Medicare and Medicaid Reimbursement for Telehealth Services

Medicare and Medicaid telehealth rules have changed several times since 2020, and 2026 brought more updates. This guide summarizes current telehealth reimbursement policy as of October 30, 2026, with a date attached to each rule.

Medicare sets one national framework. Medicaid works differently: each state designs its own telehealth program within federal rules. Both programs treat remote patient monitoring (RPM) as its own category, separate from telehealth visits.

A Timeline of Recent Telehealth Policy Changes

1. October 31, 2025: CMS released the CY 2026 Physician Fee Schedule (PFS) final rule, effective January 1, 2026. It made several telehealth policies permanent.
2. Fall 2025: Medicare telehealth flexibilities lapsed briefly starting October 1, 2025. CMS later stated it will pay telehealth claims for that period as it did before October 1, 2025.
3. Early 2026: The Consolidated Appropriations Act, 2026 extended many Medicare telehealth flexibilities through December 31, 2027. HHS updated its telehealth policy page on February 5, 2026.
4. July 14, 2026: CMS released the CY 2027 PFS proposed rule. Comments closed September 14, 2026.
5. October 8, 2026: CMS posted its most recent telehealth FAQ, which reflects the extension through 2027.

As of October 30, 2026, the CY 2027 PFS final rule has not been published. Proposed policies may change before they take effect.

Medicare Telehealth Flexibilities Through December 31, 2027

According to the CMS telehealth FAQ (updated October 8, 2026), these Medicare flexibilities apply through December 31, 2027.

Patients Can Be Seen at Home, Anywhere in the U.S.

Through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and its territories. That includes the patient’s home. There is no rural requirement during this period.

Starting January 1, 2028, the older rules return for most services. Patients would generally need to be in a medical facility in a rural area. Behavioral health is the main exception, covered below.

Audio-Only Visits

Through December 31, 2027, beneficiaries may receive audio-only telehealth services at home. CMS states this applies to both new and established patients.

Starting January 1, 2028, audio-only care at home is limited to behavioral health. It is allowed when the practitioner can offer video, but the patient cannot use it or does not consent to it.

Expanded Practitioner Types

Through December 31, 2027, physical therapists, occupational therapists, speech-language pathologists, and audiologists can furnish Medicare telehealth services. Starting January 1, 2028, these four practitioner types can no longer do so under current law.

Hospitals can also bill through December 31, 2027 for certain services their staff provide remotely to patients at home. These include outpatient therapy, diabetes self-management training, and medical nutrition therapy.

FQHCs and RHCs

Federally qualified health centers (FQHCs) and rural health clinics (RHCs) can bill non-behavioral telehealth services through December 31, 2027. Billing changed mid-year:

• Through September 30, 2026, these clinics reported HCPCS code G2025.
• Starting October 1, 2026, they bill the individual CPT or HCPCS code with the appropriate telehealth modifier.

Behavioral health telehealth at FQHCs and RHCs is paid under the RHC all-inclusive rate or FQHC prospective payment system.

In-Person Requirements for Mental Health Telehealth

Federal law requires an in-person visit within six months before a patient’s first mental health telehealth service. That requirement is delayed until after December 31, 2027.

CMS says patients who start mental health telehealth at home on or before December 31, 2027 will be treated as established. After that date, they need at least one in-person visit every 12 months, with limited exceptions.

Permanent Changes in Medicare Telehealth Policy

Some policies no longer depend on an expiration date. These come from the CY 2026 PFS final rule (effective January 1, 2026) and earlier law.

1. Behavioral health at home. The Consolidated Appropriations Act, 2021 permanently removed geographic and site restrictions for behavioral health telehealth.
2. Virtual direct supervision. Since January 1, 2026, direct supervision can be met through real-time audio and video (not audio-only). This excludes services with a 010 or 090 global surgery indicator.
3. Teaching physicians. Since January 1, 2026, teaching physicians may be virtually present in all teaching settings, but only when the service itself is furnished via telehealth.
4. Frequency limits. Telehealth frequency limits on subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations were permanently removed as of January 1, 2026.
5. Telehealth list process. CMS simplified how services are added to the Medicare Telehealth Services List starting with CY 2026.

Billing Details for 2026 and 2027

• Place of service. CMS directs practitioners to use POS 10 for telehealth in the patient’s home and POS 02 for telehealth elsewhere. Since January 1, 2024, home telehealth claims are paid at the non-facility rate.
• New modifiers. Beginning January 1, 2027, CMS requires modifiers BB and BC on applicable telehealth claims. BB applies to services furnished through a contracted or paid virtual platform. BC applies to telehealth furnished incident to a practitioner’s service. CMS states these modifiers have no payment implications.
• Practitioner home address. Practitioners with a physical practice location can furnish telehealth from home without enrolling their home address. Virtual-only practitioners must enroll their home address, with an option to suppress it from public profiles.

One related date falls outside CMS. The DEA and HHS extended telemedicine flexibilities for prescribing controlled substances through December 31, 2026. Practices that prescribe controlled substances via telehealth should watch for DEA updates before year end.

How Remote Patient Monitoring Fits Into Telehealth Reimbursement Policy

Remote patient monitoring sits outside the Medicare telehealth rules. The CMS FAQ explains that remote monitoring, chronic care management, and similar non-face-to-face services are not substitutes for in-person visits. The telehealth restrictions, including the 2028 location rules, do not apply to them.

The CMS Telehealth and Remote Monitoring booklet (MLN901705, December 2025) lists core RPM requirements:

• An established patient relationship is required for RPM.
• Data must be collected for 2 to 15 or 16 or more days in a 30-day period, depending on the code.
• Only one practitioner may bill RPM for a patient in a 30-day period.
• RPM and remote therapeutic monitoring (RTM) cannot be billed together.
• Patient consent is required when RPM services are provided.

