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Telehealth flexibilities expired. Here's how providers are coping.
Telehealth flexibilities ended on Sept. 30, forcing providers to halt new virtual visits, risk financial losses or drive hundreds of miles for rural patient care.
The expiration of telehealth flexibilities has cast virtual care providers back to a pre-pandemic world, one where various restrictions curb access to telehealth for Medicare fee-for-service beneficiaries. This has not only had a significant impact on the operations and finances of these providers but also led to concerns about the future of telehealth access.
Following the onset of the COVID-19 public health emergency, Congress implemented several waivers to ensure virtual access to healthcare amid in-person care restrictions. These waivers increased the number of geographic locations from which Medicare beneficiaries can receive telehealth services, expanded the types of healthcare practitioners who could offer telehealth, extended Medicare reimbursement for telehealth services provided by federally qualified health centers (FQHCs) and rural health centers and enabled coverage for audio-only telehealth.
The telehealth flexibilities increased access and eased the adoption of virtual care models. However, despite considerable bipartisan support, the flexibilities ended on Sept. 30, 2025.
Though telehealth providers are attempting to remain optimistic about the flexibilities being reinstated when the government reopens, navigating the current rollback and ongoing uncertainty is proving a challenge for telehealth providers of all types.
Financial & operational impact on telehealth providers
Telehealth has become an integral part of the healthcare delivery system. Although telehealth volumes have declined since the height of the PHE, it remains a key mechanism for delivering chronic and acute care across the country.
In a survey conducted before the waivers expired, providers highlighted their concerns with losing expanded telehealth access. A majority of survey respondents anticipated significant billing confusion and reimbursement losses (89%), while 62% of respondents anticipated disruptions in scheduling and care delivery.
In the immediate aftermath of the shutdown, some telehealth providers stopped taking appointments in September, while others are attempting to maintain operations, taking on significant financial risk.
For instance, Johns Hopkins Medicine proceeded with visits scheduled before the shutdown.
"We've had these sorts of telehealth cliffs happen a number of times over the past five years, and we've always sort of prepared for the worst and hoped for the best, which is what we did in this circumstance," said Helen Hughes, M.D., medical director of Johns Hopkins Medicine's Office of Telemedicine. "So, we chose not to change our processes leading up to October 1st. But on October 1st, we started holding Medicare telehealth claims and awaiting further guidance from CMS."
The health system has continued to deliver pre-scheduled care, banking on receiving retroactive reimbursement from Medicare once the government shutdown is over, she added.
However, as the shutdown has dragged on, Johns Hopkins is revisiting its approach.
"[We're] making some challenging decisions about potentially limiting our new or additional Medicare telehealth visit scheduling just to decrease some of the uncertainty," Hughes said.
Access TeleCare, a provider of acute and specialty telemedicine, is facing similar difficulties while continuing to provide care.
"We're making sure there's no gaps in care and that patients are receiving timely care," said Chris Gallagher, M.D., CEO of Access TeleCare. "And so, the care we gave on September 30th is the same care we gave on October 1st, and is the same care we're going to give on October 31st. That obviously can't continue forever, but in the immediate timeframe, we are definitely going at risk."
While the provider is not required to provide advanced beneficiary notices -- notices informing the beneficiary that they may be responsible for the cost of the service -- to patients receiving emergency care, they are providing them to patients receiving outpatient services.
With patients responsible for the cost, telehealth reimbursement will likely be more unstable than it was under the waivers, which will ultimately impact telehealth delivery and patient outcomes.
Gallagher pointed out that the lack of certain reimbursement could result in stymied telehealth access in hospitals and outpatient settings. Regarding the acute virtual care that Access TeleCare provides, this could mean a greater number of facility transfers for inpatients, which typically has an adverse effect on morbidity and mortality.
Disruptions to rural telehealth providers
In rural areas, telehealth increased access to healthcare while reducing burdens on rural providers. Without the services, rural providers may face challenges in seeing their patients regularly, particularly those who cannot travel for in-person care.
