Resources & Reports

August is already upon us and we now find ourselves quickly approaching the current expiration date for the Medicare telehealth waivers (September 30, 2025). As it stands now, without further Congressional action, the Medicare telehealth policies will soon revert back to their permanent requirements, which will reduce the amount of Medicare enrollees who will be able to access services via telehealth due to the various limitations that will again be enforced. Additionally, just last month, the Centers for Medicare and Medicaid Services (CMS) released their proposals for the 2026 Physician Fee Schedule (2026 PFS) (for more information on the 2026 PFS telehealth proposals, please see CCHP’s Fact Sheet), which includes proposed rules that would also impact permanent Medicare telehealth policies. Therefore, we have several factors at play that could impact the state of telehealth in Medicare starting on October 1, 2025 if no further action is taken by Congress.

In mid-July, the Centers for Medicare and Medicaid Services (CMS) released the proposed CY 2026 Physician Fee Schedule (PFS). CCHP has published a factsheet summarizing the key telehealth-related changes included in the proposal. As the policy community reviews the proposed updates, it is important to highlight that CMS has limited options to alter Medicare telehealth policy. Unless Congress acts within the next two months, many of the broad telehealth flexibilities that patients and providers have come to rely on since March 2020 will expire starting October 1, 2025. If that happens, current waivers and temporary policies will sunset, and Medicare’s permanent telehealth statute will take effect once again.  Permanent Medicare law still allows telehealth reimbursement, but a return to its more restrictive rules could significantly curtail utilization, even alongside potential PFS expansions. However, there have been pieces of federal legislation introduced during this current Congressional session that attempt to address and change these limitations.

Much of the telehealth community has been waiting to see what the Centers for Medicare and Medicaid Services (CMS) will be proposing in the 2026 Physician Fee Schedule (PFS). The wait was over when on July 14, 2025 the unpublished version of the 2026 PFS was released (the official version was subsequently published in the Federal Register). For those who are unfamiliar, the PFS is the vehicle CMS uses to update, change or introduce new policies that will impact the Medicare program for the following year. Unless otherwise stated, the policies typically go into effect on the first of the new year.

While many are likely familiar with the usual policy channels for telehealth in states, such as laws, regulations, Medicaid manuals, providers letters and bulletins, which comprise the majority of source information on the Center for Connected Health Policy’s (CCHP) Policy Finder, occasionally a state agency or other various organizations in the state may develop and make available additional valuable telehealth resources that readers may find helpful, yet they do not fit into the CCHP Policy Finder’s specific categories (which currently include Medicaid Reimbursement, Private Payer Policies, and Professional Regulation).  Below are a few examples that demonstrate the variety of different materials that could be useful to patients, providers and policymakers.