Medicare Telehealth Waivers Expire in 2025: Providers Must Prepare Now

The use of telehealth services in U.S. healthcare has become a standard practice, largely supported by temporary Medicare waivers and regulatory flexibilities introduced during the COVID-19 pandemic. These waivers facilitated rapid telehealth adoption by easing certain statutory and regulatory requirements, enabling coverage for a broad range of medical and behavioral health services. However, these temporary measures are set to expire on September 30, 2025, unless Congress intervenes to extend or make them permanent. The Centers for Medicare and Medicaid Services (CMS) has proposed some regulatory adjustments within its control but cannot extend the statutory flexibilities without legislative action.

Healthcare providers should prepare for significant changes effective October 1, 2025, when telehealth services must fully comply with pre-pandemic Medicare coverage guidelines if Congress does not act. This reversion could affect provider revenue streams that have grown reliant on telehealth services under the current waivers. Providers are advised to take proactive steps to assess their telehealth offerings and compliance frameworks now to mitigate potential revenue losses and regulatory risks.

It is important to note that Medicaid programs at the state level and commercial insurers are not bound by Medicare telehealth rules, which may result in a patchwork of coverage policies across payers. Providers must remain vigilant to varying telehealth reimbursement policies beyond Medicare and ensure operational readiness across payers.

Key changes anticipated in the post-waiver environment will impact both medical and behavioral health providers, potentially narrowing the scope of reimbursable telehealth services and reinstating stricter provider and patient location requirements. Providers should engage in detailed planning to align with the evolving Medicare landscape.

In summary, the forthcoming expiration of Medicare telehealth waivers represents a pivotal regulatory adjustment with pronounced implications for healthcare providers. Without congressional action, the telehealth landscape will shift toward more restrictive coverage, emphasizing the importance of strategic compliance and revenue management initiatives well before the 2025 deadline.