On September 30, 2025, the temporary Medicare telehealth flexibilities implemented during the COVID-19 pandemic expired. In the months leading up to the deadline, legislators considered proposals to continue to extend the flexibilities that permit Medicare reimbursement of telehealth. However, Congress failed to pass a government funding bill by the September 30 deadline, triggering a federal government shutdown and stalling legislative action on telehealth. As of October 1, 2025, many of the Medicare telehealth flexibilities adopted during the COVID-19 public health emergency (PHE) have officially reverted to pre-pandemic policies. Failing to adjust properly, including billing for disallowed services, and ignoring in-person requirements, may lead to audits, recoupments, or compliance penalties. In the interim, providers should review billing policies, contracts, informed consents, and patient notices to ensure they reflect updated measures while awaiting further congressional action.
Expired telehealth flexibilities include, but are not limited to:
- Originating Site Restrictions: Patients may no longer receive telehealth services from their homes, limiting coverage to certain approved health care facilities.
- Geographic Location Restrictions: Telehealth services are once again restricted to patients located in rural areas.
- Distant Sites: Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) may no longer serve as distant site providers for most telehealth services.
- Audio-Only Communication: Coverage for audio-only telehealth has ended for non-behavioral and non-mental health services.
Impact on Providers and Patients
The expiration of these provisions represents a significant shift for providers and patients who have relied on telehealth as a primary mode of health care. For patients, losing access to these flexibilities presents barriers to care and reduced access to vital services, especially for those in rural areas or without access to video-capable technology, and these changes create immediate billing and compliance challenges for providers. Claims submitted for telehealth services furnished after October 1, 2025, under the expired flexibilities, may be denied by Medicare Administrative Contractors (MACs). Providers may also be subject to audits or recoupment actions if they continued billing under the old waiver rules after the expiration.
How Frier Levitt Can Help
Frier Levitt closely monitors ongoing developments in telehealth and advises providers, telehealth organizations, and administrative companies on policy implementation strategies to comply with the evolving legal and regulatory landscape. Contact Frier Levitt to discuss how we can support the compliance of your organization’s telehealth business model.
