As of October 1, 2025, Medicare telehealth services have reverted to permanent statutory law following the expiration of the temporary waivers first established during the COVID-19 pandemic. Until the shutdown ends, Medicare’s telehealth coverage is again limited to patients located in rural areas and those receiving services in approved medical facilities rather than from home, except in certain limited situations. We highly recommend providers verify location eligibility using the HRSA data base found here: https://data.hrsa.gov/tools/medicare/telehealth. Additionally, several practitioner types such as physical therapists, occupational therapists, speech-language pathologists, and audiologists are no longer authorized to furnish reimbursable telehealth services under Medicare. For mental health services, an in-person visit is now required within six months prior to an initial telehealth encounter and at least annually thereafter, unless an exception applies.
Shortly after the shutdown, CMS issued a special Medicare Learning Network (MLN) notice directing Medicare Administrative Contractors (MAC) to place a temporary 10-business-day hold on processing telehealth claims. This administrative step is standard practice when statutory payment provisions are scheduled to expire, allowing CMS to avoid reprocessing large numbers of claims if Congress restores coverage. CMS also advised providers that when delivering services not currently eligible for payment, they may wish to issue an Advance Beneficiary Notice of Noncoverage (ABN) to alert patients of potential out-of-pocket responsibility. As of October 15th, CMS issued a second notice stating that in anticipation of possible Congressional action, MACs will continue to temporarily hold claims with dates of service of October 1, 2025 and later for services impacted by the expired Medicare legislative waivers. This includes all claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center (FQHC) claims. While providers may continue to submit these claims, CMS states that payment will not be released until the claims hold is lifted.
During this interim period, we recommend providers take action to ensure proper claim submission and compliance with new (possibly temporary) rules are met. The Center for Connected Health Policy (CCHP) has reported that some practices are delaying claim submissions or rescheduling telehealth visits, while others are shifting appointments to in-person settings or continuing virtual services at their own financial risk. Many organizations remain optimistic that Congress will soon reinstate the waivers given the extended notice.