Missed Our Telehealth Webinar? Here’s What You Need to Know for 2026 

A comprehensive recap of Jacqueline Thelian’s essential guidance on navigating the new telehealth landscape 

If you missed our recent webinar with telehealth expert Jacqueline Thelian, you missed a crucial discussion about changes that could significantly impact your practice. The telehealth landscape shifted dramatically on January 30, 2026, and providers who aren’t prepared may find themselves unable to deliver services they’ve been providing for years—or worse, facing reimbursement denials. 

The Big Picture: What Changed on January 30, 2026? 

The COVID-19 public health emergency brought unprecedented flexibility to telehealth services. Those days are largely over. Most Medicare telehealth flexibilities ended on January 30, 2026, forcing a return to pre-pandemic geographic restrictions. 

This means many services are once again limited to patients in rural areas or designated health professional shortage areas. However—and this is critical—the changes aren’t uniform across specialties. Some providers retained significant flexibility, while others lost telehealth privileges entirely. 

The Providers Who Lost Telehealth Access 

Perhaps the most dramatic change affects rehabilitation therapists. Starting January 31, 2026, physical therapists, occupational therapists, speech-language pathologists, and audiologists can no longer furnish telehealth services under Medicare. 

If you’re in one of these specialties, this isn’t a temporary restriction or a billing nuance—it’s a complete elimination of telehealth as a service delivery option for Medicare patients. Practices that built telehealth programs around these services need immediate alternative strategies for patient care continuity. 

Behavioral Health: The Major Exception 

While other specialties faced restrictions, behavioral and mental health providers emerged as the clear winners in the 2026 changes. These providers now enjoy permanent telehealth flexibilities that other specialties can only envy: 

Permanent Home Access: Medicare patients can permanently receive behavioral and mental health telehealth services in their homes. This isn’t a temporary extension—it’s now a permanent feature of Medicare coverage. 

No Geographic Restrictions: Unlike other telehealth services that are limited to rural areas, behavioral health telehealth has no geographic restrictions. Urban, suburban, and rural patients all have equal access. 

Audio-Only Services: Behavioral health providers can permanently deliver services using audio-only communication platforms. This is particularly significant for patients who lack reliable internet, have privacy concerns about video, or simply prefer phone consultations. 

Expanded Provider Types: Marriage and family therapists and mental health counselors can permanently serve as Medicare distant site providers, expanding the behavioral health workforce available through telehealth. 

However, there’s an important requirement: providers must conduct an in-person, non-telehealth visit within six months prior to the first mental health telehealth service and annually thereafter. This requirement ensures ongoing patient-provider relationships include face-to-face assessment. 

Understanding the New Geography: Originating Sites Matter Again 

For non-behavioral health services, geography has returned to center stage. The originating site must be located in either a county outside a metropolitan statistical area or a rural health professional shortage area in a rural census tract. 

Authorized originating sites include physician and practitioner offices, hospitals, critical access hospitals, rural health clinics, federally qualified health centers, hospital-based or CAH-based renal dialysis centers (including satellites), skilled nursing facilities, community health centers, renal dialysis facilities, mobile stroke units, and rural emergency hospitals. 

The patient’s home is only permissible for diagnosis and treatment of mental health disorders, treatment of substance use disorder, monthly ESRD-related clinical assessments, and diagnosis and treatment of acute stroke. 

There are no geographic restrictions for the treatment of substance use disorder, diagnosis and treatment of mental health disorders, home dialysis for ESRD patients, and diagnosis and treatment of acute stroke. 

Providers Eligible to Bill Telehealth Services 

The following providers are eligible to bill for telehealth services: physicians, physician assistants, nurse practitioners, clinical nurse specialists, clinical psychologists, clinical social workers, registered dietitians or nutrition professionals, certified registered nurse anesthetists, marriage and family therapists, and mental health counselors. All distant site providers are subject to state licensing requirements, and Medicare requires separate enrollment for each state where the practitioner provides services. 

