The Telehealth Cliff is Approaching (Again): What January 30, 2026, Means for Your Practice

UPDATE: January 2026 - CMS extended the Medicare telehealth coverage flexibilities through January 30, 2026. Yes, we got another reprieve. But before you breathe that sigh of relief, we need to talk about what this actually means, and what you should plan for right now.

If you're running a telemedicine practice or seeing any Medicare patients via telehealth, here's the situation: Congress kicked the can down the road one more time. The telehealth flexibilities that were supposed to expire on September 30, 2025 are now extended through January 30, 2026.

Here's the kicker: A lot of providers I'm talking to are suffering from what I call "boy who cried wolf fatigue." We've been through this before. Multiple deadlines, multiple extensions at the last minute.

What Actually Happens on January 31, 2026?

According to the latest CMS guidance (updated November 14, 2025), here's what's at stake if Congress doesn't extend these flexibilities past January 30, 2026:

1. The Home as an Originating Site? Gone (Mostly)

Through January 30, 2026, Medicare beneficiaries can receive telehealth services anywhere in the United States. But starting January 31, 2026, you'll only be able to bill Medicare for home-based telehealth visits in very specific circumstances:

• Behavioral health services (including mental health and substance use disorder treatment) - these can still be provided to patients at home

• Treatment for substance use disorder and co-occurring mental health conditions

• End-stage renal disease (ESRD) home dialysis services

Everything else? The patient needs to be at an approved originating site in an eligible geographic location—meaning back to pre-pandemic rural facility restrictions.

2. Hospital at Home and Remote Hospital Services End

If you're running outpatient therapy services, diabetes self-management training, or medical nutrition therapy services remotely by hospital staff to beneficiaries in their homes, listen up.

Through January 30, 2026, hospitals can continue billing for these services. But starting January 31, 2026, hospitals may no longer bill for these services when furnished remotely to beneficiaries at home.

This means if you're providing these services, you need to either:

• Transition patients back to in-facility care

• Absorb the financial risk of continuing care without Medicare reimbursement

• Transition patients to other covered telehealth services if applicable

3. Say Goodbye to Some Telehealth Providers

Through January 30, 2026, an extended range of practitioners can bill for Medicare telehealth services. But starting January 31, 2026, the following providers lose eligibility to furnish Medicare telehealth services:

• Physical therapists

• Occupational therapists

• Speech-language pathologists

• Audiologists

If you have any of these providers on staff delivering telehealth services, you need a transition plan. Now.

4. FQHCs and RHCs Get a Little More Time (But Not Much)

Here's some good news buried in the extension: Through December 31, 2026, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can continue to bill for non-behavioral health services furnished through telecommunications technology using HCPCS code G2025.

But here's what's important to understand:

• Behavioral health services furnished by FQHCs or RHCs are paid under the All Inclusive Rate (AIR) and Prospective Payment System (PPS)—and there are no in-person visit requirements for these services through at least January 31, 2026

• The home and any geographic location can continue to serve as both distant site and originating site for telecommunications services through December 31, 2026

• After December 31, 2026, unless extended again, FQHCs and RHCs will lose the ability to use G2025 for non-behavioral health telehealth services

If you're running an FQHC or RHC, you have until the end of 2026 to figure out your long-term strategy for non-behavioral telehealth services.

5. The Mental Health In-Person Requirement Returns (With a Key Grandfathering Provision)

This is where things get both frustrating and interesting. Starting January 31, 2026, if you're providing telehealth mental health services to Medicare beneficiaries at home, here's what you need to know:

For NEW mental health telehealth patients (those starting services after January 30, 2026):

• You must provide a Medicare-covered mental health service in person within 6 months prior to the first telehealth mental health visit

• After the first telehealth visit, you need an in-person visit at least once every 12 months

For EXISTING mental health telehealth patients (those receiving services on or before January 30, 2026):

• You get grandfathered in! CMS has clarified that if a beneficiary began receiving mental health telehealth services in their homes prior to January 31, 2026, they do NOT need to meet the 6-month prior in-person requirement

• These established patients will only need to have at least one in-person visit every 12 months going forward

Flexibility in the rules:

• The in-person visit can be with a colleague in the same subspecialty within your group practice if you're not available

• The in-person visit must be Medicare-billable so it shows up in CMS's claims system

Exceptions still exist:

• Patients in rural areas at an eligible originating site

• Patients receiving SUD or co-occurring mental health treatment

What about audio-only for mental health? Starting January 31, 2026, you can still use audio-only for behavioral health services to patients in their homes, BUT:

• You must be technically capable of using audio-video technology

• The beneficiary must either not be capable of or not consent to using audio-video

• Audio-only can be used for both new and established patients

Some Good News About the Government Shutdown

You might remember that brief government shutdown in late September/early October 2025. Here's what CMS clarified: they will continue to pay telehealth claims in the same way they were paid before October 1, 2025. The telehealth flexibilities apply retroactively as if there hadn't been a temporary lapse.

