Be prepared for important 2026 proposed changes to Medicare telehealth policy

The Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule, outlining updates to telehealth policies aimed at streamlining access and supporting care delivery, especially in rural and underserved communities.

These proposed changes reflect CMS' commitment to expanding telehealth access, particularly behavioral health services, while balancing oversight and quality of care.

Key proposals

PFS proposed rule key proposals include:

• Elimination of Provisional vs. Permanent Distinction. CMS proposes to remove the distinction between provisional and permanent telehealth services. Instead, the focus would be on whether a service can be furnished safely via interactive, two-way audio-video technology, simplifying the process for adding services to the Medicare Telehealth Services List.
• Removal of Frequency Limits. Frequency limitations on subsequent inpatient visits, nursing facility visits, and critical care consultations — CPT codes 99231–99233, 99307–99310, G0508 and G0509 — would be permanently removed, allowing more flexible use of telehealth for these services.
• Virtual Direct Supervision. CMS proposes to permanently allow physicians and supervising practitioners to provide required direct supervision through real-time audio and video interactive telecommunications, excluding audio-only.
• Teaching Physician Presence. The rule proposes reverting to pre-pandemic policy, requiring teaching physicians to maintain physical presence during critical portions of resident-furnished services, except in certain rural areas.
• Digital Mental Health Treatment (DMHT) and Digital Therapeutics (DTx) Expansion. CMS proposes expanding DMHT coverage to include FDA-authorized DTx for conditions such as ADHD.
• Originating Site Facility Fee Increase (Q3014). The telehealth originating site facility fee, HCPCS Q3014, would increase to approximately $31.85 in CY 2026, reflecting a 2.7% inflationary update.