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CMS clarifies telehealth rules following the government shutdown

The agency confirmed that eligible Medicare telehealth reimbursements would be processed retroactively for virtual visits, and cleared up confusion on provider home address reporting requirements.
By Andrea Fox , Senior Editor
Doctor takes a telehealth visit from her home

Photo: Recep Buyukguzel/Getty Images

The Centers for Medicare and Medicaid Services has released updated telehealth guidance that assures reimbursement for virtual care visits that occurred during the government shutdown from Oct. 1 through Nov. 13 and clarifies provider home address reporting requirements.

"CMS's guidance is a welcome, commonsense step that spares providers needless red tape," Chris Adamec, executive director of the Alliance for Connected Care, told Healthcare IT News by email on Thursday.

The update also outlines major changes that could take effect Jan. 31, 2026, if lawmakers defer action to expand telehealth.

WHY IT MATTERS

Legislation to fund the government restored critical telehealth access by extending Medicare flexibilities through Jan. 30, 2026.

While some providers restarted halted telehealth services as the government reopened, it was unclear whether eligible virtual care reimbursements, accrued during the 43-day shutdown, would be approved for retroactive payment.

In a Nov. 7 update, CMS indicated "that it has been difficult for Medicare Administrative Contractors to determine if certain claims for telehealth services were payable during the shutdown or not," the American Medical Association said in a national advocacy update.

However, claims paid under telehealth flexibilities will apply retroactively "as if there hadn't been a temporary lapse in the application of the telehealth flexibilities," CMS said in a new FAQ posted to its website Nov. 14.

"CMS will continue to pay telehealth claims in the same way they had been paid before Oct. 1, 2025," through Jan. 30, 2026.

Also, practitioners who have a physical practice location can provide telehealth services from their homes and do not need to report their home addresses on their Medicare enrollment applications

"Virtual-only telehealth practitioners whose only physical practice location is their home address will need to enroll their home address as a practice location," CMS stated.

To suppress the street address details from the practitioner's profile page on the CMS Care Compare Website, a Medicare provider finder tool for beneficiaries, these practitioners should mark the address as a "home office for administrative/telehealth use only" location in their application or email the service center, the agency added.

Telehealth advocates are relieved about the clarification.

"It enables the flexibility in how and when telehealth is delivered that is key to driving patient-centered care," Adamec said. "We're ready to help CMS take the next step and extend a similar approach to providers without physical practice sites."

THE LARGER TREND

Providers and virtual care industry groups regularly express concerns over the stopgap nature of expanded telehealth rules and continue to urge lawmakers to deliver a long-term telehealth policy that gives Medicare telehealth patients and healthcare organizations certainty.

Doctors nationwide are worried about lawmakers acting before Jan. 31.

Patients complaining about lapses in telehealth services have "good reason to complain," according to Dr. Ryan Nadelson of the Northeast Georgia Diagnostic Associates and Clinic.

In an opinion piece published on Thursday in The Hill, Nadelson called for passage of the Creating Opportunities Now for Necessary and Effective Care Technologies for Health Act (reintroduced in June) to make expanded telehealth coverage through Medicare permanent.

"Every week I see the consequences of telemedicine's quiet disappearing act," he wrote.

Last week's updated guidance from CMS offers a preview of telehealth services that could be lost. For example, Medicare beneficiaries need to be located in a rural area and in a medical facility to receive Medicare telehealth services starting Jan. 31, 2026, except for behavioral health services, according to CMS.

"Physical therapists, occupational therapists, speech-language pathologists and audiologists can no longer furnish Medicare Telehealth services," the agency said. Also, after Jan. 31, outpatient therapy, diabetes self-management training and medical nutrition therapy services furnished remotely by hospital staff would no longer be billable.

Medicare patients in cancer recovery requiring specialized physical therapy provided in other parts of their states, and those with debilitating chronic conditions who are largely unable to travel to medical facilities without great difficulty, are just two examples where a rollback on telehealth could reduce access to care and cause harm.

Of note, Federally Qualified Health Centers and Rural Health Clinics may continue to bill for nonbehavioral telehealth services to patients at home through Dec. 31, 2026.

"The home may continue to serve as a distant site for beneficiaries receiving telecommunications services furnished by RHCs and FQHCs," CMS said.

For RHC and FQHC behavioral telehealth services, in-person visit requirements could apply after Jan. 31, however.

ON THE RECORD

"A bipartisan bill to restore parity sits stalled in Congress," Nadelson wrote. "A single lapse in Washington now echoes in every exam room."

Andrea Fox is senior editor of Healthcare IT News.
Email: afox@himss.org
Healthcare IT News is a HIMSS Media publication.