So if you provided services during that period and were worried about payment, you're good. CMS has your back on this one.

What You Need to Do Right Now

I get it. We've been through this dance before. Another extension, another reprieve, another few months of uncertainty. But here's my advice: Don't waste this extension.

You now have until January 30, 2026. That's not a lot of time, but here’s a checklist you can use to prepare:

Step 1: Assess Your Exposure

• How many of your Medicare patients are receiving telehealth services from home?

• How many of those patients would struggle to access in-person care?

• What percentage of your revenue comes from Medicare telehealth reimbursements?

If the answers to these questions aren’t pretty, it's time to act.

Step 2: Communicate with Your Mental Health Patients (This is GOOD NEWS)

If you're providing mental health services via telehealth, you need to communicate with your patients about the grandfathering provision.

For patients already receiving mental health telehealth services:

• They're grandfathered in and don't need the 6-month prior in-person visit

• They just need one in-person visit every 12 months going forward

• Make sure you document when their 12-month clock starts (January 31, 2026)

For new mental health telehealth patients you want to start after January 30, 2026:

• They need an in-person visit within 6 months before their first telehealth session

• Consider scheduling those in-person visits now for patients who might need telehealth services in the future

This grandfathering provision is a huge win. Don't let it go to waste by failing to document properly.

Step 3: Make a Financial Decision (You Have Until January 30)

If Medicare stops reimbursing certain telehealth services after January 30, 2026, you need to decide:

• Will you continue offering telehealth to affected patients without reimbursement?

• Will you allow existing telehealth appointments to proceed but stop scheduling new ones?

• Will you send cancellation notices for affected visits?

• For non-behavioral health services at FQHCs/RHCs: Do you bank on another extension past December 31, 2026, or start transitioning now?

There's no right answer here—it depends on your practice's financial health and patient care philosophy. But you need to make this decision before January, not in a panic on January 31.

Step 4: Explore Alternatives

For patients who can't come into the office, research alternative care locations that may be more accessible:

• Eligible originating sites like FQHCs, RHCs, or rural hospitals

• Partnership opportunities with these sites to facilitate continued telehealth access

You can use the Medicare Telehealth Payment Eligibility Analyzer to check if a site qualifies for Medicare telehealth reimbursement. Just enter the street address and see if it's eligible.

Step 5: Train Your Team

Make sure your providers, schedulers, and front-desk staff understand the new requirements. The last thing you want is confusion when patients start calling to ask why their appointments are changing.

Final Thoughts: This Isn't Over

Look, I'm glad we got the extension to January 30, 2026. It gave breathing room to providers utilizing telemedicine for their Medicare patients. But let's be clear about what this is: a temporary reprieve, not a permanent solution.

Eventually, we will return to the rural area, distant/originating site, and facility-based coverage requirements in place before the pandemic.

Use this extension wisely to either:

• Build a practice model that can survive without the flexibilities, or

• Advocate loudly for permanent telehealth legislation

This cycle of extensions and cliffs? It's exhausting. And it's not sustainable.

You can control how you respond to this. You can't control Congress or CMS, but you can control how prepared your practice is for whatever comes next.

If you need help navigating these changes, understanding the new documentation requirements for mental health services, or developing a compliance strategy that works whether these flexibilities are extended again or not, that's exactly what Functional Lawyer is here for.

Stay compliant. Stay informed. And use this extension to build a practice that can thrive no matter what Congress does next.

Want the official details? Check out the CMS Telehealth FAQ for Calendar Year 2026 (updated November 14, 2025) for all the technical specifications.

Need help with compliance strategy? Schedule a discovery call and let's make sure your practice is ready for January 31, 2026—and whatever comes after.

– Scott Rattigan, J.D.
Functional Lawyer