Telehealth Policy Changes 2025: A Provider's Essential Guide

As a healthcare provider or organization, the looming "telehealth policy cliff" is not a distant threat; it's an urgent deadline. On October 1, 2025, critical telehealth flexibilities that have been in place since the COVID-19 pandemic are set to expire. If Congress doesn't act, this could significantly alter how you provide and receive payment for virtual care, affecting both your practice and your patients.

This article provides a clear guide to understanding the changes and building a robust strategy to thrive in a post-waiver world.

What is the Telehealth Policy Cliff?

The Telehealth Policy Cliff refers to the expiration of temporary waivers that expanded telehealth services and reimbursement under Medicare and other programs. For over five years, these waivers have allowed for:

• Reimbursement for virtual visits to Medicare patients in their homes.

• Wider use of telehealth for all providers, regardless of their location.

• The use of audio-only visits for certain services.

• The ability for FQHCs and RHCs to serve as distant site providers for medical visits.

On October 1, 2025, many of these flexibilities may revert to their pre-pandemic restrictions, requiring providers to act quickly to avoid a significant disruption in care delivery and revenue.

Key Policy Changes and Their Impact on Providers

The potential return of these waivers would bring several critical changes:

• Reimbursement Restrictions: The biggest change is the end of at-home telehealth reimbursement for Medicare beneficiaries. This would mean providers could no longer bill for many common telehealth visits to patients in their homes.

• Limited Provider Eligibility: Certain specialists, including occupational therapists, physical therapists, speech-language pathologists, and audiologists, would lose their eligibility to provide telehealth services to Medicare patients.

• Rural & Facility Constraints: The pre-pandemic rules requiring patients to be in a designated rural healthcare facility for a virtual visit would be reinstated. This severely limits access for a majority of the population.

• Hospital at Home Program: Innovative care models like Hospital at Home could be jeopardized without the waivers that allow for virtual monitoring and care from a patient’s home.

Your Checklist to Prepare for the Cliff

As a proactive healthcare leader, you can’t afford to wait for a last-minute legislative decision. Use this checklist to build a resilient telehealth strategy:

1. Assess and Analyze Your Telehealth Services

• Identify High-Volume Services: Review your current telehealth data to determine which services are most reliant on the expiring waivers. This includes home-based visits and care from specialists who may lose eligibility.

• Evaluate Patient Population: Understand the demographics of your telehealth patients, especially the percentage of Medicare beneficiaries who may be affected by reimbursement changes.

2. Develop a Multi-Tiered Strategy

• Contingency Planning: Create a clear plan for your organization if the waivers expire. This might include a return to more in-person visits, but also exploring alternative payment models.

• Adopt an All-Payer Strategy: Don't rely solely on Medicare. Diversify your services to include commercial payers, Medicaid, and self-pay options that may have more permanent telehealth policies in place.

• Explore New Technology: Invest in platforms that offer robust, all-encompassing solutions that can handle both in-person and virtual workflows seamlessly, regardless of shifting regulations.

3. Advocate for Permanent Telehealth Policy

• Join the Conversation: Connect with professional organizations like the American Telemedicine Association (ATA) and others that are actively lobbying Congress for permanent telehealth legislation.

• Educate Your Networks: Use your platform to inform fellow providers, patients, and policymakers about the benefits of telehealth and the risks of letting the waivers expire.

The Future of Telehealth is Now

The telehealth policy cliff is a call to action. By understanding the risks and preparing your organization with a proactive strategy, you can ensure your virtual care services remain a vital part of your practice. The future of telehealth is in the hands of those who are prepared to adapt and advocate for a system that benefits providers and patients alike.