In this article:

• Telehealth and Extended Flexibilites – Feb, 2026
• Telehealth Prior to the Pandemic
• Current Telehealth Rules
• Important Details (modifiers, frequency, teaching physicians, and more)
• RHCs and FQHCs
• Place of Serivce
• CPT® Codes for Telehealth
• Is it or isn’t it a Telehealth Service
• Communication-Based Technology Services

Telehealth Flexibilities Extended Until Dec. 31, 2027!

Date of article: 2/5/2026

• Congress passed another “keep the government funded” bill but in this one, telehealth flexibilities are extended until the end of 2027, almost two years.
• Telehealth as we know it today started with two CMS rules in March and April 2020 in response to the Covid-19 pandemic and these rules allowed for telehealth anywhere in the country while patients where at home.
• Since then, Medicare telehealth has been scheduled to “end” “expire” and Congress has passed multiple extensions; and CMS has revised the telehealth rules in most of the Physician Fee Schedule rules since then.
• CMS has made some—but not all—changes permanent; CMS states it lacks the authority to permanently change the telehealth rules to the current situation because that requires an Act of Congress.
• Citations at the end of the article.

Types of telehealth Services Allowed In All Geographic Areas, Not Effected By The Pandemic Or Flexibilities

• Home dialysis for ESRD patients undergoing home dialysis
• Diagnosis and treatment for acute stroke
• Treatment of substance use disorders
• Diagnosis and treatment of behavioral health disorders (more about this below)

Prior To The Pandemic

For an historical perspective prior to the pandemic, there were restrictions on telehealth. When CMS discusses flexibilities they are referring to any restriction on location (among many others listed below). Before the pandemic, the patient could not receive telehealth in their homes, unless for the above stated carve-outs. They needed to live in an underserved geographic area and go to an originating site (a hospital or clinic) to receive services. A patient might be seen in an Emergency Department in a rural area and need a consultation from a specialist in a tertiary care center. The ED would serve as the originating site and the specialist would perform the service in a distant site.

“An originating site is the location where a Medicare beneficiary gets physician or practitioner medical services through a telecommunications system. The beneficiary must go to the originating site for the services located in either:

• A county outside a Metropolitan Statistical Area (MSA)
• A rural Health Professional Shortage Area (HPSA) in a rural census tract”

After the declaration of the PHE, patients could receive telehealth services in their home located in any geographic location within the US and its territories.

Information about Health Professional Shortage Areas is found at https://data.hrsa.gov/tools/medicare/telehealth

There were also frequency limitations on the number of subsequent hospital, nursing facility services and critical care visits that could be performed via telehealth. Recall that before the pandemic, physical therapists, occupational therapists, speech language pathologists and audiologists could not perform via any services via telehealth for Medicare beneficiaries.

Current Telehealth Rule (Aka “Flexibilities” By CMS) All Continued Through Dec. 31, 2027

• Removing geographic requirements and expanding originating sites: The patient doesn’t need to be in an underserved area and can receive telehealth in their home.
• Expanding practitioners eligible to furnish telehealth services: Physical Therapists, Occupational Therapists,  Speech Language Pathologists and Audiologists can continue to perform services via telehealth. They join these professionals who are eligible telehealth providers:  Physicians, Physician assistants, Nurse practitioners, Clinical nurse specialists, Clinical psychologists, Clinical social workers, Registered dietitians or nutrition professionals, Certified registered nurse anesthetists, Marriage and family therapists, Mental health counselors. This extends to Hospital Outpatient Departments (HOPDs)  and that PT, OT, SLP and audiology services are reported on the UB-04 but payment is factored via MPFS, thus aligning continued eligibility and billing from a hospital/facility site, since some of these services are on the Medicare telehealth list.
• Extending Telehealth services for FQHCs and RHCs: May continue to perform services including mental health services via telehealth.
• Delaying the in-person requirements under Medicare for mental health furnished through telehealth and telecommunications technology.  Delayed until Jan 1, 2028.  More about behavioral health below.
• Allowing for furnishing of audio-only telehealth services: Continues to be allowed if the practitioner has the capability for audio/visual real time communication but the patient does not or prefers not to use it. Document the patient’s wishes in the note for that encounter.
• Extending use of telehealth to conduct face-to-face encounter prior to recertification or eligibility for hospice care.
• Requiring the use of modifiers for telehealth services in certain instances. Continue to use modifiers, as described below.
• GPCI floor of 1, extended until the end of 2026.

Important Details

Professionals providing telehealth from their home

Professionals may continue to report telehealth services from their home. CMS allows those professionals to use the practice address to report services (or the address that goes into Box 32 on the CMS 1500). The MLN Matters article (MLN901705, Dec. 2025) has instructions on how to suppress the home address in the PECOS system. The November 2025 FAQ states that professionals who have a physical practice location but are performing services from home may use their practice location as the address. If their only location is their home, they will need to enroll their home address as a practice location.

Two-way interactive real-time technology and audio only

A practitioner must use two-way interactive, real-time technology for telehealth. Audio only is permitted if the practitioner has the capability for that service but the patient doesn’t have access to that technology or doesn’t consent to using it.

