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How providers can prepare for the upcoming telehealth cliff
Telehealth flexibilities are set to expire on Jan. 30, 2026, but there are strategies that can help healthcare providers navigate the ongoing uncertainty.
New year, same problem -- at least for telehealth providers.
Following a 43-day government shutdown last October, which also halted telehealth flexibilities, virtual care providers were granted a short-term reprieve. The pandemic-era flexibilities that have significantly eased access to telehealth services nationwide were extended through Jan. 30, 2026.
But this means that telehealth providers are already staring down the barrel of another telehealth cliff, a frustrating yet familiar space.
"Having uncertainty in the mix is just making it very difficult to do any sort of strategic planning or concrete strategic planning," said Bragg Hemme, a healthcare regulatory attorney at Polsinelli law firm.
"[Providers are] kind of just stuck in this midst of uncertainty where they have to plan for change, but they don't know what that change is going to be," she continued. "And a key component of that change is coming to them in three-month spurts or six-month spurts, even annual spurts."
Navigating this uncertain terrain will require providers to remain agile and create contingency plans for various potential outcomes.
Managing the telehealth policy uncertainty
Though nobody can accurately predict whether or not the waivers will be extended, Hemme noted that providers can look back to the 2025 government shutdown to glean insights into what another expiration will mean for them.
For instance, CMS retroactively paid for telehealth services provided during the 2025 shutdown. Hemme suggested that providers develop plans to financially manage situations in which they may not receive payment on time or at all.
She added that while some organizations will be able to manage the financial risk, others may have to halt services.
"It really is assessing your risk tolerance, paying close attention to federal and state rules, and making sure you understand the finances if you get paid under model A versus model B -- with the flexibilities and without flexibilities," she said.
Another strategy to mitigate the negative impacts of waiver expiry is to include contingencies in vendor contracts, particularly if your payer mix is heavily weighted toward Medicare. Examples of contingencies include language in contracts that defines responsibilities for telehealth services provided in the event that the flexibilities lapse.
It may also be worthwhile for providers to adjust their payer mix regarding telehealth services to mitigate financial risk.
"Making sure that your payer contracts are not tied to the Medicare rules with respect to telehealth, I think, is insulating as well," said Hemme. "So that you're still investing in that infrastructure and those technologies for the purposes of all of your payers, even if Medicare isn't able to pay."
Hemme also noted that potential increases in the uninsured population could make a case for providers continuing to invest in telehealth. Even with the uncertainty around Medicare reimbursement for the services, telehealth could enable providers to extend care to a larger swath of the population at a reduced cost.
In addition to making contingency plans and adding safety valves to their vendor contracts, healthcare providers must keep a close eye on the shifting policy and reimbursement landscape for virtual care. Hemme recommended monitoring federal agency websites, including the HHS, paying attention to the legislature when it's in session and getting on state Medicaid agency mailing lists.
Advocating for action on telehealth flexibilities
Preparing internally for the push-and-pull of telehealth waiver extensions is critical, but it is also important to advocate for longer extensions or for making them permanent.
"[Providers] need to be able to plan for the next evolution of healthcare right now, and that technology piece, and whether or not they can get paid for it, is a key component of that," Hemme underscored. "And so, they really need some certainty."
Industry groups agree, and 2026 has brought with it renewed calls urging Congress to act on this issue.
On Jan. 6, 2026, the American Telemedicine Association (ATA) issued a statement "urging Congress to act swiftly and sensibly to avoid another lapse in telehealth services."
"Congress and the Administration have demonstrated longstanding bipartisan leadership and historic support for telehealth over the past six years, and the American people and their healthcare providers have embraced these tech-enabled solutions, which have proven to be lifesaving strategies for extending care delivery to patients everywhere," said Alexis Apple, vice president of federal affairs at the ATA and deputy executive director of ATA Action.
"We are counting on our government champions to find a permanent solution or at least to establish a long-term extension for these telehealth waivers," she continued.
Similarly, the American Medical Association (AMA) released an issue brief on Jan. 5, 2026, detailing how telehealth has benefitted patients and providers, including expanding healthcare access, ensuring care continuity and enhancing efficacy.
The brief also cites evidence showing that telehealth can be an effective substitute for in-person care, boost appointment completion rates and lower hospital readmissions.
"The continued reliance on temporary extensions has created instability for providers and patients," the brief states. "Congress stands at a pivotal policy juncture. Permanent telehealth reform is not only necessary to preserve the expanded access achieved during the pandemic, but it is also aligned with CMS's broader digital transformation agenda."
The broader agenda refers to the CMS Health Tech Ecosystem Initiative, which was announced in July 2025. The initiative brought various stakeholders together, including health systems, tech companies and payers, to commit to improving information sharing by establishing an interoperability framework and increasing the availability of personalized tools.
"These efforts lay the groundwork for a patient-centric, tech-enabled health system, but cannot succeed without concurrent updates to coverage, payment and policy," the brief states.
Anuja Vaidya has covered the healthcare industry since 2012. She currently covers the virtual healthcare landscape, including telehealth, remote patient monitoring and digital therapeutics.
