Strategic Move Positions Nation’s Largest Medicare Advantage Carrier as Telehealth Access Leader
As temporary COVID-19 telehealth flexibilities under Original Medicare expired on September 30, 2025, UnitedHealthcare announced it will continue offering expanded telehealth coverage for medical and mental health services delivered at home through 2026 across its Medicare Advantage plans.
This decision affects millions of beneficiaries enrolled in UnitedHealthcare Medicare Advantage—the nation’s largest Medicare Advantage carrier, with plans available to 94% of Medicare eligibles in 2026.
Bobby Hunter, CEO of UnitedHealthcare Government Programs, stated: “We’re modernizing our offerings in response to rising health care costs while preserving what matters most to our members. From $0 copays to enabling access to high-quality care, we’re helping people live healthier lives with confidence and support.”
What UnitedHealthcare Will Cover in 2026
Comprehensive In-Home Telehealth
UnitedHealthcare Medicare Advantage members will retain access to:
✓ Medical telehealth services delivered at home by in-network physicians and non-physician practitioners (PAs, NPs)
✓ Mental health telehealth with no in-person visit requirements when provided by in-network mental health providers
✓ Both audio-only and audio-video visits for services on CMS’s Medicare Telehealth List
✓ No geographic restrictions—members can access care from home regardless of location
Network Requirements
For individual Medicare Advantage PPO plans, telehealth services must be provided by in-network providers. Medicare Advantage PFFS plans allow members to access telehealth from any Medicare-eligible provider.
The Context: What Changed on October 1, 2025
Original Medicare’s Telehealth Retreat
Congress failed to extend pandemic-era telehealth flexibilities beyond September 30, 2025. As a result, Original Medicare beneficiaries now face:
- Geographic restrictions: Most telehealth services require patients to be in a medical facility located in a rural area
- Originating site requirements: Patients cannot receive most services from home
- In-person mandates: Mental health telehealth requires an in-person visit within the last 6-12 months
- Limited audio-only coverage: Most services require video capability
The Growing Divide
This creates a stark two-tier system:
| Coverage Feature | Original Medicare | UnitedHealthcare MA |
| Home-based telehealth | Limited | ✓ Covered |
| Geographic restrictions | Yes | No |
| In-person requirements (mental health) | Yes | No |
| Audio-only visits | Limited | ✓ Covered |
| Rural-only requirements | Yes (most services) | No |
Why This Matters: Strategic and Competitive Implications
1. Competitive Advantage During Open Enrollment
The timing is critical. During the October 15-December 7, 2025 Medicare open enrollment period, telehealth access becomes a powerful differentiator for beneficiaries choosing between Original Medicare and Medicare Advantage.
For seniors who have come to rely on telehealth—particularly those with mobility challenges, transportation barriers, or living in rural areas—the choice is now clear: Original Medicare offers restricted access, while UnitedHealthcare Medicare Advantage maintains expanded coverage.
2. Mental Health Access Protection
The mental health coverage distinction is particularly significant. Original Medicare now requires in-person visits for mental health telehealth, creating barriers for patients managing behavioral health conditions.
UnitedHealthcare’s decision to waive in-person requirements for mental health telehealth could be decisive for beneficiaries seeking consistent mental health care without transportation or mobility obstacles.
3. Market Position Reinforcement
UnitedHealthcare’s 2026 Medicare Advantage plans emphasize value and accessibility with $0 premiums, $0 copays for primary care and Tier 1 prescriptions, and dental, vision, and hearing benefits. Adding continued telehealth access to this package strengthens an already compelling value proposition.
4. Statutory Flexibility Advantage
Medicare Advantage plans have statutory authority to offer additional benefits beyond traditional Medicare coverage, including telehealth benefits not routinely covered by Original Medicare. UnitedHealthcare is leveraging this flexibility to maintain member satisfaction and competitive positioning.
Implications for Healthcare Providers
The Two-Track Challenge
Providers now face operational complexity managing different telehealth rules based on patient insurance:
If your patient has Original Medicare:
- Verify originating site compliance (rural medical facility for most services)
- Document in-person visits for mental health telehealth
- Limit audio-only services
- Be prepared for claim denials if flexibilities aren’t met
If your patient has UnitedHealthcare Medicare Advantage:
- Home-based telehealth fully covered
- No geographic or originating site restrictions
- Audio-only and video visits both eligible
- No mandatory in-person requirements for mental health
Revenue Cycle Impact
Claims Risk: Claims submitted for Original Medicare telehealth services under expired flexibilities will be denied. Providers continuing to bill under old waiver rules after September 30, 2025, may face audits or recoupment actions.
Documentation Requirements: Providers must implement systems to verify insurance type before scheduling telehealth appointments and document compliance accordingly.
Network Importance: Ensuring in-network status with UnitedHealthcare and other Medicare Advantage carriers maintaining telehealth coverage is now directly tied to telehealth revenue sustainability.
What Providers Should Do Now
1. Audit Your Patient Population
Immediately assess:
- What percentage of patients have Original Medicare vs. Medicare Advantage?
- How many patients rely primarily on telehealth for ongoing care?
- Which Medicare Advantage plans in your market maintain telehealth coverage?
2. Update Billing and Scheduling Systems
- Flag patient insurance type before telehealth scheduling
- Create separate workflows for Original Medicare vs. Medicare Advantage telehealth
- Implement pre-claim edits to catch non-covered telehealth services
- Train staff on the divergent rule sets
3. Communicate with Patients
Proactively inform Original Medicare patients about coverage changes. For those who lose telehealth access, discuss:
- Transitioning to in-person visits
- Medicare Advantage enrollment options during open enrollment
- Alternative care delivery arrangements
4. Verify Credentialing Status
Prioritize in-network credentialing with Medicare Advantage plans, particularly UnitedHealthcare. Out-of-network status now directly limits telehealth revenue opportunities.
