Medicare Just Rolled Back Telehealth Flexibilities — Here’s What It Means for You
On October 1, 2025, the pandemic-era Medicare telehealth flexibilities officially expired, triggering a return to stricter pre-COVID rules. The changes include:
Telehealth services are once again limited to certain approved facility locations (rather than patients’ homes) in most cases.
Only specific provider types remain eligible to bill Medicare for telehealth.
For mental health telehealth, patients must have had an in-person visit within six months before the first telehealth session and annually thereafter.
Medicare Administrative Contractors (MACs) have been instructed to temporarily hold telehealth claims to avoid massive reprocessing if rules are reinstated. Claims can still be submitted, but payment is paused.
Providers are being urged to consider issuing Advance Beneficiary Notices (ABNs) when performing telehealth services that may no longer be covered under the reverted rules.
You can read the full article here: “Medicare Telehealth Flexibilities Have Expired” (Mondaq) https://www.mondaq.com/unitedstates/healthcare/1686646/medicare-telehealth-flexibilities-have-expired?
What This Means for Providers & Billing Operations:
1. Heightened Financial Risk & Cash Flow Disruption
With claim payments on hold and stricter telehealth eligibility, practices face increased denial risk and delays. A billing partner that understands these regulatory shifts becomes essential — not optional.
2. Telehealth Strategy Must Be Reassessed
The services your practice assumed could be delivered remotely may no longer qualify under Medicare. It’s time to audit your telehealth offerings:
Determine which telehealth services still qualify under the reverted rules
Identify which must shift to in-person or be billed differently
Ensure your documentation, coding, modifiers, and place-of-service use match the “old rules” precisely
3. Documentation & Compliance Burden Rising
With reversion to stricter rules, even small coding errors or documentation gaps can trigger denials. Clarity and consistency are more important than ever.
4. Patient Communication Is Key
Patients used to home telehealth may be surprised by these changes. Practices should inform patients proactively about:
Which telehealth appointments may no longer be covered
When in-person visits are required
Patient financial responsibility (especially for services that may fall outside Medicare coverage)
5. Advocacy & Monitoring Remain Vital
It’s not impossible that Congress will restore or codify telehealth flexibilities — perhaps even retroactively. Providers, associations, and billing partners should stay engaged in the policy dialogue.
Even as the flexibilities expire, the decisions made now could shape the next round of reforms.
How Allied PM Solutions Can Steer You Through
This is a turning point for telehealth billing. As your billing team, we can act as more than a claims processor. We can:
Perform claims audits to catch at-risk telehealth submissions
Flag services that no longer qualify under Medicare’s reverted rules
Guide on correct modifiers, place-of-service codes, and ABN usage
Monitor payer responses and adjust to denials trends
Help plan for cash flow contingencies as reimbursements get delayed or paused
📞 Contact us today at info@alliedpmsolutions.com or 669-202-0840 to learn how we can help your practice stay compliant and maximize reimbursement with your telehealth claims and beyond.