PBN preview: Without congressional action, the end is nigh for telehealth expansions

After five years, most – but not all – of Medicare’s telehealth expansions are scheduled to end at midnight, Oct. 1. Even though one quarter of eligible Medicare patients continue to take advantage of the broader telehealth benefit, it seems unlikely that Congress will pass another last-minute extension or a permanent upgrade to Medicare telehealth law to keep the popular policies in place (PBN 9/8/25 subscription required).

 

While national advocacy groups such as the American Telemedicine Association (ATA), medical societies and individuals are urging Congress to act fast, practices should warn patients and staff that many of these exceptions are about to expire.

 

For most telehealth services the three main changes will be the return of three key sections of the telehealth law:

 

1. Originating site rules. The patient must go to an originating site, such as a hospital, physician’s office or rural health clinic for a telehealth visit which will be transmitted to the treating provider at a distant site. The provider can decide whether the encounter requires a presenter at the originating site.

 

2. Geographic location requirements. The originating site must be in a rural area or a health professional shortage area (HPSA).

 

The resources section of this article, below, includes a link to the Medicare Telehealth Payment Eligibility Analyzer. Enter the address of the originating site to determine whether telehealth services are covered.

 

3. Treating provider limits. Medicare will not cover telehealth services by the following four specialties after Sept. 30: Audiologists, occupational therapists (OT), physical therapists (PT) and speech language pathologists (SLP).

 

However, some exceptions have been extended on a permanent or temporary basis.

 

 

Medicare patients can continue to receive treatment for mental health conditions from home. The geographic restrictions do not apply to these services and patients can opt for an audio-only encounter if they’re at home. Note that audio-only encounters are not an option if a patient is at an originating site.

 

If your practice bills for a variety of specialties, such as psychiatry and pain management, or psychology and internal medicine, make sure everyone on the staff and your patients understand the rule only applies to the encounters to treat relevant conditions and that the primary diagnosis should support the telehealth services.

 

Older telehealth expansions will continue to apply to the treatment of substance abuse disorders and related mental health conditions, monthly clinical assessments for end-stage renal disease (ESRD) patients and treatments for acute stroke patients, according to 410 CFR §410.78.

 

 

CMS will maintain the following exceptions that would have otherwise expired Oct. 1, until midnight, Jan. 1, 2026:

CMS intends to make the virtual direct supervision requirement permanent for a wide range of codes and end the frequency limits in 2026 (PBN 7/28/25 subscription required).

 

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