On November 14, 2025, the Centers for Medicare and Medicaid Services (CMS) released updated guidance to practitioners (PDF, 76KB)opens in new window on the status of Medicare claims for services furnished by telehealth. The guidance incorporates policies from Congress’ restoration of the telehealth flexibilitiesopens in new window, which temporarily lapsed due to a weeks-long government shutdown, on November 12. The guidance also incorporates new CMS policies from the October 31 release of the Medicare Physician Fee Schedule Final Rule for Calendar Year 2026opens in new window.
During the government shutdown, a new requirement for a periodic in-person visit briefly went into effect. The guidance clarifies that, for Medicare claims submitted or incurred during the shutdown, “CMS will continue to pay telehealth claims in the same way they had been paid before October 1, 2025 [and] [t]elehealth flexibilities will apply retroactively as if there hadn’t been a temporary lapse in the application of the telehealth flexibilities through January 30, 2026.” The guidance also provides information about the operation of the in-person visit requirement if it is ever allowed to go into effect.
For clinicians who may be concerned about the privacy of their home address information, the guidance specifies that practitioners who provide telehealth services from their homes but have a physical practice location “are not required to report their home address on their Medicare enrollment application.” Practitioners who operate a virtual-only practice from their homes must enroll their home address as a practice location but are advised to “mark the address as a ‘Home office for administrative/telehealth use only’ location in their enrollment application to suppress the street address details from the practitioner’s profile page on the CMS Care Compare Website.”
The current Medicare telehealth flexibilities, including a delay of the in-person visit requirement, are now set to expire on January 30, 2026, if Congress doesn’t act before then. APA Services will continue to press Congress for a longer-term solution on these Medicare flexibilities and a repeal of the in-person visit requirement. If you have any questions, please contact Stephen Gillaspy, deputy chief of health policy and health care financing, or Andrew Strickland, senior legislative and regulatory officer.
