UPDATE: Be Prepared — We’ve Hurled Over the Telehealth Cliff

October 1 marked not only the shutdown of the United States government, but the end of telemedicine flexibilities initially established in the advent of the COVID-19 pandemic.

As Bradley previously reported, Congress passed a collection of legislative measures between March 2020 and December 2023 expanding Medicare coverage eligibility and reimbursement requirements for services rendered via telemedicine, with the intent of ensuring that a provider’s ability to furnish quality healthcare to his or her patients is not impacted by physical, in-person requirements. These statutory expansions — initially set to expire on December 31, 2024 — were subsequently extended through March 31, 2025, with the passing of the American Relief Act. However, in light of the impending March 31 expiration date, Congress once again extended COVID-19-era telehealth policies and waivers through September 30, 2025.

Because Congress did not take further legislative action to modify and/or prolong these measures, telemedicine flexibilities in Medicare officially expired September 30, 2025, meaning that, effective October 1, 2025, telehealth within the Medicare program is now subject to pre-pandemic statutory limitations.

Included below is a brief summary of key COVID-19 telehealth flexibilities and the statutory restrictions now in effect as a result of their expiration.

Over the past five years, providers and patients alike have benefitted from or grown accustomed to both the limitations and benefits of telemedicine delivered under these COVID-19 flexibilities.

Moving forward, Medicare and commercial payors may begin denying claims for telehealth services formerly reimbursable under the COVID-19 flexibilities.

Providers should continue to monitor Congressional action concerning Medicare telehealth services, as additional legislative action has the potential to reinstate some or all of the expired COVID-19 flexibilities. Additionally, providers may need to evaluate the telehealth services and arrangements they offer to patients to assess coverage restrictions under the current statutory limitations.

Providers may need to consider changing how they deliver patient care under the new (or prior) coverage policies to mitigate the impact of the telehealth “cliff” on the continuity of care provided to Medicare patients. Providers should also note that many commercial payors follow Medicare’s coverage policies, so this may affect coverage and billing options under those plans as well.

Should you have any questions about how this may impact your telehealth practice, please contact Evie Lalangas or Carly Kirkland.

Bradley will continue to monitor any developments related to these Medicare telehealth coverage restrictions.