2026 Telehealth Policy Update: Medicare Flexibilities Extended
- HC Intellect
- Feb 4
- 5 min read
Date: February 5, 2026
To: Providers, Billing & Compliance Teams
From: Compliance & Coding Department
Subject: Telehealth Policy Update – 2026
Bottom Line
The Consolidated Appropriations Act, 2026 extends all major Medicare telehealth flexibilities through December 31, 2027. This includes home as an originating site, no geographic restrictions, expanded practitioner eligibility, continued audio-only coverage, and sustained authority for FQHCs and RHCs to serve as distant-site providers. Behavioural health in-person requirements are deferred until January 1, 2028, and the Hospital-at-Home waiver program is extended through September 30, 2030.
Context
Telehealth flexibilities originally implemented during the COVID-19 Public Health Emergency were due to expire. The passage of the Consolidated Appropriations Act, 2026 prevents any lapse in coverage and ensures continuity of telehealth delivery nationwide. Extensions provide regulatory stability and allow practices to maintain virtual care models without reverting to pre-PHE restrictions.
Why this matters
• Sustains nationwide access to telehealth, preventing disruption in care delivery.
• Supports patients who rely on virtual access due to mobility, broadband, or transportation barriers.
• Maintains operational and revenue predictability for practices.
• Allows continued interprofessional telehealth (e.g., PT/OT/SLP, audiology).
• Protects audio-only access, which remains essential for many Medicare beneficiaries.
What Changes in 2026
Beginning in 2026, telehealth flexibilities continue without limitation through December 31, 2027. Home remains an originating site. Geographic restrictions remain suspended. Expanded practitioner types stay eligible. Audio-only coverage remains available when clinically appropriate. Behavioural health continues telehealth without in-person requirements until January 1, 2028. The Hospital-at-Home waiver is extended through 2030.
Recommended Practice Policy
• Continue allowing Medicare telehealth visits from home or any location with no geographic limitations.
• Maintain expanded practitioner participation, including PT/OT/SLP and audiologists when the service is within scope of practice and appears on the Medicare Telehealth Services List”, for telehealth.
• Permit audio-only visits when clinically appropriate and document rationale.
• Continue behavioural health telehealth without requiring in-person visits until January 1, 2028.
• Maintain FQHC and RHC distant-site workflows.
• Validate Medicare Telehealth Services List for eligible codes.
• “Telehealth services must meet the same medical necessity, documentation, and coverage standards as in-person services.”
Workflow Updates (Action Items)
Clinical Operations
• Continuing offering telehealth and audio-only visits as standard scheduling options
• Train clinicians on appropriate documentation for audio-only encounters
• Reinforce clinical appropriateness criteria for modality selection (video vs. audio)
Billing & Coding
• Maintain current telehealth POS 10 (patient at home), POS 02 (patient not at home) and modifier (93 & 95) usage per CMS guidance (“POS selection must reflect the patient’s physical location at the time of service per CMS POS definitions.”)
• Audit telehealth claims quarterly to ensure services align with the Medicare Telehealth Services List
• Flag audio-only visits to confirm documentation supports medical necessity
Compliance
• Update telehealth policies to reflect extension through 12/31/2027
• Remove language referencing “temporary” or “PHE-related” telehealth flexibilities
• Monitor CMS updates for any future changes prior to 2028
Behavioral Health
• Continue tele-behavioral services; track the 1/1/2028 in-person deadline in work queues.
