Medicare Telehealth Updates for 2026 

CMS released the Telehealth FAQ for Calendar Year 2026 (updated November 14, 2025). Changes are based on the CY 2026 PFS final rule, prior rules, and statutes like the Consolidated Appropriations Act, 2021. Flexibilities extend through January 30, 2026, with restrictions resuming January 31 unless noted. Behavioral health services retain broader access. 

Beneficiary Location Requirements 

Through January 30, 2026, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories. Starting January 31, 2026, except for behavioral health, beneficiaries must be in a medical facility and rural area. 

Practitioner Restrictions 

Through January 30, 2026, an expanded range of practitioners can bill for Medicare telehealth services. Starting January 31, 2026, physical therapists, occupational therapists, speech-language pathologists, and audiologists cannot furnish these services. 

Outpatient Therapy, Diabetes Self-Management Training, and Medical Nutrition Therapy 

CMS aligns payment policies with telehealth rules. Through January 30, 2026, hospitals can bill for services furnished remotely by staff to beneficiaries at home. Starting January 31, 2026, hospitals cannot bill for these when furnished remotely to home-based beneficiaries. 

Payments in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) 

Behavioral health services furnished by RHCs or FQHCs on or after January 1, 2022, via telecommunications are paid under the All-Inclusive Rate (AIR) for RHCs and Prospective Payment System (PPS) for FQHCs. Through December 31, 2026, RHCs and FQHCs can bill non-behavioral health services furnished via telecommunications using HCPCS code G2025. The home can continue as the originating site for services furnished by RHCs and FQHCs. 

In-Person Visit Requirements for Behavioral Health 

Section 1834(m) requires an in-person, non-telehealth visit within 6 months prior to the first mental health telehealth service, effective after January 30, 2026. Per CY 2022 PFS, payment for behavioral health via telecommunications at home requires a prior in-person service (paid or payable by Medicare) within 6 months of the initial telehealth service. After the first, an in-person service is required within 12 months of each subsequent telehealth service, with limited exceptions. In-person visits can be by a same-specialty physician/practitioner in the same group if the telehealth provider is unavailable. 

This 6-month prior visit does not apply to beneficiaries who began home-based mental health telehealth on or before January 30, 2026; they are established and need one in-person visit every 12 months. Hospital staff remote behavioral health aligns with PFS rules. For RHC/FQHC virtual patient presence, in-person requirements do not apply until at least January 31, 2026. 

Audio-Only Telehealth Services 

Under current law, beneficiaries can receive audio-only telehealth at home through January 30, 2026. Starting January 31, 2026, physicians/practitioners may use two-way real-time audio-only for behavioral health at home if technically capable of audio-video but the beneficiary cannot or does not consent to video. Audio-only applies to new and established patients. Hospital staff remote mental health (per CY 2023/2024 OPPS rules) may use audio-only. 

Virtual Presence for Teaching Physicians 

In the CY 2026 PFS final rule, starting January 1, 2026, teaching physicians can have virtual presence in all teaching settings for Medicare telehealth services via audio/video real-time technology during the key portion, across all residency locations. 

Place of Service Codes 

Use POS 02 for telehealth other than patient’s home or POS 10 for telehealth in patient’s home (private residence, not facility). Per CY 2024 PFS, starting January 1, 2024, home-based telehealth claims pay at non-facility rates. 

Frequency Limits for Inpatient, Nursing Facility Visits, and Critical Care 

In the CY 2026 PFS final rule, telehealth frequency limits on subsequent inpatient/nursing facility visits and critical care consultations are permanently removed, effective January 1, 2026. 

Virtual Direct Supervision 

In the CY 2026 PFS final rule, starting January 1, 2026, direct supervision presence may include virtual via audio/video real-time (excluding audio-only) for services without 010/090 global surgery indicators. Applies to most incident-to services (§410.26), many diagnostic tests (§410.32), pulmonary rehabilitation (§410.47), cardiac/intensive cardiac rehabilitation (§410.49), and certain hospital outpatient services (§410.27(a)(1)(iv)). 

Geographic/Place Restrictions for Behavioral Health (Including SUD) 

The Consolidated Appropriations Act, 2021 permanently removed restrictions. Beneficiaries in rural/urban areas can receive services at home. Two-way interactive audio-only is permitted. 

Requests to Change Medicare Telehealth Services List 

Requests must reach CMS by February 10 for consideration in next year’s PFS rulemaking. Include supporting documentation; all info is public. See https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/index.html for submission details and current list. 

Non-Face-to-Face Services (e.g., Community Health Integration, Chronic Care Management) 

Telehealth restrictions under §1834(m) apply only to inherently face-to-face services. Non-face-to-face services that do not substitute for in-person encounters are exempt. 

Special Flexibilities for ACOs in Medicare Shared Savings Program 

The Bipartisan Budget Act of 2018 allows clinicians in applicable ACOs to furnish/pay for telehealth without geographic restriction, at beneficiary home, to prospectively assigned beneficiaries. Applicable ACOs: ENHANCED track or BASIC C/D/E with prospective assignment. Bill via ACO participant TIN. No-risk or preliminary prospective ACOs follow standard FFS rules. No application needed. See Medicare Shared Savings Program Telehealth Fact Sheet on CMS.gov. 

Distant Site from Home 

Practitioners can provide telehealth from home. Those with physical locations need not report home address; bill from physical site. Virtual-only practitioners must enroll home as practice location, marked “Home office for administrative/telehealth use only” to suppress street details on CMS Care Compare. Email QPP@cms.hhs.gov to suppress address/phone.