If your practice has delivered virtual visits since 2020, the temptation is to assume nothing has moved. It has, twice over.

The RealityReviewing the 2026 Medicare telehealth rules

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The Problem

Rules moved; configuration did not.

Code lists, scheduling caps and supervision policies were set up years ago and never revisited. The rules changed on 1 January and nothing in the system knows it.

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The Solution

Treat it as a configuration project.

Audit the code list, strip out the frequency caps, write the supervision policy down with its exclusion named, and split audio-only billing by visit type.

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The Resolution

Claims that survive the remittance file.

Billing works from a current list, scheduling stops blocking billable visits, and the practice knows its exposure well before the 2027 date arrives.

Medicare telehealth flexibilities: what changed on 1 January 2026

The CY 2026 Physician Fee Schedule took effect at the start of the year with a conversion factor of $33.57 for qualifying alternative payment model participants and $33.40 for everyone else, per the CY 2026 Physician Fee Schedule final rule. Three provisions inside it matter operationally.

The services list stopped being two lists

CMS removed the distinction between provisional and permanent telehealth services. The review now turns on one question: whether the service can be furnished using an interactive, two-way audio-video system. Fewer annual surprises about which codes fall off, and a simpler answer when a clinician asks whether something can be delivered virtually.

It also means the internal reference your billing team works from is probably organized around a distinction that no longer exists. Worth a look before someone denies a claim on the basis of it.

Frequency limits came off three service types

CMS permanently eliminated frequency limits for subsequent inpatient visits, subsequent nursing facility visits and critical care consultations. Practices with a hospital or skilled nursing footprint have tracked those caps in a spreadsheet for years. That tracking is now unnecessary, and any hard stop built into scheduling rules is blocking revenue rather than protecting it.

Direct supervision telehealth: the rule with a carve-out

This is the change most likely to alter how a practice staffs a day. CMS finalized a definition of direct supervision that can be met through real-time audio and visual interactive telecommunications, explicitly excluding audio-only. It applies to incident-to services, diagnostic tests, pulmonary rehabilitation and cardiac rehabilitation.

The carve-out matters: services carrying global surgery indicators of 010 or 090 are excluded. A practice that reads the headline and not the exception can build a supervision model that fails on exactly the services where supervision is examined most closely. Write the policy down, and name the exclusion in it.

Separately, CMS made permanent the ability for teaching physicians to provide virtual supervision in all teaching settings, in clinical instances where the service was furnished virtually. That provision had been due to lapse at the end of 2025.

Telehealth originating site rules and the 31 December 2027 date

Per the HHS telehealth policy updates, there are no geographic restrictions on the originating site for non-behavioral Medicare telehealth services through 31 December 2027, and those services can be delivered on audio-only platforms through the same date. Patients can be seen at home until then.

That is a borrowed arrangement with an expiry printed on it. The rules revert unless Congress acts again, and they have been extended repeatedly rather than settled. A practice building a service line on the assumption that home-based virtual visits are permanent is building on a two-year lease.

Behavioral health sits differently. Geographic restrictions on the originating site are permanently waived. Audio-only delivery is permanently allowed. Marriage and family therapists and mental health counselors can permanently serve as distant-site providers. If you are deciding where to invest configuration effort, behavioral health telehealth rests on permanent statutory footing in a way the rest of the program does not.

Audio-only telehealth billing now carries two different risks

Audio-only sits awkwardly across that line. It is permanent for behavioral services and temporary for everything else, which means one modality carries two risk profiles depending on visit type. Practices billing audio-only without distinguishing between the two are carrying exposure they have never measured.

The fix is not complicated. Your templates should make the distinction visible at the point of documentation rather than at the point of appeal, and your reporting should answer one question on demand: how much of our audio-only volume is non-behavioral? That number is what the 2027 conversation will turn on.

Telehealth documentation requirements that move with the rules

Everything above eventually lands in a template. If your virtual visit note does not capture modality, patient location and the supervision arrangement in a structured field, you are relying on narrative text to prove compliance at audit, which is the weakest position available.

Structured capture of modality is the highest-value single change. It lets you report audio-only volume by visit type, which is the number you will need as 2027 approaches. That is template work rather than a clinical change, and it is usually a short project.

The same logic applies to programs running alongside virtual visits. Remote patient monitoring has its own documentation and billing requirements, and practices frequently run it through the same telehealth workflow without separating the two in the record. Where any of this touches how patient information moves or is stored, it also belongs in the scope of your HIPAA compliance practice rather than being treated as a billing question alone.

Where practices get caught

Four patterns recur. A supervision model built from a headline, missing the surgical exclusion. A billing team working from a code list nobody has refreshed since the structure changed. Meaningful non-behavioral volume built on home-based visits with nobody owning the 2027 date.

And the one that shows up in groups with more than one site: telehealth configuration gets built once, by whoever set up the first location, then copied. When the rules move, the copy does not. We regularly find one office running a current code list and another running the version it inherited two years ago, with nobody aware the two had diverged.

None of these are clinical failures. They are configuration and ownership gaps, and they are fixable well before they turn into denials. The rule text is public. The CY 2026 changes were published in full in the Federal Register, but reading a rule and reconfiguring a system around it are different jobs.

Most of this work touches the same four places: the code list your billers reference, the scheduling rules, the visit templates and the supervision policy. That overlap is why it usually makes sense to handle it as one piece of rebuilding the workflow around it rather than four separate tickets, and why it sits naturally alongside the rest of our EHR solutions work.

Telehealth rule changes 2026: common questions