September 30 was the last day before the Medicare telehealth waivers expired.
On March 14, 2025, the federal telehealth waivers applicable to Medicare, which have been in place since the pandemic, were extended for an additional six months, until Sept. 30, 2025. In recent weeks, several proposed extensions of these waivers have been made within recent budget talks. Since no final budget deal or continuing resolution materialized, the result was an expiration of the Medicare telehealth waivers and a federal government shutdown.
There is very little the Centers for Medicare and Medicaid Services (CMS) can do about the Medicare telehealth waivers as most of those policies are embedded in federal statute and require Congress to act. However, in the CMS 2025 Physician Fee Schedule (PFS) CMS extended for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) the ability to continue to use telecommunication technologies to provide non-behavioral health services until the end of 2025. Additionally, within the proposed 2026 Physician Fee Schedule (PFS), CMS includes that they would extend that policy through the end of 2026. Therefore, FQHCs and RHCs will still have the capacity to provide services via technology and be reimbursed by Medicare at least through the end of this year, and potentially even through the end of 2026 if next year’s proposed PFS is finalized as written. However, it is important to highlight that FQHCs and RHCs will have to meet previously waived in-person requirements related to mental health services without the waivers.
For more information on this, see CCHP’s Eligible Providers and Mental Health newsletters from the aforementioned Summer Medicare Waiver newsletter series. See the chart below for additional guidance.
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