CMS Telehealth 2026 Update: The Calm Before 2028
CMS released updated telehealth guidance on February 4, 2026. At first glance, it looks like stability. Most pandemic-era flexibilities remain in place through December 31, 2027.
But that date matters.
For revenue cycle leaders, compliance officers, and CFOs, this is not just an extension. It is a runway. And 2028 will change the structure of Medicare telehealth.
Let’s break down what is stable, what is permanent, and what sunsets.
What Continues Through December 31, 2027
Geographic Flexibility
Beneficiaries can receive Medicare telehealth services anywhere in the U.S., rural or urban.
This ends in 2028 for most services.
Expanded Practitioner Eligibility
An extended range of practitioners may bill for telehealth services through 2027.
Beginning January 1, 2028:
Physical therapists
Occupational therapists
Speech-language pathologists
Audiologists
will no longer be permitted to furnish Medicare telehealth services.
Organizations with therapy-heavy telehealth utilization should model revenue impact now.
Hospital Remote Billing Alignment
Hospitals may continue billing for:
Outpatient therapy
Diabetes self-management training
Medical nutrition therapy
when furnished remotely by hospital staff to patients at home through 2027.
After 2028, this billing pathway closes.
What Is Permanent
Behavioral Health Telehealth Flexibility
Geographic and originating site restrictions are permanently removed.
Patients in rural or urban areas may receive behavioral health telehealth services in their homes.
Audio-only remains permitted.
This is not temporary. It is structural.
Removal of Telehealth Frequency Limits
As of January 1, 2026, CMS permanently removed telehealth frequency limits for:
Subsequent inpatient visits
Nursing facility visits
Critical care consultations
This stabilizes utilization models for inpatient tele-consults.
Virtual Direct Supervision
Beginning January 1, 2026, direct supervision may be met via real-time audio/video technology for services without a 010 or 090 global surgery indicator.
This affects:
Incident-to services
Many diagnostic tests
Pulmonary and cardiac rehab
Certain hospital outpatient services
This is operationally significant for staffing models.
What Changes in 2028
January 1, 2028 introduces structural tightening:
Non-behavioral health telehealth services generally require rural location and medical facility presence.
Therapy professionals lose telehealth eligibility.
Hospitals lose ability to bill certain remote services furnished to patients at home.
Mental health telehealth will require in-person visit timing compliance:
One in-person visit within 6 months prior to first telehealth service
At least one in-person visit every 12 months thereafter
Patients established before January 1, 2028 will follow modified transition rules.
Audio-Only Rules
Through 2027, audio-only remains broadly permitted.
Beginning 2028:
Audio-only remains allowed for behavioral health.
The practitioner must be technically capable of video.
The patient must be unable or unwilling to use video.
This introduces documentation risk.
ACO Telehealth Flexibilities
Applicable Medicare Shared Savings Program ACOs in the ENHANCED or certain BASIC tracks may continue furnishing telehealth without geographic restriction, provided services are billed under the ACO participant TIN.
This remains a strategic advantage for qualifying organizations.
Strategic Questions Revenue Leaders Should Be Asking Now
How much of our 2025–2026 telehealth revenue is therapy-based?
What percentage depends on hospital-remote billing alignment?
Are we prepared to track in-person mental health compliance requirements in 2028?
Where are we relying on audio-only encounters without documentation safeguards?
Do our billing teams fully understand POS 02 vs POS 10 reimbursement impacts?
2026 and 2027 are not years to relax. They are years to prepare.
The organizations that wait until late 2027 will be compressing operational redesign into a compliance crisis window.
Bottom Line
Telehealth is not disappearing.
But it is narrowing.
Behavioral health remains structurally protected.
Hospital outpatient and therapy-based telehealth face meaningful revenue exposure in 2028.
If your organization depends on telehealth margin, this is the time to map risk and tighten billing precision.