As we explained in our previous client alert, at the time the government shutdown ended, it was unclear whether Medicare telehealth services provided during that time (October 1 through November 12, 2025) would be reimbursed.
The Center for Medicare and Medicaid Services (CMS) has since issued updated guidance definitively stating that telehealth flexibilities will apply retroactively to all services provided as of October 1, 2025, as if there had not been a temporary lapse in the application of the telehealth flexibilities. These Medicare telehealth flexibilities will continue to be in place through January 30, 2026, unless a further extension is issued or legislation is passed which makes these flexibilities permanent.
It is important to note that these extended waivers apply exclusively to Medicare. Telehealth reimbursement policies under state Medicaid programs and commercial insurers may differ so practitioners should review applicable contracts and coverage guidelines. Additionally, this federal extension does not alter state licensure requirements governing telehealth practice.
Should you have any questions regarding this extension, please contact the authors, the Garfunkel Wild attorney with whom you regularly work, or email us at [email protected]
