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Beware of Imminent Lapse of Medicare Telehealth Flexibilities
While much attention has been focused on the potential for a federal government shutdown in recent days, health care providers should also be aware of the impact on Medicare telehealth reimbursement. Certain Medicare telehealth regulatory flexibilities that have been in place since the COVID-19 public health emergency could expire today (September 30, 2025) if Congress does not implement an extension amid ongoing discussions about government funding. While Congress has implemented multiple extensions of the flexibilities in recent years, which expanded Medicare fee-for-service reimbursement of telehealth services, it appears increasingly likely that they will expire for at least some period of time.
Among other things, that means Medicare telehealth services provided to patients in their homes would not be eligible for reimbursement in most geographic areas (i.e., Medicare’s geographic originating site restrictions would at least temporarily return for telehealth services). Medicare fee-for-service reimbursement for the services of some providers, such as occupational therapists, physical therapists, speech-language pathologists, and audiologists, would also be unavailable when provided via telehealth. There is a possibility that any extension implemented by Congress would include retroactive eligibility and reimbursement of services provided after the expiration of the flexibilities. However, providers should expect to experience at least some interruption to Medicare telehealth fee-for-service reimbursement if the flexibilities are allowed to expire.
Our Chambliss legal team continues to monitor the situation. Please contact Cal Marshall or your Chambliss relationship attorney if you have questions or need additional information concerning this issue.
