For most of the last six months, the question we heard most from practice managers was not about coding. It was "can we still do video visits for Medicare patients this week?" The honest answer changed three times. The flexibilities that had been in place since 2020 lapsed on October 1, 2025 when the federal government shut down. A continuing resolution signed November 12, 2025 restored them through January 30, 2026 and CMS instructed contractors to reprocess held claims. Then they lapsed again on January 31, 2026, along with a partial shutdown, and Medicare Administrative Contractors were told once more to hold telehealth claims rather than deny them.
On February 3, 2026 the President signed the Consolidated Appropriations Act, 2026, which ended the shutdown and extended the core Medicare telehealth flexibilities through December 31, 2027. Two years is the longest runway practices have had since the public health emergency ended in May 2023. It is worth spending an hour this month making sure your telehealth billing is set up correctly for it, and cleaning up whatever broke during the gaps.
This article is the rulebook as it stands in March 2026 for traditional Medicare, plus the checks we are running for billing clients on the claims from October through February.
Key takeaways
- The geographic and originating site waivers, the expanded practitioner list, FQHC and RHC distant site status, audio-only coverage and the delay of the tele-mental health in-person requirement all run through December 31, 2027.
- Medicare still wants office E/M codes 99202 to 99215 with POS 10 or POS 02, not the CPT telemedicine codes 98000 to 98015. Audio-only visits need modifier 93.
- Every telehealth encounter from October 1, 2025 through February 3, 2026 should be checked for an accepted claim and a remittance. Held claims that were never released are the most common leak.
- Medicare Advantage plans set their own telehealth coding rules. Keep a payer-by-payer matrix.
How we got here
| Date | What happened | Effect on claims |
|---|---|---|
| October 1, 2025 | Government shutdown; statutory telehealth flexibilities expire | MACs instructed to hold telehealth claims for dates of service from October 1 |
| November 12, 2025 | Continuing resolution signed, extending flexibilities through January 30, 2026 | Held claims released and paid; retroactive to October 1 |
| January 31, 2026 | Flexibilities lapse again; partial shutdown begins | MACs hold telehealth claims and return, rather than deny, those submitted during the lapse |
| February 3, 2026 | Consolidated Appropriations Act, 2026 signed; flexibilities extended through December 31, 2027 | Claims for the lapse period payable; hold lifted |
The two lapses were short, but both fell at the start of a month, and both caught practices that had scheduled a week of chronic care follow-ups by video. The reprocessing happened automatically for claims the MAC was holding. It did not happen for claims a practice was holding in its own system.
What is extended
The act carries forward the same set of waivers Congress has been renewing since 2022:
- The geographic and originating site restrictions are waived, so a Medicare patient at home in a metropolitan area can be seen by telehealth.
- The list of practitioners who can bill telehealth stays expanded to include physical therapists, occupational therapists, speech-language pathologists and audiologists.
- Federally Qualified Health Centers and Rural Health Clinics can continue as distant site providers.
- The in-person visit requirement for tele-mental health services is delayed again.
- Audio-only telehealth remains payable for patients who cannot or will not use video.
- The Acute Hospital Care at Home waiver is extended as well.
What did not change: the extension is statutory and time-limited. Nothing here is permanent, and December 31, 2027 will arrive with the same cliff unless Congress acts again. We think practices should keep telehealth as part of the schedule but avoid building a business model that depends on it surviving 2028 unchanged.
How to bill it correctly in 2026
Medicare has not adopted the CPT telemedicine E/M codes 98000 to 98015 that the AMA introduced for 2025. For Medicare patients you continue to bill the office E/M codes 99202 to 99215 and use place of service and modifiers to indicate telehealth. The one exception is 98016, the brief virtual check-in code that replaced G2012, which Medicare does pay. Many commercial payers accept the full 98000 series, so your charge master needs both paths.
| Situation | Medicare coding | Notes |
|---|---|---|
| Video visit, patient at home | 99202 to 99215 with POS 10 | POS 10 pays at the non-facility rate |
| Video visit, patient at another location (clinic, SNF) | 99202 to 99215 with POS 02 | POS 02 pays at the facility rate |
| Audio-only visit, patient at home | 99202 to 99215 with POS 10 and modifier 93 | Patient must be unable or unwilling to use video and the provider must be capable of video; document both |
| Brief virtual check-in, established patient | 98016 | Five to ten minutes, patient-initiated, not related to a visit in the prior seven days |
| Tele-mental health, established patient | 90832 to 90838, 90791 with POS 10 | In-person requirement still delayed |
| Commercial payer that accepts CPT telemedicine codes | 98000 to 98015 | Verify each payer; some still want 99202 to 99215 with modifier 95 |
Modifier 95 is no longer needed on most Medicare telehealth claims because place of service carries the information, but some Medicare Advantage plans and many commercial payers still require it. Keep a payer-by-payer matrix and check it against the first remittances every quarter.
