As we look toward 2026 and beyond, it’s clear that telehealth is no longer an emergency workaround — it’s an expected part of care delivery. With pandemic-era flexibilities set to expire, now is the time for healthcare organizations to prepare for what comes next.
What’s Changing:
The Consolidated Appropriations Act of 2023 extended most of the COVID-19 telehealth flexibilities through December 31, 2024, and subsequent legislative updates stretched some provisions through September 30, 2025. These include:
- Removal of geographic and originating site restrictions (for most non–behavioral health services)
- Expanded coverage for audio-only telehealth
- An extended list of eligible provider types
However, one key deadline to watch is January 1, 2026. On this date, in-person visit requirements for mental and behavioral telehealth services delivered by FQHCs and RHCs will return, unless Congress intervenes.
November may also bring key changes for 2026, with the Calendar Year 2026 Medicare Physician Fee Schedule Proposed Rule indicating a possible extension of telehealth services until December 31, 2026 for Rural Health Clinics and Federally Qualified Health Centers. While this proposed rule is currently open for public comment, the Final Rule is expected to be finalized in the first few weeks of November 2025.
What to Do Now:
- Audit your current telehealth mix to understand which services may be at risk.
- Evaluate in-person alternatives for services that may lose coverage.
- Monitor federal updates for legislation that could extend or permanently adopt current flexibilities.
- Train your teams on documentation and billing changes set to take effect post-2025.
Telehealth isn’t going away — but the rules are evolving. Whether you’re a large system or a rural health provider, proactive planning today helps avoid disruption tomorrow.
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