Introduction
The COVID-19 pandemic accelerated the adoption of telehealth across the U.S., with emergency waivers and flexibilities allowing providers to care for patients virtually without the usual restrictions. For years, these temporary rules gave practices more freedom in delivering care, billing, and expanding access.
But as of September 30, 2025, telehealth flexibilities have officially expired. This shift leaves many providers asking the same question: Now what?
In this blog, we’ll break down what the expiration means for healthcare organizations, what changes to expect in billing and compliance, and how your practice can adapt to this “new normal.”
What Were Telehealth Flexibilities?
Telehealth flexibilities, introduced during the Public Health Emergency (PHE), temporarily removed barriers to virtual care. These included:
- Expanded patient locations – Patients could access telehealth from their homes instead of traveling to an originating site.
- Broader provider eligibility – More provider types could bill for telehealth services.
- Audio-only visits – Coverage extended to telephone visits for patients without video capability.
- Cross-state licensure allowances – Many states permitted providers to deliver care across state lines.
- Parity in reimbursement – Telehealth visits were reimbursed at the same rate as in-person visits.
With the expiration, many of these allowances are no longer in place.
What Changes With the Expiration of Telehealth Waivers?
1. Patient Location Restrictions Return
Patients may once again need to travel to an approved originating site (such as a clinic or hospital) for telehealth services, depending on payer rules.
2. Audio-Only Coverage Scales Back
Audio-only visits may no longer be reimbursable for many specialties, particularly under Medicare.
3. Provider Eligibility Tightens
Only certain provider types may now bill for telehealth services, as defined by CMS and commercial payers.
4. Licensure Requirements Reinforced
Providers must comply with state licensure laws, limiting cross-state telehealth unless part of an interstate compact.
5. Payment Reductions Possible
Some services may see reduced reimbursement compared to in-person visits, impacting revenue if practices rely heavily on telehealth.
How Should Your Practice Prepare?
The expiration of flexibilities doesn’t mean telehealth is gone—but it does mean adapting to new compliance, billing, and operational realities. Here are steps your practice can take:
1. Review Payer Policies
Not all payers are treating telehealth the same. Check CMS, Medicaid, and commercial payer rules to understand what’s still covered.
2. Update Documentation & Coding Practices
Ensure your billing team is using the correct CPT® codes, modifiers, and place-of-service codes for telehealth encounters. Errors could increase denials and slow down cash flow.
3. Evaluate Patient Access
With originating site requirements back in place, determine how these changes affect your patient population. Will patients still choose telehealth if it means traveling to a facility?
4. Train Staff and Providers
Educate clinical and administrative staff on compliance changes, scheduling workflows, and billing updates.
5. Explore Hybrid Care Models
Telehealth is still a valuable tool—but it may need to be combined with in-person care. Hybrid models can improve access while staying compliant.
The Future of Telehealth: Beyond Flexibilities
While federal flexibilities have expired, some states and commercial payers continue to support telehealth innovation. Healthcare practices should expect an evolving landscape where telehealth remains part of care delivery, but under stricter rules and oversight.
The organizations that succeed will be those that:
- Stay compliant with payer requirements
- Embrace hybrid care models
- Leverage technology strategically
- Maintain strong revenue cycle processes
Final Thoughts
The end of telehealth flexibilities is a major transition point for providers and patients alike. For healthcare organizations, this means reassessing workflows, billing, and compliance strategies to remain successful in a more regulated telehealth environment. While approximately 90% of traditional Medicare patients will lose access to telehealth benefits, please keep in mind these changes will affect CMS (Centers for Medicare and Medicaid Services). As for commercial insurers (this includes Medicare Advantage plans), there hasn’t been any official communication or documentation released with specific Telehealth policies. Best way forward is to stay informed and review your state regulations to include the guidance shared by the individual commercial payers.
For access to a complete guide to current Telehealth regulations visit: MLN901705 – Telehealth & Remote Patient Monitoring
For the CMS Telehealth Factsheet visit: CMS.gov
At Medcycle Solutions, we help practices navigate these changes—ensuring accurate billing, optimized reimbursement, and a streamlined revenue cycle.