For 2026, CPT added code 99445 for 2 to 15 days of device readings and code 99470 for the first 10 minutes of treatment management. Our guide to CPT 99445 explains how the shorter monitoring window works. For therapy and musculoskeletal programs, see our overview of RTM codes.

What CMS Proposed for 2027

The CY 2027 proposed rule (July 14, 2026) includes several RPM and RTM proposals:

1. RTM would be limited to established patients.
2. Practitioners would need to furnish a separately reportable initiating visit tied to the start of RPM or RTM.
3. Payment would apply only when clinical staff employed by the practice perform the services.
4. CMS asked for comment on bundling RPM and RTM codes into four new HCPCS G-codes.

These are proposals, not final policy. Practices should review the final rule once CMS publishes it.

Medicaid Telehealth Varies by State

Medicaid telehealth follows a different model. According to Medicaid.gov, states have broad flexibility to design telehealth delivery for most Medicaid benefits. Services must still meet federal requirements and the state plan.

Payment rules depend on each state’s choices:

• A state that pays telehealth at the same rate as in-person care generally does not need a separate state plan amendment (SPA).
• A state that pays telehealth differently must submit a reimbursement SPA.
• States decide whether audio-only counts as telehealth and which providers and sites qualify.

CMS also maintains a State Medicaid and CHIP Telehealth Toolkit, updated February 2024.

For state-by-state detail, the Center for Connected Health Policy tracks Medicaid telehealth rules. Its current summaries note that every state offers some live video reimbursement in Medicaid. CCHP also reports that a little over half of state Medicaid programs reimburse RPM, often with limits. Common limits include restricting billing to home health agencies, covering only certain conditions, and limiting device types.

Before starting a Medicaid telehealth or RPM program, practices can check these points with their state:

1. Which services and provider types are eligible.
2. Whether the patient’s home qualifies as an originating site.
3. Whether audio-only visits are covered.
4. Whether payment matches in-person rates.
5. Which conditions and devices qualify for RPM.
6. How Medicaid managed care plans in the state handle each item.

Keeping Telehealth and Monitoring Workflows Simple

Policy changes are easier to absorb when readings appear where care teams already document care.

Tenovi partners with eClinicalWorks (eCW). Readings flow through the Tenovi Cloud into the eCW dashboard and patient record. Staff review trends and act on them without switching systems or re-keying data. That keeps documentation in one place when a payer asks for proof of data days or management time. Our post on EHR integration covers this workflow in more detail.

Frequently Asked Questions About Medicare and Medicaid Telehealth

This section answers common questions about Medicare and Medicaid telehealth as of October 30, 2026. Dates reflect CMS, HHS, and Medicaid.gov guidance available at that time.

1) How long do the Medicare telehealth flexibilities last?

Under current law, most Medicare telehealth flexibilities run through December 31, 2027. These include home-based care anywhere in the U.S., audio-only visits at home, and expanded practitioner types. Starting January 1, 2028, many services would return to rural and facility-based rules unless Congress acts again.

2) Is behavioral health telehealth at home permanent?

Yes. The Consolidated Appropriations Act, 2021 permanently removed geographic and site restrictions for behavioral health telehealth. The in-person visit requirement for mental health telehealth is delayed until after December 31, 2027.

3) Does remote patient monitoring count as telehealth under Medicare?

No. CMS treats remote monitoring as a non-face-to-face service, not a substitute for an in-person visit. The Medicare telehealth location and practitioner rules do not apply to RPM. RPM has its own requirements, including patient consent and data collection thresholds.

4) Does Medicaid cover telehealth in every state?

Every state Medicaid program offers some form of live video reimbursement, according to the Center for Connected Health Policy. Details vary by state, including eligible services, provider types, audio-only coverage, and payment rates. Practices should confirm rules with their state Medicaid agency and managed care plans.

5) What telehealth billing changes take effect in 2027?

Beginning January 1, 2027, CMS requires modifiers BB and BC on applicable telehealth claims, with no payment implications. CMS also proposed RPM and RTM changes for 2027 on July 14, 2026. Those proposals are not final as of October 30, 2026.

6) Can FQHCs and RHCs still bill for telehealth?

Yes. FQHCs and RHCs can bill non-behavioral telehealth services through December 31, 2027. Since October 1, 2026, they bill the individual service code with a telehealth modifier instead of G2025. Behavioral health telehealth is paid under each clinic’s standard payment method.

Understanding Medicare and Medicaid Telehealth

Medicare and Medicaid telehealth policy now runs on a few key dates. Most Medicare flexibilities last through December 31, 2027. Behavioral health at home, virtual direct supervision, and removed frequency limits are permanent. New telehealth modifiers start January 1, 2027, and proposed RPM changes await a final rule. Medicaid remains state-driven, so each program’s rules need a direct check. Remote patient monitoring follows its own requirements, which gives care teams a steady way to support patients between visits.

Tenovi provides remote monitoring infrastructure with 60+ cellular-connected devices, delivered through the Tenovi Gateway or SIM-embedded devices. Patients need no apps, no syncing, and no Wi-Fi. Providers work with one partner and one API, and we handle fulfillment, provisioning and support. Contact us for a free demo and consultation.

This article is for informational purposes only and is not billing, coding, or legal advice. Coverage, codes, and payment rates vary by payer and change over time. The billing provider is responsible for verifying current requirements, documenting medical necessity, and submitting accurate claims. CPT® is a registered trademark of the American Medical Association.