Modifiers

• Modifier 93 Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System
• Modifier 95 Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System
• Modifier GT is used by distant site practitioners billing telehealth under the CAH Optional Payment Method II, on institutional claims.
• Modifier GQ (audio only) is for FQHCs and RHCs to use for Audio-Only.
• Modifier FQ is for behavioral health telemedicine services

Frequency limitations permanently removed

• Subsequent inpatient visits (CPT® codes 99231, 99232, and 99233)
• Subsequent nursing facility visits (CPT® codes 99307, 99308, 99309, and 99310)
• Critical care consultations (HCPCS codes G0508 and G0509) CPT® codes 99291 and 99292 never had frequency limitations

Supervision by Teaching Physicians

Teaching physicians may permanently have virtual presence when billing for services provided involving residents in all teaching settings but only in clinical situations when they provide the service virtually (for example, a 3-way telehealth visit with the patient, resident, and teaching physician in separate locations)

The MLN Matters Citation booklet describes this permanent change:

“Teaching physicians may permanently have virtual presence when billing for services provided involving residents in all teaching settings but only in clinical situations when they provide the service virtually (for example, a 3-way telehealth visit with the patient, resident, and teaching physician in separate locations).”

Teaching physicians may no longer provide supervision virtually except if the patient, resident, and attending are all in a different location. This returns E/M services to the prior rule The teaching physician must personally perform the key and critical components of the service or be present when these were performed.

RHCs and FQHCs

These entities may continue to provide telehealth services through December 31, 2026 for medical services. (Behavioral health discussed separately.) Report HCPCS code G2025 on the claim form.  The patient may continue to be at home in any geographic areas.

Behavioral health via two-way, real-time audio/visual communication and audio only communication is permanent, based on a law Congress passed in 2023 and isn’t affected by the current extension, except for the delay in the in-person requirement, listed below. For audio only services, the practitioner must have the capability for audio/visual but the patient either doesn’t have the capability or prefers to do audio only.  Behavioral health telehealth services may continue to be billed by physicians, behavioral health practitioners and practitioners in RHCs and FQHCs.

CMS discusses the requirement for an in person visit for audio only behavioral health (which is currently delayed).  The language below is to be updated (by CMS) to reflect the December 31, 2027 delay.

• In-person behavioral health visit requirement. An in-person visit within six months of an initial Medicare behavioral/mental telehealth service, and annually thereafter, is not required through September 30, 2025. For FQHCs and RHCs, the in-person visit requirement for mental health services furnished via communication technology to beneficiaries in their homes is not required until January 1, 2026.
• The above quote notes the difference for RHCs and FQHCs, which aren’t required to have the in person visit within 6 months of initiating telehealth for behavioral health. This is not for established patients receiving behavioral health via telehealth; notice CMS says “of an initial Medicare behavioral/mental telehealth service.”

Place of Service Codes

Use one of these place of service codes:

POS 02 for Telehealth Provided Other than in Patient’s Home

The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health-related services through telecommunication technology. (Effective 1/1/17)

POS 10 for Telehealth Provided in Patient’s Home

The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology. (Effective 1/1/22)

Although the CPT® books notes that POS 10 was effective at the start of 2022, CMS made it effective on January 1, 2024.

What about a patient in their car?  Use POS 10

From the 2023 Final Rule, p. 193.

“We remind readers that we defined “home” in our CY 2022 PFS final rule (86 FR 65059) to include, as: “both in general and for this purpose, a beneficiary’s home can include temporary lodging, such as hotels and homeless shelters. We also clarified that for circumstances where the patient, for privacy or other personal reasons, chooses to travel a short distance from the exact home location during a telehealth service, the service is still considered to be furnished ‘in the home of an individual’ for purposes of section 1834(m)(4)(C)(ii)(X) of the Act.”

CPT® Codes for Telehealth

CPT® added 17 new CPT® codes for audio only, audio/visual visits, in code range 98000–98016. These are divided into new and established patient visits and with either time or MDM definitions. The bad news: CMS assigned 16 of these an invalid status indicator. That means, CMS will not recognize or pay for the new CPT® telehealth codes. Only one of the code, 98016, has an active status indicator in the fee schedule. It replaced G2012.  98016 is for a brief, technology check-in.

Appendix P in the CPT® books lists codes that may be performed via telehealth using synchronous, real-time, interactive audio-video services.  These are also indicated with a star in the main body of CPT®.  Office visits were removed from this list in the 2025 CPT® book, because CPT® added specific telehealth codes.

Appendix T in the CPT® book lists codes that may be performed via audio-only technology. There is a symbol that looks like a speaker to indicate those in the main body of CPT®.

Is it or isn’t it a Telehealth Service?

• Many payers and practices use the broad term telehealth to describe services that are not done face-to-face with a patient
• CMS describes telehealth services as non-face-to-face services that are on its telehealth list

There are two sets of lists for telehealth: CMS’s list of telehealth services and The AMA’s list of CPT® codes that could be reported via telehealth, in Appendix P of the CPT® book. Both CMS and CPT® defined telehealth as using a real-time, interactive audio and video communication system, which uses modifier 95. CPT® defined modifier 95 as “synchronous telemedicine service rendered via a real-time audio and visual telecommunications system.”  CMS’s list includes HCPCS codes.

In the updated Nov. 14, 2026 FAQ CMS asks why non-face-to-face services like care management, remote monitoring and community health integration aren’t on the telehealth list. Their answer is that Medicare telehealth services are services that “are in whole or in part, an inherently face-to-face service. Services that do not serve as a substitute for an in-person encounter are not subject to the rules that apply to Medicare telehealth services.” That is, since care management services are not defined as face-to-face services, performing them is not considered telehealth.

Communication-Based Technology Services (CBTS)—Also Not telehealth

CMS began paying for services that used communication technology, but didn’t meet the criteria of telehealth. The patient wasn’t required to be in an underserved area and there was no requirement for real-time audio and visual communication. These included the brief virtual check-in HCPCS codes G2010 and G2012, and on-line digital E/M, 99421—99423. These are not on the telehealth list, are not considered to be telehealth services and do not require modifier 95.

Citations:

MedLearn Matters MLN901705 December 2025

https://www.cms.gov/files/document/telehealth-faq-updated-11-26-2025.pdf