Telehealth in 2026: What Providers Should Review Before CMS Releases Findings

Telehealth flexibilities remain in effect through January 30, 2026, but CMS scrutiny is increasing. As federal reviewers finalize telehealth utilization and compliance findings expected later this month, healthcare organizations, especially Critical Access Hospitals, Federally Qualified Health Centers, and Rural Health Clinics, should be assessing risk now, not after enforcement activity begins.

CMS reviews are expected to focus on how temporary telehealth flexibilities have been used, documented, and billed. The outcome of these findings may shape future enforcement priorities, audit activity, and policy decisions moving into 2026.

What Telehealth Flexibilities Are Still in Effect

Through January 30, 2026, Medicare continues to allow several COVID-era telehealth provisions, including:

• Home as an originating site

• Audio-only visits for certain services

• Expanded eligible provider types

• Distant site billing for FQHCs and RHCs

These flexibilities remain especially important for rural and underserved populations, but they are also drawing increased regulatory attention.

Where CMS Is Likely Looking Closely

As telehealth utilization data matures, CMS oversight is shifting from access expansion to compliance validation. Common risk areas include:

• Audio-only visits without sufficient documentation of medical necessity

• Incorrect POS or modifier usage

• Confusion between originating and distant site billing

• Services that rely entirely on temporary flexibilities

• Limited internal audit documentation to support billed services

Organizations that cannot clearly identify and defend telehealth claims may face recoupments or corrective action requests as enforcement tightens.

What Happens After January 30, 2026

If Congress does not extend current flexibilities, most non-behavioral telehealth services will revert to pre-pandemic rules beginning February 1, 2026. Expected changes include:

• Home no longer qualifying as an originating site for most services

• Geographic restrictions returning

• FQHCs and RHCs potentially losing distant site eligibility

• Audio-only visits becoming limited primarily to behavioral health

Behavioral and mental health telehealth services retain permanent flexibilities.

How Proactive Organizations Are Preparing

Rather than waiting for CMS findings, proactive organizations are:

• Identifying telehealth encounters by CPT, modifier, POS, and payer

• Monitoring audio-only utilization patterns

• Auditing documentation before external reviews occur

• Quantifying revenue exposure tied to temporary flexibilities

• Preparing leadership for potential reimbursement changes

MRSNH supports this work by combining RevNav, which provides telehealth utilization and revenue visibility, with AudiQ, which supports defensible documentation audits and compliance review. Together, they help organizations see risk early and respond with confidence.

Looking Ahead

Telehealth is not going away. But unmanaged telehealth risk is becoming more expensive. Organizations that invest now in visibility, documentation integrity, and audit readiness will be best positioned as CMS findings are released and policy direction becomes clearer.