Unless Congress acts, several temporary Medicare telehealth policies established during the COVID-19 pandemic will end on September 30, 2025. These policies expanded access to care, but their expiration could create a “telehealth policy cliff” affecting patients, providers, and health systems nationwide. With political uncertainty in Washington, stakeholders face the possibility of major changes to reimbursement and coverage rules.
What’s at Stake?
- Medicare reimbursement for telehealth visits in patients’ homes would end, restoring pre-pandemic rural and facility restrictions.
- Programs like Hospital at Home could lose funding and face disruption.
- Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) would no longer be eligible to serve as distant-site providers after December 2025.
- Telehealth prescribing rules for controlled substances remain uncertain, despite temporary extensions until December 2025.
While Congress has granted last-minute extensions in the past, providers are urged to prepare contingency plans now. Early communication with patients and staff can reduce confusion if policies expire on schedule.
The Return of Geographic and Facility Restrictions
Without an extension, Medicare will once again limit telehealth reimbursement to specific originating sites and rural areas. Home-based telehealth visits would only be covered in narrow circumstances, such as for mental health, substance use disorder treatment, or end-stage renal disease dialysis support.
The End of the Hospital at Home Waiver
The Hospital at Home model allows patients to receive acute care at home. If the waiver expires:
- Hospitals cannot bill Medicare Fee-for-Service for Hospital at Home care.
- Private payers, Medicaid managed care, and self-pay patients may still be billed.
- Hospitals would need to absorb costs if they continue home-based care without reimbursement.
Preparing for Transition
- Develop plans to transition Hospital at Home patients back to inpatient care.
- Communicate clearly with patients, caregivers, and staff.
- Plan for transportation, bed capacity, and staffing needs after September 30, 2025.
Telehealth Prescribing of Controlled Substances
The DEA and DOJ have proposed new rules requiring special telemedicine registrations for prescribing controlled substances. Concerns include:
- Complex registration categories and high application fees.
- Exclusion of primary care providers from advanced prescribing authority.
- Limits on Schedule II prescribing, which may disrupt psychiatric and pain management care.
- State-by-state registration requirements and potential processing delays.
- Identity verification mandates that could add administrative burden.
Advocacy groups, including the American Telemedicine Association, are urging revisions to reduce barriers and ensure patient access.
Provider Eligibility
Who Remains Eligible?
- Physicians, nurse practitioners, physician assistants, clinical psychologists, clinical social workers, dietitians, and mental health counselors.
Who Loses Eligibility?
- Occupational therapists
- Physical therapists
- Speech-language pathologists
- Audiologists
Practices should prepare transition plans to maintain care continuity for patients who rely on providers losing telehealth eligibility.
Impact on FQHCs and RHCs
After December 31, 2025, FQHCs and RHCs may lose their ability to serve as distant-site telehealth providers for medical visits. Mental health services may continue with restrictions, but reimbursement and billing codes could change. Clinics should review service offerings, staffing, and patient communication strategies now.
Telemental Health Services
Beginning October 1, 2025, Medicare will require most telemental health patients to have an in-person visit with their provider within six months before their first telehealth visit, and again at least every 12 months. Exceptions may apply for rural patients, substance use disorder treatment, or when travel risks outweigh benefits.
Planning Ahead
- Identify patients who may be affected by in-person requirements.
- Expand in-person capacity and referral networks.
- Communicate changes and exceptions clearly to patients.
- Track and document exceptions in medical records.
- Monitor CMS updates for evolving guidance.
Contingency Planning Checklist
- Assess patient impact: Identify who depends on telehealth outside approved sites and evaluate their alternatives.
- Evaluate financial risk: Decide whether to continue offering telehealth without Medicare reimbursement.
- Prepare communications: Draft patient notices and consider using an Advance Beneficiary Notice (ABN) to explain financial liability.
- Train staff: Ensure providers, schedulers, and billing teams understand upcoming changes.
- Explore alternatives: Partner with FQHCs, RHCs, or rural hospitals to maintain access where possible.
Conclusion
The potential expiration of telehealth flexibilities on September 30, 2025, could reshape care delivery across the country. While Congress may still act, healthcare providers should prepare now with proactive communication, workflow adjustments, and contingency planning. Taking steps today will ensure patients, providers, and health systems are not caught unprepared if the telehealth policy cliff arrives.
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