If there’s one thing telehealth billing has taught revenue cycle teams over the past several years, it’s that “current rules” is a moving target. Medicare telehealth reimbursement has been extended, allowed to lapse, and re-extended on a recurring basis since the pandemic-era flexibilities were first put in place, and 2026 has already delivered another round of exactly that pattern. Any billing guidance on this topic needs a firm date stamp, because a post written in early 2025 describing telehealth rules as settled would already have been proven wrong twice over by the time this one was written.
What Actually Happened With the Telehealth Deadlines
Coming into late 2025, Medicare’s telehealth flexibilities were once again facing a scheduled expiration tied to a government funding deadline — a now-familiar pattern where these flexibilities get extended in short bursts attached to continuing resolutions and appropriations bills rather than through standalone permanent legislation. A government shutdown in the fall of 2025 briefly put telehealth billing into real limbo, with reports of telehealth utilization dropping sharply during the lapse period as practices and patients weren’t sure what would be reimbursed. When the shutdown ended, Congress extended the flexibilities on a short-term basis through January 30, 2026 — another cliff, not a resolution.
That January 30 deadline was then addressed through the Consolidated Appropriations Act of 2026, signed in early February 2026, which extended most Medicare telehealth flexibilities considerably further than the prior short-term patches — through December 31, 2027. As of this writing in September 2026, that is the operative deadline, and it’s the most durable extension telehealth billing has had in some time. That said, given the repeated pattern of last-minute, short-term extensions over the preceding several years, practices should treat “through 2027” as the current legal reality rather than as a guarantee that no further legislative action will be needed before then — this is a policy area that has surprised billing teams before.
What’s Reimbursable Under the Current Rules
Under the flexibilities currently in effect through the end of 2027, several of the pandemic-era expansions that many practices now consider standard remain in place:
- Geographic and originating site flexibility: The requirement that a Medicare telehealth patient be located in a rural area, and that they be located at an approved originating site facility rather than at home, has been waived for a broad range of services — patients can generally receive covered telehealth services from home, regardless of geographic location, rather than needing to travel to a clinic or facility to originate the telehealth encounter.
- Audio-only services: Audio-only telehealth remains billable for many services under the current extension, which matters considerably for behavioral health specifically, where a substantial share of patients either lack reliable video access or have a clinical reason to prefer a phone-only encounter.
- Expanded practitioner and site eligibility: Physical therapists, occupational therapists, speech-language pathologists, and audiologists have gained the ability to bill Medicare for telehealth services delivered within their scope of practice — a change that had previously been unavailable to these disciplines under Medicare telehealth policy. Federally Qualified Health Centers and Rural Health Clinics have also gained expanded ability to serve as the distant site (the location of the billing provider) for telehealth encounters.
- Place of service coding: The prevailing convention uses POS 02 for telehealth provided to a patient outside their home and POS 10 for telehealth provided to a patient in their home, with home telehealth generally paid at the non-facility rate rather than the reduced facility rate. Getting this distinction right on every claim matters directly for correct payment, and it’s exactly the kind of detail worth double-checking against a current modifier and place-of-service reference rather than relying on memory, since these codes and their associated payment implications have shifted more than once in recent years.
What’s Genuinely Uncertain or Time-Limited
Being honest about the limits of this extension matters more than presenting a clean, settled picture. A few things billing teams should track rather than assume:
- Behavioral health telehealth flexibilities have generally been placed on more permanent footing than flexibilities for other specialties, including some geographic and place-of-service restrictions being removed on a lasting basis rather than tied to the same recurring deadline — but confirming this against current guidance for a specific service type is worth doing rather than assuming every behavioral health telehealth rule is permanent.
- The audio-only allowance is broad through the current extension period, but guidance describes it narrowing after the extension period ends, generally back toward being available mainly for behavioral health services where video isn’t feasible, rather than remaining available across the board.
- DEA rules governing telemedicine prescribing of controlled substances are a separate regulatory track from CMS’s Medicare telehealth payment rules, and have their own history of temporary extensions and rulemaking activity distinct from the appropriations-driven Medicare deadlines described above. A practice prescribing controlled substances via telehealth should confirm current DEA telemedicine prescribing rules specifically, rather than assuming Medicare’s payment extension automatically covers prescribing authority as well — these are genuinely different rules enforced by different agencies.
- Commercial payer telehealth policy doesn’t automatically track Medicare’s. Some commercial and Medicaid plans made their pandemic-era telehealth expansions permanent well before Medicare’s own flexibilities were extended this far; others still tie their telehealth coverage to Medicare’s rules by reference, which means a further Medicare change could still ripple into commercial claims processing depending on the plan.
A Practical Note From Billing Teams
Practices that lived through the late-2025 shutdown period reported a specific, painful pattern: claims for telehealth services delivered during the lapse were held or denied by Medicare Administrative Contractors while the legislative situation was unresolved, then needed to be reprocessed once the retroactive extension was signed. The practical lesson billing teams took from that experience wasn’t about the substance of the rules at all — it was to hold or closely track telehealth claims during any period where an extension deadline is actively pending in Congress, rather than assuming continued payment, and to be prepared to resubmit or follow up once a resolution passes, since retroactive extensions have consistently been the pattern rather than a true lapse in coverage for services already delivered.
Practical Takeaway
As of September 2026, Medicare telehealth flexibilities — expanded originating sites, audio-only coverage, and broadened practitioner eligibility — are extended through December 31, 2027 under the Consolidated Appropriations Act of 2026. Treat that date as the current, reliable rule, but keep watching for legislative activity as it approaches, since this policy area has repeatedly been resolved at the last minute rather than well ahead of its deadlines, and confirm commercial payer and DEA prescribing rules separately rather than assuming they move in lockstep with Medicare’s payment policy.