Distant Site Requirements 

A distant site is the location where a physician or practitioner provides telehealth. Distant site practitioners can provide telehealth services from their home. Medicare doesn’t require practitioners with a physical practice location who provide telehealth services from their homes to report their home address on their Medicare enrollment application. Practitioners can enroll and bill from their physical practice location as if they provided the telehealth service in person. 

Virtual-only telehealth practitioners who only have a physical practice location at their home address need to enroll it as their practice location. You may choose to suppress your street address details from the public by marking your address as a “home office for administrative or telehealth use only” location in your enrollment application in PECOS. 

Technology Requirements: Not Just Any Video Call 

Generally, you must use two-way, interactive audio-video technology. As of January 1, 2025, audio-only is permitted if you’re capable of video, but the patient at home either can’t use video or doesn’t consent to it. For behavioral health services, audio-only is fully permissible when the patient is at home. 

This distinction matters for compliance. You can’t default to audio-only simply because it’s easier—the patient must be incapable of video or actively refuse it. 

The Documentation Challenge: Virtual Supervision 

One of the most complex topics is virtual direct supervision. Medicare permanently revised the definition of direct supervision to allow supervising physicians or practitioners to provide supervision through virtual presence using real-time audio-visual interactive telecommunications—but only for services without a 010 or 090 global surgery indicator. 

This flexibility sounds simple, but it creates significant documentation requirements. The presentation outlines key documentation elements: 

• Identification of the Supervising Provider and their Credentials – Does each provider know who their supervising provider is on any given day? How can this information be verified? 

• Method of Supervision – Note that the supervision must be real-time audio-visual interactive telecommunications. What platform was used, and is it OCR-compliant? 

• Immediately Available – Documentation to demonstrate that the supervising provider was immediately available 

• Details of Involvement – When applicable 

The presentation emphasizes: “Be mindful of how this is documented!” Inadequate documentation of virtual supervision is a prime target for audits and could result in claim denials or recoupment demands. 

Teaching Physicians Get Permanent Virtual Presence 

Teaching physicians may now have virtual presence when billing for services involving residents in all teaching settings, but only when they provide the service virtually (for example, three-way telehealth visits with patient, resident, and teaching physician in separate locations). 

This creates new training opportunities for academic medical centers, but documentation is critical. Each record must clearly show who supervised, how they supervised, and their immediate availability. 

Place of Service Codes: A Simple But Critical Change 

Effective January 1, 2024 (yes, before the recent changes), Medicare introduced new place of service codes specifically for telehealth: 

• POS 02 – Telehealth Provided Other than in Patient’s Home: Use this when the patient isn’t at home during the telehealth visit. 

• POS 10 – Telehealth Provided in Patient’s Home: Use this when the patient is at home (not a hospital or facility, but a private residence). 

Using the wrong POS code may result in claim denials, so verify your billing staff understands the distinction and applies it correctly to every telehealth claim. 

Removed Frequency Limitations and Consent Requirements 

Medicare permanently removed telehealth frequency limitations on subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations. These changes allow more consistent telehealth monitoring without artificial frequency caps. 

For consent, Medicare requires consent for all services, including non-face-to-face services. You may obtain patient consent at the same time you initially provide the services. Medicare does not require direct supervision to get consent. In general, auxiliary personnel under general supervision of the billing practitioner can get patient consent for these services. The person receiving consent can be an employee, independent contractor, or leased employee of the billing practitioner. 

State Licensing Requirements 

All providers remain subject to state licensing requirements, with separate Medicare enrollment needed for each state. The pandemic’s interstate flexibility hasn’t been permanently extended. 

Government Shutdowns and Other Payers 

During government shutdowns, claims processing includes a 10-business-day hold, but because Medicare already operates under a 14-day payment floor, the impact should be minimal. Continue submitting claims, but expect payment delays. 