A worked example: a 71-year-old established patient with hypertension and type 2 diabetes has a video follow-up from home on March 10, 2026. The physician reviews home blood pressure logs, adjusts one medication and orders labs. Moderate medical decision making supports 99214. The claim carries 99214, POS 10, no telehealth modifier, and the diagnosis codes for both conditions. If the patient's video failed and the visit finished by phone, the claim is 99214, POS 10, modifier 93, and the note says why. The payment is the same non-facility rate either way.
Documentation that survives an audit
The telehealth audits we have seen from Medicare contractors and from MA plans ask for the same handful of things: the patient's location at the time of the visit, the provider's location, the modality (video or audio), the patient's consent to a telehealth visit, and for audio-only visits the reason video was not used. None of that is clinically interesting and all of it is easy to miss when a template was built for in-person visits. A five-field telehealth block at the top of the note, filled in by the medical assistant during rooming, covers it. The E/M level is then supported the same way it would be in person: by medical decision making or by total time on the date of the encounter.
One habit we push hard: record the start and end time of every telehealth visit even when you code by medical decision making. Audio-only visits in particular get questioned, and a documented 18-minute call is much easier to defend than a note with no duration at all.
Cleaning up from the gap
Three things went wrong in practices during the fall and winter lapses, and all three should be checked now.
Held claims that were never released. CMS told Medicare Administrative Contractors to hold telehealth claims for dates of service from October 1, 2025 while Congress acted, then to process them once the November extension passed, and repeated the instruction for the January 31 to February 3 lapse. Most were paid automatically. Some practices, though, held claims in their own systems on advice from a vendor and never released them. Pull every telehealth encounter from October 1, 2025 through February 3, 2026 and confirm each has an accepted claim and a remittance.
Patients billed as self-pay. Some practices converted Medicare telehealth visits to self-pay during the October lapse because they were told Medicare would not cover them. Those visits are now payable, the patient is owed a refund of anything beyond the normal coinsurance, and the claim should be submitted to Medicare. Timely filing for Medicare is one year from the date of service, so there is time, but do not let it drift.
Visits that were cancelled. Nothing to bill, but check the recall list. Patients whose chronic care follow-ups were cancelled in October and never rescheduled are a care gap and a lost visit.
Medicare Advantage is a separate question
The statutory flexibilities govern traditional Medicare. Medicare Advantage plans have always been able to offer telehealth as a supplemental benefit and most did throughout the lapses. Their coding rules, however, vary. Some require modifier 95, some require GT, some pay audio-only at a reduced rate, and CMS has proposed for the 2027 payment year that diagnoses captured only on audio-only encounters be excluded from risk adjustment, which will change how plans behave toward those visits. Check each MA plan's provider manual and note the rules on your matrix.
Questions we hear
Can a new patient be seen by video?
Yes for traditional Medicare under the extended waivers, using 99202 to 99205 with POS 10. Document that the patient consented to telehealth and note the patient's location at the time of the visit.
Do we need the patient's home address on the claim?
Not on the claim, but it belongs in the note. Several audits we have seen asked for the patient location and the provider location for each telehealth encounter. A one-line template field for both solves it.
Should we bill G2211 with telehealth E/M?
Medicare allows the G2211 complexity add-on with office E/M codes including those furnished by telehealth, when the longitudinal relationship criteria are met. Since 2025 it is payable with modifier 25 only when the E/M is billed with an annual wellness visit, vaccine administration or another Part B preventive service on the same day. Apply the same rules you use in person.
What to do this month
- Export every telehealth encounter from October 1, 2025 through February 3, 2026 and confirm each has an accepted Medicare claim and a remittance. Release anything still on hold in your system.
- Find visits converted to self-pay during the lapses, bill Medicare, and refund the patient.
- Check that your charge master carries 99202 to 99215 with POS 10 and 02 for Medicare and the 98000 series for the commercial payers that accept it, and that 98016 replaced G2012.
- Add or confirm the five-field telehealth block in your visit template: patient location, provider location, modality, consent, and reason for audio-only.
- Update the payer matrix with each MA plan's telehealth modifier and audio-only rules, and check it against March remittances.
If telehealth denials are a recurring line in your denial reports, the usual cause is a place of service or modifier mismatch with one payer, not a coverage problem. A twenty-claim sample usually finds it, and it is one of the first things we check in an RCM audit.
