The Expiring Telehealth Flexibilities: A Recap

Throughout the COVID-19 pandemic, temporary waivers expanded telehealth access, allowing for broader coverage of services delivered remotely, including audio-only visits and relaxed geographic restrictions. These flexibilities were intended to ensure continuity of care during a public health crisis. However, without Congressional intervention, these provisions lapsed on October 1, 2025, creating what many in the industry have termed a “telehealth cliff.”

Impact on Medicare Claims

The Centers for Medicare & Medicaid Services (CMS) initially issued guidance that appeared to halt all Medicare payments for telehealth services affected by the expired provisions. However, this direction was quickly revised. CMS now states it will continue processing and paying held claims, with exceptions for certain impacted services. This shift, while offering some relief, has introduced further confusion, particularly regarding its consistency with instructions given to MACs to temporarily hold affected claims.

ATA Urges Immediate Action

On October 14, the American Telemedicine Association (ATA) released a statement demanding a swift, short-term solution from Congress and the administration. The ATA emphasized the potential for widespread disruption to patient care, as commercial insurers often mirror Medicare’s coverage decisions. The association argues that a prolonged period of uncertainty will inevitably lead to reduced access to vital telehealth services.

CMS Guidance and Claim Holds

CMS published an MLN Connects Newsletter Update on October 15, instructing MACs to temporarily hold claims with dates of service on or after October 1, 2025, that are impacted by the expired telehealth flexibilities. While claims are being held rather than immediately denied, providers should be aware that payment remains contingent on future legislative or administrative action. CMS also recommends that practitioners inform beneficiaries of potential non-coverage through an Advance Beneficiary Notice of Noncoverage.

The agency indicated it would continue to process and pay held claims, except for select services. The scope of this exception remains unclear, adding to the existing ambiguity.

What does this evolving situation mean for the long-term viability of telehealth as a core component of the healthcare system? And how can providers navigate these uncertain waters to ensure continued access to care for their patients?

Frequently Asked Questions About Telehealth Reimbursement

• What is the current status of telehealth reimbursement following the expiration of the flexibilities?

  Currently, Medicare is temporarily holding claims impacted by the expired flexibilities, but payment is not guaranteed. The situation is fluid and dependent on Congressional action or further administrative guidance.

• Will commercial insurers follow Medicare’s lead regarding telehealth coverage?

  Many commercial insurers base their coverage policies on Medicare guidelines, so the expiration of the flexibilities could lead to reduced coverage across the healthcare market.

• What should telehealth providers do with claims submitted after October 1, 2025?

  Providers can continue submitting claims, but payment will be held until the situation is resolved. CMS recommends providing beneficiaries with an Advance Beneficiary Notice of Noncoverage.

• What is an Advance Beneficiary Notice of Noncoverage?

  This notice informs Medicare beneficiaries that certain services may not be covered by Medicare, allowing them to make informed decisions about their care.

• What role is the American Telemedicine Association playing in addressing this issue?

  The ATA is actively advocating for a short-term solution to restore telehealth flexibilities and prevent disruption to patient care.