage criteria.
- Consider holding non-behavioral telehealth claims until CMS issues additional instructions.
- Reinforce front-end screening for patient location, eligibility, and required documentation.
Protect your revenue and workflow before denied claims pile up.
BCA, Inc. can help assess your telehealth processes, identify compliance gaps, and optimize billing workflows so your clinic stays on track.
Book a consultation or explore a telehealth claims audit today for actionable guidance.