Alert
Be Prepared for Important 2026 Proposed Changes to Medicare Telehealth Policy
The Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule, outlining updates to telehealth policies aimed at streamlining access and supporting care delivery, especially in rural and underserved communities.
These proposed changes reflect CMS’s commitment to expanding telehealth access, particularly behavioral health services, while balancing oversight and quality of care.
Key Proposals
PFS proposed rule key proposals include:
- Elimination of Provisional vs. Permanent Distinction. CMS proposes to remove the distinction between provisional and permanent telehealth services. Instead, the focus would be on whether a service can be furnished safely via interactive, two-way audio-video technology, simplifying the process for adding services to the Medicare Telehealth Services List.
- Removal of Frequency Limits. Frequency limitations on subsequent inpatient visits, nursing facility visits, and critical care consultations—CPT codes 99231–99233, 99307–99310, G0508 and G0509—would be permanently removed, allowing more flexible use of telehealth for these services.
- Virtual Direct Supervision. CMS proposes to permanently allow physicians and supervising practitioners to provide required direct supervision through real-time audio and video interactive telecommunications, excluding audio-only.
- Teaching Physician Presence. The rule proposes reverting to pre-pandemic policy, requiring teaching physicians to maintain physical presence during critical portions of resident-furnished services, except in certain rural areas.
- Digital Mental Health Treatment (DMHT) and Digital Therapeutics (DTx) Expansion. CMS proposes expanding DMHT coverage to include FDA-authorized DTx for conditions such as ADHD.
- Originating Site Facility Fee Increase (Q3014). The telehealth originating site facility fee, HCPCS Q3014, would increase to approximately $31.85 in CY 2026, reflecting a 2.7% inflationary update.
- Telehealth Services List. Providers must continue using standard E/M codes with modifiers for telehealth billing, noting there were no plans to add the telemedicine E/M codes 98000–98015 to the list.
Telehealth Access for FQHCs and RHCs
Additional proposals related to Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are as follows.
- RHCs and FQHCs would be able to bill for non-behavioral health telehealth services using code G2025, payment for a telehealth distant site by a RHC or FQHC, through December 31, 2026.
- CMS proposes to permanently allow for direct supervision utilizing audio and visual telecommunications in the RHC and FQHC setting.
Implications
By removing certain limitations and allowing virtual supervision, CMS aims to reduce barriers for providers and patients alike. The permanent allowance of audio-only behavioral health telehealth services and expanded billing options for FQHCs and RHCs further support care in rural and underserved areas.
In many respects, CMS’s 2026 proposed changes to Medicare telehealth policy are beneficial to providers and patients; however, if they go into effect as proposed, there are aspects for which you’ll want to ensure systems and processes are in place to meet requirements. For instance, surrounding teaching physician presence.
What you can do now to proactively prepare:
- Closely monitor for notice of CMS finalizing the rule.
- Consider needed policy and process changes to ensure your organization is prepared on January 1, 2026, to implement needed changes. This could include updating policy and procedure documents, system configuration updates, and training.
You can also visit the CMS fact sheet on the CY 2026 Medicare PFS proposed rule for more details.
We’re Here to Help
For more information on operations, compliance, and coding compliance related to telehealth for your health care organization, contact your firm professional.