As of midnight on October 1, 2025, several of the most significant COVID-era telehealth flexibilities officially expired. These changes are now in effect, and they carry immediate implications for physicians and medical groups providing telehealth services, including those in the behavioral and mental health space. The regulatory environment has shifted back to the pre-pandemic framework, and practices must act quickly to realign their operations and billing practices to remain compliant.

The most impactful change is the return of Medicare’s geographic and originating site restrictions. During the pandemic, Medicare patients could receive telehealth care from virtually anywhere, including their own homes. That flexibility is now gone. Except for limited behavioral health services, Medicare telehealth coverage once again applies only to patients located in qualifying rural areas who are receiving care at approved originating sites, such as clinics or hospitals.

Audio-only telehealth coverage has also ended for most non-behavioral services. This means that real-time audio and video technology is again required for most telehealth encounters. Physicians who have been providing phone-only visits will need to confirm whether those encounters still qualify for reimbursement.

Expanded provider eligibility has reverted to the pre-pandemic baseline. Physical therapists, occupational therapists, speech-language pathologists, and audiologists are no longer permitted to bill Medicare for telehealth services unless another exception applies.

The waiver of the in-person visit requirement for mental health telehealth has expired as well. Medicare once again requires that patients have an in-person visit within six months prior to initiating tele-mental health care and at least once every twelve months thereafter. This change is likely to disrupt continuity of care for established patients and create new administrative burdens for mental health providers.

Finally, the Hospital at Home program authority has ended. Hospitals that were providing acute-level inpatient care in patients’ homes under the PHE waiver must now transition those programs back to in-facility models or discontinue them.

As of October 9, CMS and its contractors are holding some claims that rely on the now-expired flexibilities while awaiting further congressional action. This temporary hold is intended to prevent unnecessary reprocessing if Congress later passes a retroactive extension, but in the meantime, many claims are delayed and some providers are seeing uncertainty in payment timelines. Across the country, practices are scaling back certain telehealth services until they can confirm which encounters remain billable under the reinstated restrictions. Some are issuing Advance Beneficiary Notices to Medicare patients to clarify that continued telehealth services may not be covered. Commercial and Medicare Advantage payors are taking varying approaches, with some maintaining pandemic-era flexibilities while others are aligning with the stricter Medicare framework.

Physicians should immediately review their telehealth operations and identify which services can continue under the current rules. Any Medicare telehealth visits that no longer meet the geographic, originating site, or provider eligibility requirements should be flagged and modified to avoid denials or overpayment risk. For mental health providers, scheduling in-person visits for affected patients should now be a top operational priority.

Patient communication is also critical. Practices should notify affected patients, especially those who receive tele-mental health care or audio-only visits, about potential coverage changes and the need for in-person appointments. Where appropriate, practices should issue Advance Beneficiary Notices to protect patients and preserve compliance. Billing and compliance staff should receive updated training on the reinstated rules, including which CPT codes are still payable via telehealth and which are not. Documentation should clearly reflect when a patient encounter qualifies under a behavioral health exception or another covered category.

Physicians should also monitor developments closely. Several bills, including the Telehealth Modernization Act of 2025 and the CONNECT for Health Act of 2025, remain pending in Congress. If either passes, some of the expired flexibilities could be reinstated retroactively. Until then, providers must operate under the current pre-pandemic standards.

As of October 9, 2025, the expiration of these telehealth flexibilities has created significant disruption, particularly in mental health care where continuity and accessibility are essential. While advocacy efforts continue in Washington, physicians must protect themselves by following the rules now in place and by documenting their compliance carefully. The regulatory pendulum has swung back, at least for now, and the focus should be on stability, compliance, and transparent patient communication while the future of telehealth is debated in Congress.