IT / Scheduling
• Ensure telehealth visit types remain active in EHR and scheduling systems
• Preserve telephone-only visit workflows for eligible services
Quick reference table
Payer | Telehealth POS | Telehealth Modifier (A/V) | Audio-only Modifiers | Eligible Serices | Key Notes / Gotches |
Medicare Part B | POS 02 | 95 | “Modifier 93 permitted only for services CMS or the payer has designated as audio-only eligible; documentation must support lack of video capability.” | Only codes on the CY2026 Medicare Telehealth Services List are payable via telehealth. | Originating site: flexibility (including home) continues for all Medicare telehealth services on the Telehealth Services List through 2/31/2027, not just behavioral health. |
UnitedHealthcare (UHC) | POS 02 or POS 10 | 95 for A/V | 93 for audio-only (when supported) | UHC publishes an eligible telehealth code list; communications tech (CTBS/RPM) may not qualify as POS 02/10 telehealth. | Do not bill CTBS/RPM as telehealth; use the proper CPT for those services. UHC distinguishes audio-only list; follow it when billing with 93. |
Aetna | POS 02/10 (per plan) | 95 or GT for A/V (plan may specify) | 93 when allowed by plan Aetna’s telemedicine | Aetna’s telemedicine policy includes a code list; actual coverage can be plan-level. | Audio-only is not universally covered. Verify plan language; some plans require audiovisual for telehealth. |
Humana | POS 02/10 | 95 for A/V | 93 for audio-only (when allowed) | Humana defines telehealth eligibility via its guidance and may update lists seasonally. | Audio-only is treated separately in policy; unless in their approved list, audio visits may not pay or may pay at lower levels. |
Cigna | POS 02/10 | 95 / GT / GQ (one required to indicate telehealth) | 93 when supported by plan | Cigna’s telehealth code/coverage guidance is tied to its Virtual Care materials and plan benefits. Some plans differ. | Ensure the modifier matches actual delivery: don’t choose randomly — Cigna audits have denied mismatches between claimed modality and documentation. |
Blue Cross Blue Shield (Commercial) | POS 02/10 | 95 or GT (plan may specify) | 93 (state/plan specific) | BCBS is plan- and state-specific; most mirror Medicare with commercial flexibility. | Many BCBS plans require telehealth parity language in the contract. Some require 95 even if POS 02 used. |
TRICARE East (Humana Military) | POS 02 | 95 | Rare/Generally not standard | Telehealth covered when medically necessary and referral rules met. | Active Duty requires referral/authorization. Pain mgmt. often needs auth even for telehealth. |
TRICARE West (TriWest) | POS 02 | 95 | Rare/Generally not standard | Telehealth covered under CCN when referral/authorization exists. Following Medicare guidance | Authorization required for most specialty telehealth, incl. pain management. |
FAQs
Q1. Can patients receive Medicare telehealth services from home?
A: Yes. Under the Consolidated Appropriations Act, 2026, Medicare beneficiaries may continue to receive telehealth services from any location, including the patient’s home, with no geographic restrictions, through December 31, 2027, provided the service is included on the Medicare Telehealth Services List. This applies to non-procedural pain management and orthopedic services such as follow-up E/M visits, imaging review, medication management, and post-procedure follow-ups. Telehealth does not replace in-person requirements for procedures.
Q2. Are audio-only (telephone) visits allowed?
Yes, when clinically appropriate and when permitted by CMS or the applicable payer. Documentation must explain why video was not used and why audio-only was sufficient.
Q3. Does behavioral health related to pain have different rules?
A: Yes. Behavioral health services related to pain management may continue via telehealth, including from the home, with the in-person requirement deferred until January 1, 2028.
Q4. Can NPs, PAs, and therapists provide telehealth?
A: Yes. Expanded practitioner eligibility remains in effect through December 31, 2027, subject to scope-of-practice and payer rules.
Q5. What POS and modifiers should be used?
A: POS 10 for home, POS 02 for non-home locations. Modifier 95 for audio-video and modifier 93 for audio-only when allowed.
Q6. Are initial consultations allowed via telehealth?
A: Yes, for evaluation and management only when clinically appropriate. An in-person exam is still required prior to procedures.
Q7. Does telehealth waive authorization requirements?
A: No. Telehealth does not waive prior authorization, referral, or medical necessity requirements.
Q8. Should telehealth still be labeled as temporary or COVID-related?
A: No. Telehealth flexibilities have been statutorily extended through December 31, 2027, and should not be referred to as temporary.
Q9. What is the key compliance takeaway?
A: Telehealth is a supplement, not a substitute, for in-person procedural care. Document modality, medical necessity, and payer compliance carefully.
— End of Memo —
HC Intellect is a Milwaukee-based healthcare revenue cycle management (RCM) and technology firm with a deep specialization in interventional pain management and related surgical specialties. The company partners closely with pain practices and ASCs to optimize coding, billing, and collections across the full revenue cycle, with particular expertise in complex procedure coding, E&M optimization, and payer-specific reimbursement challenges unique to interventional pain. By combining experienced RCM teams with proprietary analytics and AI-driven tools, HC Intellect helps pain practices reduce denials, accelerate cash flow, and sustainably improve financial performance.
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