Published November 18, 2025
By Jan Ileto, Policy and Regulatory Affairs Manager
With recent congressional action and evolving CMS guidance, providers may face confusion about what’s currently allowed and what is not.
Please find the specific information you need below to navigate the current complexity.
This table has been updated to account for updates, clarifications, and regulations provided by CMS as well as congressional action.
Timeline of Medicare Telehealth Policy Updates (Fall 2025) Update 11.13.2025
| Date | Source | Summary |
| Oct 15, 2025 | CMS FAQ | Clarified in-person visit exemption for patients established before 9/30/25; distinguished “telecommunications services” from “telehealth” for FQHCs/RHCs. |
| Oct 21, 2025 | MLN Connects | MACs resumed processing behavioral/mental health claims; other telehealth and Hospital at Home claims remained on hold pending further guidance. |
| Oct 31, 2025 | CY 2026 MPFS Final Rule | Extended G2025 proxy billing for FQHCs/RHCs through 12/31/26; in-person rule for mental health services reaffirmed to begin 10/1/25 (now superseded by HR 5371 – see below). |
| Nov 6–7, 2025 | MLN Connects & CMS All Fee-For-Service Providers Webpage Spotlight | CMS returned held claims with denial codes; instructed providers to resubmit eligible claims or hold others pending congressional action. |
| Nov 12, 2025 | H.R. 5371
(Congressional Action) |
Restored Medicare telehealth flexibilities retroactive to Oct 1, 2025 through Jan 30, 2026, including for FQHCs/RHCs. Supersedes prior CMS guidance. |
What to Do Now
- Claims returned earlier? You may now be able to resubmit under the new law.
- Waiting for CMS guidance? Stay tuned — updated implementation guidance is expected soon.
- Billing teams confused? This chart should help sort out what changed and when.
- As always, consult your legal, compliance, and billing teams to determine what approach fits your organization.
| Medical Care Telehealth Coverage Expires | |
| Waiving the location requirements so patient may be located in any geographic location in the US and the home as a permitted site | January 30, 2026 |
| Maintain the expanded list of eligible telehealth providers | January 30, 2026 |
| Authorizes federally qualified health centers (FQHCs) and rural health clinics (RHCs) as eligible telehealth providers | January 30, 2026 |
| Delays the prior in-person visit for mental health requirement | January 30, 2026 |
| Delays the prior in-person visit for mental health requirement when services provided via telecommunications technology for FQHCs and RHC | January 30, 2026 |
| Authorizes audio-only for telehealth services | January 30, 2026 |
| Extends the use of telehealth to conduct a face-to-face encounter for recertification of eligibility for hospice car | January 30, 2026 |
| Extends the Acute Hospital Care at Home Initiative | January 30, 2026 |
What Changed?
Congress extended the telehealth waivers by replacing the old expiration date of September 30, 2025 with January 30, 2026. This change is retroactive, meaning any telehealth visits from October 1, 2025 onward that weren’t covered under permanent telehealth rules are now covered under federal law where there were flexibilities in place for the COVID-19 public health emergency that have been extended repeatedly.
Impact on the 2026 Physician Fee Schedule (PFS)
CMS had planned to require prior in-person visits for mental health services delivered via telehealth by FQHCs and RHCs starting October 1, 2025. Because Congress extended the waivers, that requirement is delayed until January 31, 2026 as federal law overrides CMS regulations, so the waiver extension takes precedence.
What About Other Telehealth Policies?
- The continuing resolution doesn’t change most of the CY 2026 PFS telehealth policies because CMS cannot alter federal law without Congress.
- For non-mental health services provided by FQHCs and RHCs via telehealth:
- These services will again be considered “telehealth visits” until January 30, 2026.
- Billing and payment remain the same (use G2025), as they did during the shutdown.
Bottom Line
The waivers are extended by about 2.5 months (until January 30, 2026), giving providers more time before new requirements take effect.
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