During the COVID-19 public health emergency, Medicare relaxed many of its longstanding telehealth restrictions to enable broader access to virtual care. These flexibilities included waiving geographic limitations, permitting beneficiaries to receive telehealth in their homes, and authorizing certain services—such as behavioral health and chronic care management—to be delivered remotely. These waivers were critical in ensuring continuity of care when in-person access was limited.
However, many of those flexibilities were tied to temporary emergency authorities and were set to expire absent congressional action. As of October 1, 2025, in the absence of new legislation, Medicare’s pre-pandemic rules for non-behavioral health telehealth services have resumed, ending most of the temporary flexibilities that had been in place since the COVID-19 public health emergency. In response, CMS issued new guidance to clarify how Medicare Administrative Contractors (MACs) should handle telehealth claims and provider billing during the transition period.
What the CMS guidance says: claims hold, reinstated limits, and provider cautions
CMS issued a Medicare Learning Network (MLN) Connects Newsletter update on October 1, 2025, directing all MACs to place a temporary 10-business-day hold on telehealth claims to avoid reprocessing if Congress restores pandemic-era flexibilities. The MLN update titled, “Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors,” states that Providers may continue submitting claims, but payments will not be released until the hold is lifted. CMS noted the delay should have minimal impact given Medicare’s existing 14-day payment floor.
The update further confirms that, with the expiration of the statutory telehealth “extenders,” Medicare coverage has reverted to pre-pandemic limits. This means most beneficiaries must again be located in a rural health clinic or hospital to receive telehealth from a distant-site provider, and audio-only visits are now limited to behavioral health services. Certain practitioner types, including occupational therapists, physical therapists, speech-language pathologists, and audiologists, can no longer bill for telehealth. However, under the Bipartisan Budget Act of 2018, clinicians in eligible Medicare Shared Savings Program ACOs may continue providing covered telehealth services without geographic restrictions, including when the beneficiary is at home.
CMS advised that practitioners offering non-covered telehealth services should consider issuing Advance Beneficiary Notices of Noncoverage (ABNs) and may choose to hold claims pending congressional action on reinstating the flexibilities.
What’s Next
Congressional intervention remains the key variable. If lawmakers act to restore or extend telehealth flexibilities, CMS may lift the claims hold and re-enable broader reimbursement retroactively. In the meantime, providers should monitor legislative and CMS updates, consider issuing ABNs for non-covered services, and decide whether to hold telehealth claims pending further guidance. They should also review compliance practices to ensure adherence to the reinstated geographic and practitioner restrictions now in effect.
Various MACs have made CMS’s update available on their websites. For example, the update can be found on Noridian’s website, available here.
