Medicare Telehealth Flexibilities Expire: What Hospital Leaders Need to Know

Healthcare Policy Update
Oct 03, 2025
Article Background

What’s happening

While the government shutdown is getting all of the headlines, healthcare providers are also concerned about various federal health programs that expired on September 30th, including most notably certain Medicare telehealth flexibilities. Rules for furnishing telehealth to Medicare beneficiaries now revert to pre-pandemic limitations.

Of interest

The following Medicare telehealth flexibilities are now expired:

Geographic and originating site flexibilities
Expanded provider type eligibility
Audio-only telehealth
Rural health clinic/federally qualified health center flexibility as a distant site
Waiver of the mental health visit in-person requirement

The Centers for Medicare and Medicaid Services (CMS) issued an MLN Connects bulletin providing limited guidance to address telehealth visits covered under fee-for-service Medicare and special rules that may apply to telehealth visits provided by clinicians in certain accountable care organizations.

Why you should care

The expiration impacts the continuity of care for patients relying on telehealth services, potentially disrupting their access to healthcare. Providers must adapt to new requirements, which may involve converting telehealth visits to in-person or phone consultations, or notifying patients about potential changes in coverage and billing.

Looking to learn more?

Our partners at McDermott+ and McDermott Will & Schulte (MWS), trusted leaders in healthcare consulting and law, outline the immediate impacts of the expiration and next steps for providers.  Click here to read their Medicare telehealth flexibilities expiration note.