Medicare Telehealth Flexibilities Extended After Government Shutdown Ends

The Continuing Appropriations Act, 2026 (H.R. 5371) signed into law on 12 November 2025 ended the federal government shutdown that began on 1 October 2025. A significant provision for healthcare providers within the legislation was the short-term extension of Medicare telehealth flexibilities initially established during the COVID-19 public health emergency. These flexibilities had lapsed during the shutdown but are now extended through 30 January 2026, with the Centers for Medicare & Medicaid Services (CMS) confirming retroactive applicability through updated guidance. CMS's updated telehealth FAQs clarify practitioner enrollment requirements for telehealth services delivered from home. Distant-site practitioners delivering telehealth from home typically do not need to report their home address if they maintain a separate physical practice location. Conversely, virtual only practitioners whose sole practice location is their home must list their home address but can designate it for administrative or telehealth use only to suppress address visibility on public CMS platforms. Further CMS guidance, consistent with the 2026 Medicare Physician Fee Schedule Final Rule, states that separate Medicare enrollment is mandatory for each state where a practitioner provides and bills for services. During the shutdown lapse, Medicare Administrative Contractors were instructed to return certain telehealth claims, but CMS now advises these claims are payable retroactively if they meet Medicare coverage requirements. Providers may resubmit pending claims and submit any held telehealth claims anticipating legislative action. CMS also encourages providers to identify beneficiaries who paid out of pocket for telehealth services during the lapse period and issue refunds if appropriate before submitting claims to Medicare. This approach ensures compliance with Medicare billing rules and reimbursement standards. The guidance aims to minimize disruption to telehealth service reimbursement and supports the ongoing integration of telehealth within Medicare's coverage framework. Healthcare providers and organizations should closely monitor these evolving CMS policies to ensure enrollment and billing practices align with regulatory requirements. Legal and compliance advisory services remain available to support providers navigating complex enrollment, billing, and telehealth policy adjustments. Staying informed of CMS subregulatory guidance is critical for operational continuity and payer-provider coordination in telehealth delivery under Medicare.