When Mrs. Smith’s twice-weekly home telehealth check-ins stopped being clearly reimbursable, her clinic had only a few hours to figure out whether visits should move to in-person or risk denied claims. That is the real-world choice facing thousands of clinicians and compliance teams now that the Public Health Emergency (PHE) telehealth flexibilities waiver has expired due to no resolution and a government shutdown at midnight on September 30, 2025. Congressional actions failed to pass H.R. 5371 (Continuing Appropriations and Extensions Act, 2026). These flexibilities include payment for home-based telehealth, removal of geographic originating-site restrictions, broader eligible distant-site providers, and expanded use of audio-only communications for certain services.
Bottom line: the rules are shifting from broad pandemic-era latitude back toward stricter originating-site, modality, and provider requirements. This is bound to create immediate coding, revenue, and access risks without preparation.
Providers need to understand that some telehealth guidelines have been implemented permanently, some expired Sept 30, 2025, and some expire on December 31, 2025. It is important to understand how these changes can affect a practice.
Quick Takeaway for Leaders
- Primary risk: increased denials and improper payment exposure for home-based and audio-only telehealth visits.
- Primary operational impact: need for accurate originating-site documentation, updated clinician billing flags, and revised patient workflows.
- Immediate priority: run targeted audits, deploy pre-billing edits, and communicate with patients and clinicians this week.
What’s Changing
- Originating site and geographic limits largely return; home will not be a default reimbursable site for many services.
- Audio-only flexibilities narrow, remaining permitted mainly for select behavioral health uses.
- Distant-site provider eligibility and in-person visit requirements for some services may revert to pre-pandemic norms.
Inform your clinicians and billing staff of this change, publish patient-facing FAQs, and make sure all visits that are being performed by telehealth are in-line with the pre-pandemic rules and guidelines. Be sure to monitor denials daily, escalate systematic failures, and refine workflows.
Strategic Leadership Moves
- Treat this as a combined compliance and access problem: preserve care where permitted and create hybrid pathways that protect patient continuity.
- Leverage trade associations and government affairs to seek clarity or extensions where appropriate.
- Use the transition to strengthen telehealth quality metrics and equity monitoring so future pivots are operationally smoother.
LW Consulting, Inc. (LWCI) offers a comprehensive range of services to assist your organization in maintaining compliance, identifying trends, providing education and training, or conducting documentation and coding audits. For more information, contact LWCI to connect with one of our experts!
