Most providers not ready for telehealth flexibilities to expire

A majority of healthcare providers feel underprepared for a rollback of Medicare telehealth flexibilities if they are left to expire at the end of September, according to a new Black Book Research report.

Flexibilities enacted to expand Medicare telehealth access during the COVID-19 pandemic will expire on Sept. 30, 2025, unless Congress extends them. The flexibilities include eliminating geographic restrictions for telehealth services, allowing rural health clinics and federally qualified health centers to continue offering telehealth and enabling audio-only telehealth coverage.

Telehealth proponents expect the flexibilities to be extended; however, if they are not, healthcare providers will face several challenges, according to the Black Book report.

The report is based on survey insights collected in August 2025. Black Book Research polled 431 telehealth providers from hospitals, physician practices and ambulatory clinics.

Most respondents (71%) reported being only somewhat prepared or not at all prepared for the flexibilities to expire, with 84% noting that their compliance and IT teams do not have formal response plans. Only 8% said staff had been trained or briefed on the upcoming changes.

The survey also uncovered technological gaps and privacy and security concerns that could increase healthcare provider burdens if the flexibilities expire.

About 41% of organizations expressed low confidence in managing overlapping federal and state mandates, while 59% were uncertain whether their systems currently meet CMS encryption and authentication standards. Additionally, less than one-third of respondents said they had completed vendor audits for telehealth compliance. The report noted that organizations risk billing for ineligible telehealth encounters or failing security requirements without audits.

Further, survey respondents pointed to operational challenges and health inequities that may result from a rollback of the telehealth flexibilities.

Approximately 62% of respondents anticipate disruptions in scheduling and care delivery, and 47% expect a significant loss of patient engagement, primarily among those who use audio-only telehealth.

Most respondents (65%) also fear reduced telehealth access for vulnerable populations, particularly elderly, rural and minority patients, while 89% anticipate significant billing confusion and reimbursement losses.

The report highlighted several recommendations for healthcare providers, vendors and policymakers, including developing contingency plans, offering platforms with built-in consent management and audit trails and developing a clearer federal strategy for telehealth reimbursement.

"The September 2025 telehealth policy cliff represents a pivotal moment for U.S. healthcare. It is both a risk -- jeopardizing access, reimbursement, and compliance -- and an opportunity to build a stronger, smarter national telehealth infrastructure," the report 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.