5. Monitor Congressional Action
Several bipartisan bills could restore Medicare telehealth flexibilities:
- The CONNECT for Health Act (65 Senate co-sponsors) would permanently extend flexibilities
- The Telehealth Modernization Act proposes a two-year extension
It’s possible CMS could apply retroactive reimbursement if legislation passes. Providers should monitor developments and consider holding claims associated with services not currently payable.
The Broader Market Context
Medicare Advantage Growth Trajectory
This policy divergence could accelerate the already substantial shift from Original Medicare to Medicare Advantage. If telehealth access proves decisive in plan selection, insurers maintaining these benefits will capture market share.
UnitedHealthcare’s dominant market position—plans available to 94% of Medicare eligibles in 2026—means its telehealth policy will set competitive standards. Other Medicare Advantage carriers will face pressure to match or exceed these benefits.
The Cost Consideration
The Congressional Budget Office scored telehealth extension through December 2024 as costing $2.4 billion. However, evidence suggests beneficiaries with greater telehealth access may have fewer emergency department visits and improved medication adherence—potentially offsetting costs through reduced acute care utilization.
Medicare Advantage plans can absorb these costs within their capitated payment structure, while Original Medicare operates on fee-for-service economics that make telehealth expansion more challenging from a budget perspective.
Looking Ahead
Will Original Medicare Restore Coverage?
Congressional action remains possible but uncertain. The CONNECT for Health Act has strong bipartisan support (65 Senators), but legislative gridlock has prevented progress.
For now, the two-tier system persists: Medicare Advantage members enjoy expanded access while Original Medicare beneficiaries face pre-pandemic restrictions.
The New Normal?
UnitedHealthcare’s announcement may signal a permanent shift where Medicare Advantage plans routinely offer benefits that Original Medicare cannot or will not cover. This aligns with the broader trend of Medicare Advantage plans providing supplemental benefits like dental, vision, and hearing coverage.
From a policy perspective, this raises questions about equity in Medicare coverage and whether beneficiaries’ access to care should depend on their plan choice.
Key Takeaways for Billing and Credentialing Professionals
For Medical Billing Companies:
- Update systems immediately to reflect October 1, 2025, policy changes
- Implement eligibility verification checkpoints before telehealth scheduling
- Prepare for increased Original Medicare telehealth denials
- Educate provider clients about documentation requirements for compliant billing
- Monitor for retroactive policy changes that might reverse denials
For Credentialing Specialists:
- Prioritize Medicare Advantage network enrollment for providers offering telehealth
- Verify telehealth-specific credentialing requirements with each payer
- Expedite applications to avoid coverage gaps during the transition
- Maintain updated provider telehealth capability documentation
For Practice Administrators:
- Conduct patient insurance audits to identify affected populations
- Establish clear protocols for insurance verification before telehealth scheduling
- Document thoroughly to support compliance with applicable coverage rules
- Communicate proactively with patients about coverage changes
Clarifications
While most temporary telehealth flexibilities under Original Medicare expired on September 30, 2025, certain categories of services remain eligible for remote delivery. These include some behavioral health, primary care, and substance use disorder services under specific conditions.
It’s also important to note that telehealth coverage rules vary by plan type and state, and providers should verify current CMS and Medicare Administrative Contractor (MAC) guidance before billing.
Information regarding UnitedHealthcare’s telehealth coverage applies specifically to its Medicare Advantage plans and does not automatically extend to Original Medicare or other private payers.
UnitedHealthcare’s decision to maintain expanded telehealth coverage through 2026 represents a competitive strategy and a commitment to access. As the nation’s largest Medicare Advantage carrier, this policy will affect millions of beneficiaries and set market expectations for telehealth coverage.
For healthcare providers, the message is clear: understanding the distinction between Original Medicare and Medicare Advantage telehealth rules is now essential to maintaining compliant operations and optimal revenue cycle performance.
The policy divergence creates immediate operational challenges, but also clarifies the value proposition of Medicare Advantage membership for beneficiaries who have come to rely on telehealth access.
Whether Congress acts to restore parity or this two-tier system becomes permanent remains to be seen. Until then, providers must navigate dual requirements while UnitedHealthcare and other Medicare Advantage plans fill the access gap left by Original Medicare’s retreat.
Sources
- UnitedHealthcare Provider. (October 2025). “UnitedHealthcare Medicare Advantage telehealth benefits continue through 2026.”
- UnitedHealthcare. (October 2025). “UnitedHealthcare’s 2026 Medicare Advantage Plans Deliver Value, Access and Consumer Choice.”
- U.S. Department of Health and Human Services. (2025). “Telehealth Policy Updates.”
- Centers for Medicare & Medicaid Services. (2025). “Telehealth Insurance Coverage.”
- McDermott Will & Emery. (October 2025). “Medicare telehealth flexibilities expire: Immediate impacts and next steps.”
- Kaiser Family Foundation. (October 2024). “What to Know About Medicare Coverage of Telehealth.”
- AARP. (2025). “Medicare Telehealth Coverage Expired Sept. 30.”
Disclaimer: This article is intended for informational purposes only and does not constitute legal, billing, or compliance advice. Healthcare providers and billing companies should consult with qualified professionals regarding specific regulatory requirements.
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