While the webinar focused on Medicare, remember that other insurers have their own policies. Although CPT designates codes for audio-visual and audio-only services, many insurers don’t recognize these codes. Confirm each insurer’s specific policies before assuming your Medicare-compliant approach works universally. 

What You Should Do Now 

The 2026 telehealth changes demand immediate action from practices: 

1. Audit your current telehealth services against the new restrictions. Are you providing services that are no longer permitted? 

2. Review your patient population geography. Are your patients in eligible areas for the services you’re providing? 

3. Examine your documentation processes for virtual supervision. Do your templates capture all required elements? 

4. Train your billing staff on the new POS codes and ensure they’re applied correctly. 

5. Verify your state licensure and Medicare enrollment for each state where you provide telehealth. 

6. Update your consent processes to ensure they meet current requirements. 

7. Check your technology platforms for OCR compliance and capability to provide required audio-video services. 

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The telehealth landscape in 2026 looks dramatically different from what providers experienced during the pandemic. While behavioral health providers enjoy expansive permanent flexibility, other specialties face significant restrictions—and some have lost telehealth access entirely. 

The responsibility for understanding and complying with these changes rests squarely with providers. Remaining current with updates and changes is not optional, and proper coding requires analysis of statutes, regulations, and carrier policies that may vary from payer to payer. 

The providers who will thrive in this new environment are those who approach these changes proactively, invest in understanding the nuances, and implement compliant processes before problems arise. Don’t wait for a denial or an audit to discover you’ve been providing services incorrectly for months. 

For detailed information on specific telehealth codes, coverage policies, and the complete Medicare telehealth service list, consult the CMS resources referenced in the presentation and available at cms.gov. 

Expert Insights from Our Billing Supervisor 

Tatyana Kantor, our Billing Department Supervisor, recently received clarification from CMS regarding cross-state telehealth billing scenarios. Here are her key insights that complement the information from our webinar: 

Q: If my practice is enrolled with a Medicare Administrative Contractor (MAC) in one state, do I need to enroll with a different MAC when providing Remote Patient Monitoring (RPM) or Chronic Care Management (CCM) services to patients in another state? 

According to CMS guidance, cross-state enrollment with a different MAC is typically not required for RPM/CCM services when you’re providing remote services to patients in another state. You should continue to bill the MAC where your practice is enrolled. However, you must ensure you’re licensed to provide services to patients in that state, as state licensure requirements always apply. 

Q: What Place of Service (POS) code should I use for RPM and CCM services when my patients are in assisted living facilities or nursing homes in another state? 

For RPM and CCM services specifically, you should use POS 11 (Office), which reflects your provider location—not the patient’s location. This is because RPM and CCM are remote services, and you’re not physically present at the facility. You may not use POS 13 (Assisted Living Facility) for RPM/CCM services, as POS 13 is reserved for face-to-face services provided at an assisted living facility. 

Q: What about telehealth visits for patients in assisted living facilities—which POS code applies? 

For telehealth visits (not RPM/CCM), use POS 02 (Telehealth) when the patient is at the assisted living facility. If the assisted living facility is considered the patient’s home, you may use POS 10 (Telehealth Provided in Patient’s Home) instead. The distinction matters for compliance, so verify how the facility is classified. 

Q: Where should I bill when providing services across state lines? 

Bill to the MAC where your practice is enrolled, regardless of where your patients are located (as long as you have appropriate state licensure). Your provider location determines which MAC processes your claims. For example, if your practice is enrolled with the New York MAC, you would continue billing there even when serving patients in New Jersey nursing homes or assisted living facilities. 

Important Reminder: While these guidelines provide clarity on cross-state billing scenarios, always maintain clear documentation of the services provided, time spent (for CCM), and device data (for RPM). If you have specific billing scenarios that don’t fit these general guidelines, contact your MAC directly for definitive guidance. 

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