Navigating Post-Pandemic Compliance Changes in Medicare Telehealth

Emily Manning of Rivkin Radler LLP reports that several temporary Medicare telehealth flexibilities expired on September 30, marking a significant shift in compliance requirements for healthcare providers. During the COVID-19 pandemic, 

Medicare had allowed broad telehealth access, including from patients’ homes and via audio-only communication. Those temporary rules expanded access to care but have now reverted to pre-pandemic standards, with key implications for reimbursement and compliance monitoring.

The most impactful change involves the reinstatement of the “originating site” requirement. Except for behavioral and mental health services, Medicare beneficiaries must now receive telehealth care from approved sites, such as healthcare facilities or rural health clinics, rather than from home. Manning notes this change could particularly affect seniors and patients in underserved areas who benefited from home-based virtual visits.

Medicare has also ended coverage for most audio-only telehealth visits, again with the exception of behavioral health services. Providers must now use both audio and video technology to qualify for reimbursement, creating access challenges for patients without reliable internet connections or video-enabled devices.

Additionally, the list of practitioners eligible to furnish Medicare-covered telehealth services has narrowed. Manning explains that while the pandemic temporarily expanded eligibility to include physical, occupational, and speech therapists, as well as audiologists, the rules now limit coverage to physicians, physician assistants, advanced practice nurses, certain behavioral health professionals, and registered dietitians.

For compliance officers and healthcare administrators, organizations must promptly update billing systems, verify patient site information, and confirm communication methods before each telehealth appointment to remain compliant and avoid reimbursement denials.