This is the problem Joe Miller, M.D., is facing. Miller, a family physician and medical director for Hillcrest Hospice, relies on telehealth to ensure healthcare access for patients who require frequent recertifications to remain in hospice.
Miller explained that when a person enters hospice care, they are initially certified for 90 days and then must be recertified for another 90 days, followed by recertification every 60 days to remain eligible for hospice care. Telehealth has been immensely beneficial for this recertification process.
"The nice thing about telehealth is, a lot of times, we can schedule it when it's going to be very convenient not only for the patient but for the family," Miller said. "And then I can not only talk to and check the patient, but also talk to the family, answer their questions, and really provide better care for those patients."
Without telehealth, the recertification process becomes harder for patients and physicians alike. Miller is already clocking in hundreds of miles to ensure his patients' care can continue.
"There's a [recertification that] needs to be done by Sunday," he said at the time of the interview in late October. "And, so on Saturday, I will drive to go to see this patient so that we can get it done, so we can continue her care. I happen to be on a family vacation with my family, and I'm driving back right now, but I'll go do that just simply because we have to do it."
This may not be possible for Miller to continue in the long term. Eventually, he explained, the hospice will need to hire nurse practitioners to conduct these recertification exams in person. Nurse practitioners can conduct the exams, but they still report to physicians, who must ultimately sign off on the recertification.
Not only would hiring more providers to conduct recertifications increase costs for hospice facilities, but it would also disrupt continuity of care for patients.
"We are putting another person in the middle that doesn't have the experience that a medical director would," Miller said. "And I think that that isn't necessarily good care for the patient, and it's more expensive care."
The impact of removing a vital care access mechanism, such as telehealth, is particularly apparent in rural areas. Between adding travel burdens for providers and patients, as well as the potential need for additional providers amid shortages, ending telehealth flexibilities does not bode well for rural healthcare.
What providers need to stabilize telehealth delivery
Telehealth providers are optimistic that this period of uncertainty will not last long.
"We are still very hopeful that Congress will come through on this issue," Hughes said. "Our understanding is that Medicare telehealth has bipartisan support. Medicare beneficiaries have had access for five-plus years. We think it's very unlikely that, once the government reopens, a package will be passed that does not include Medicare telehealth. So, I think we're operating under the assumption that this will eventually be a permanent care modality and that this is a temporary -- temporary yet painful -- process that is unfortunately a consequence of the shutdown."
To avoid future upheaval in telehealth care delivery, providers are urging Congress to make the waivers permanent.
A letter signed by more than 450 telehealth and provider organizations and sent to Congressional leaders on Nov. 4, 2025, stated that "This cycle of temporary fixes has resulted in patients and providers facing continued disruptions in care. Providers are faced with decisions between providing the necessary care for their patients and cutting access to clinicians and services they are providing virtually."
Gallagher echoed this sentiment, adding that, in lieu of permanency, Congress needs to sign off on another extension as soon as possible.
According to Hughes, it would also be immensely helpful if the telehealth waiver deadlines were decoupled from the government funding deadlines.
Further, Hughes noted that the Congressional Budget Office's estimation that extending telehealth could cost billions is hampering the continuation of telehealth flexibilities.
"In our experience, telehealth visits for Medicare beneficiaries typically substitute for in-person care as opposed to being additive, extra visits. So, it's hard for us to understand where that score comes from," she said. "It would be great if CBO could revisit that score, given that now we are five to six years past the start of the pandemic, we likely have more data to help us understand the true cost."
Ensuring consistent and affordable telehealth services is critical for the providers and patients who have come to depend on the care modality. While several factors are driving Congress' inability to end the shutdown, its impact is leaving providers and patients without a critical tool in the care access arsenal.
Anuja Vaidya has covered the healthcare industry since 2012. She currently covers the virtual healthcare landscape, including telehealth, remote patient monitoring and digital therapeutics.