Telehealth Rules Just Changed: What Stays, What Goes, and What It Means for Your Practice
- As of February 1, 2026, new patients require an in-person visit within the prior 6 months before starting Medicare telehealth services — ending the COVID-era waiver for fully remote intake
- Established Medicare patients must now be seen in person at least once every 12 months to continue telehealth sessions
- Audio-only telehealth for mental/behavioral health is permanently allowed — this is no longer a temporary flexibility
- Geographic and location restrictions for mental health telehealth are permanently removed — patients can receive care at home, including in urban areas
The hybrid model is now the permanent standard. Congress let the COVID-era telehealth flexibilities expire on February 1, 2026 — but not all of them. What remains reshapes how psychiatrists and therapists must structure their practices: some in-person contact required, but the geographic barriers are gone for good.
What changed
Two requirements now apply to Medicare telehealth. First, new patients must have had an in-person visit within the past six months before their first telehealth session. This ends the fully remote intake model that many practices built during COVID. Second, established patients must be seen in person at least once per 12 months to maintain telehealth eligibility.
These are not bureaucratic inconveniences. They are structural changes that affect scheduling, office space decisions, and patient accessibility. A practice that went fully virtual must now maintain some physical presence.
What survived permanently
Two COVID-era flexibilities became permanent law. Audio-only telehealth for mental and behavioral health services is now a permanent benefit — not a temporary waiver. This matters for patients without reliable broadband, smartphone cameras, or private spaces for video calls. It is an access equity provision.
Geographic and originating site restrictions are permanently removed for mental health. Patients can receive telehealth from home, regardless of whether they live in a rural or urban area. This was the single biggest barrier to telehealth access pre-COVID, and it is now permanently gone.
What this means in practice
The new model is hybrid by design, not by choice. Pure telehealth practices serving Medicare patients must adapt — either by establishing in-person visit capacity or by limiting their panel to patients who can travel to them. Private-pay and commercial insurance practices are not directly affected by Medicare rules, but commercial payers typically follow Medicare's lead within 12–18 months.
The hybrid model is now permanent law — some in-person contact required for Medicare telehealth, but geographic barriers are gone for good.
Rules apply to Medicare; commercial payer policies vary. State-level telehealth laws add additional complexity. Implementation details may evolve through CMS guidance.