CurrentOptumPolicy N/A

Medicare telehealth policy FAQs

Clarifies Medicare telehealth coverage, billing, supervision, provider eligibility, and site/location rules, including time-limited flexibilities through 2027 and phased changes effective 2026–2028 for Medicare providers, RHCs/FQHCs, ACO participants, and beneficiaries.

Policy Summary

PayerOptum

PolicyMedicare telehealth policy FAQs

Policy CodePolicy N/A

Change TypeCoverage and billing clarifications with time-limited flexibilities

Effective DateN/A

Next Review DateN/A

Key ActionSubmit requests to add or change services on the Medicare Telehealth Services List to CMS by February 10 with supporting documentation for consideration in PFS rulemaking.

SourceLink

POLICY UPDATE CHANGES

Through December 31, 2027, beneficiaries may receive Medicare telehealth services anywhere in the United States and territories; some restrictions resume starting January 1, 2028.

Beginning January 1, 2026, teaching physicians may have a virtual presence for Medicare telehealth services and direct supervision may include virtual presence (audio/video) for many services.

Audio-only telehealth is permitted in the home through December 31, 2027; restricted rules apply starting January 1, 2028, but audio-only remains available for behavioral health when clinician is technically capable of audio-video and patient cannot or does not consent to video.

Certain allied therapists (PT, OT, SLP, audiology) may bill for telehealth through December 31, 2027 but cannot furnish Medicare telehealth starting January 1, 2028.

Dec 31, 2027end date for many expanded telehealth flexibilities

Jan 1, 2026virtual teaching physician presence effective

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nofrequency limits removed

02 / 10Place of Service codes

Medicare Telehealth Coverage Criteria and Rules

Billing, Place of Service, and Related Coding Rules

RHC/FQHC telehealth billingHCPCSCovered

G2025

HCPCS code RHC/FQHC billing for non-behavioral health telecommunication services

Place of Service codes for telehealthmixedCovered

POS 02	Telehealth Provided Other than in Patient's Home
POS 10	Telehealth Provided in Patient's Home

In‑person prior visit window for initial mental health telehealth service (post‑2027)

RequirementAn in-person, non‑telehealth visit must have occurred within 6 months prior to the patient's first mental health telehealth service (effective after December 31, 2027).

Subsequent visitsAfter the first in‑home telehealth mental health visit, an in‑person, non‑telehealth service is required within 12 months of each telehealth service, with limited exceptions and allowance for same‑specialty group practice coverage if the furnishing practitioner is unavailable.

GrandfatheringBeneficiaries who began receiving mental health telehealth services in their homes on or before December 31, 2027 are considered established and are exempt from the 6‑month prior in‑person requirement; they must have at least one in‑person visit every 12 months after December 31, 2027.

Actions Providers Must Take

Billing Rule

ACO telehealth billing requirement

To receive payment under the Medicare Shared Savings Program special telehealth flexibilities, telehealth services must be billed through the Tax Identification Number (TIN) of an ACO participant in an applicable ACO. Applicable ACOs are those with prospective assignment for a performance year in the ENHANCED track or BASIC track levels C, D, or E. Risk-based ACOs using preliminary prospective assignment with retrospective reconciliation do not qualify as applicable ACOs; clinicians in those ACOs and clinicians in non-risk-based ACOs remain subject to standard Medicare FFS telehealth rules.

Bill telehealth services through the ACO participant TIN to qualify for ACO payment flexibilities.
Applicable ACOs: ENHANCED track or BASIC track levels C, D, or E (with prospective assignment).
Preliminary prospective assignment with retrospective reconciliation = not eligible for ACO telehealth flexibilities.

Note

Process to request changes to the Medicare Telehealth Services List

Key Definitions

Established patient — definition (mental health telehealth)

DefinitionAn 'established patient' for mental health telehealth is a beneficiary who began receiving mental health telehealth services in their home on or before December 31, 2027; such beneficiaries are treated as established and are not subject to the 6‑month prior in‑person visit requirement effective after December 31, 2027.

ImplicationEstablished patients must still have at least one in‑person, non‑telehealth visit every 12 months after December 31, 2027 (consistent with requirements for ongoing care).

ApplicabilityThis definition applies specifically to in‑home mental health telehealth services and the transition from expanded flexibilities that end December 31, 2027.

Applicable ACO — definition and applicability for billing flexibilities

Definition'Applicable ACOs' are MSSP ACOs with prospective assignment for a performance year in the ENHANCED track or the BASIC track levels C, D, or E; these ACOs qualify for special telehealth flexibilities.

Policy Summary

PayerOptum

PolicyMedicare telehealth policy FAQs

Policy CodePolicy N/A

Change TypeCoverage and billing clarifications with time-limited flexibilities

Effective DateN/A

Next Review DateN/A

Key ActionSubmit requests to add or change services on the Medicare Telehealth Services List to CMS by February 10 with supporting documentation for consideration in PFS rulemaking.

SourceLink

On This Page

Requests to add or modify services on the Medicare Telehealth Services List must be submitted to CMS by February 10 of a given year to be considered for the following calendar year’s PFS rulemaking. Include all supporting documentation with the request. Note submissions are subject to public disclosure. See CMS Telehealth webpage for submission details and the current list.

Deadline: February 10 each year for consideration in next years PFS rulemaking.
Include supporting documentation with each request.
Submitted information is subject to public disclosure; follow CMS instructions on where to send requests.

Billing requirementTo receive payment under the ACO telehealth flexibilities, the telehealth service must be billed through the TIN of an ACO participant in an applicable ACO; there is no special application or approval process.

LimitationsRisk‑based ACOs using preliminary prospective assignment with retrospective reconciliation do not meet the definition of an applicable ACO because final assignment occurs after the performance year; clinicians in such ACOs remain subject to standard Medicare FFS telehealth rules.

ScopeClinicians in applicable ACOs may furnish and receive payment for covered telehealth services to prospectively assigned beneficiaries without geographic restriction, including services provided in the beneficiary's home.