Changes to Medicare Payment for Telehealth Services in Proposed 2026 Physician Fee Schedule Rule

At a Glance

• CMS proposes a streamlined three-step process for adding telehealth services, removing the “provisional” label and reducing administrative burden.
• CMS recommends adding several behavioral and specialty services to the telehealth list, while removing or declining others that don’t meet statutory criteria.
• Proposed changes would lift visit frequency limits and allow direct supervision via video for most services, expanding access and easing compliance.

CMS published its CY 2026 Medicare Physician Fee Schedule Proposed Rule on July 16, 2025. Following is a summary of the proposed changes affecting telehealth services.

Changes to the Telehealth Services List and Review Process

Streamlined Review Process

CMS proposes to simplify the process for adding or removing services from the Medicare Telehealth Services List. The current five-step process will be reduced to three steps: 

• Step 1: Is the service separately payable under the Physician Fee Schedule (PFS)?
• Step 2: Is the service subject to section 1834(m) of the Social Security Act (i.e., would it normally be face-to-face)?
• Step 3: Can each element of the service be provided via an interactive telecommunications system?

CMS learned from prior feedback that the current five-step process for reviewing telehealth services is seen as unclear and administratively burdensome, particularly regarding the level of clinical evidence required for a service to move from provisional to permanent status. CMS believes that physicians and practitioners — with their clinical expertise and knowledge of patient needs — should be trusted to exercise professional judgment regarding telehealth's appropriateness. By eliminating steps requiring mapping to existing services or direct evidence of equivalency to in-person care, CMS aims to simplify the process, reduce administrative burden, and prioritize patient and practitioner choice while maintaining necessary safety guardrails.

Removal of “Provisional” vs. “Permanent

All services on the list will be considered "permanent" if they meet the new three-step criteria. The distinction between provisional and permanent status will be eliminated. 

Proposed Additions and Deletions to the Telehealth Services List

CMS applied the above criteria to the requests for changes to the Medicare Telehealth Services List for CY 2026. To additions, services must be separately payable, typically furnished face-to-face and capable of being delivered via telecommunications technology.  For deletions or non-inclusions, CMS found that some codes (a) do not involve direct physician/practitioner interaction (e.g., certain codes are clinical staff only); (b) are not separately payable under the PFS; or (c) are inherently non-face-to-face and thus do not fit the statutory definition of telehealth. Thus, it recommends the following changes to the List for CY 2026:

Proposed Additions for CY 2026:

• Multiple-Family Group Psychotherapy (CPT 90849).
• Group Behavioral Counseling for Obesity (G0473).
• Infectious Disease Add-On (G0545).
• Auditory Osseointegrated Sound Processor (92622, 92623).

Not Proposed for Addition:

• Dialysis Procedures (CPT 90935, 90937, 90945, 90947), as more is information needed on how these can be furnished via telehealth.
• Home INR Monitoring (G0248): Typically furnished by clinical staff, not physicians/practitioners, and thus outside the definition of telehealth services under the Act.
• Telemedicine E/M Services (CPT 98000-98015): Not separately payable under the PFS.
• Digital Mental Health Treatment, Remote Physiologic Monitoring, Remote Therapeutic Monitoring: Not considered telehealth services under section 1834(m).

Proposed Deletion:

• Social Determinants of Health Risk Assessment (HCPCS code G0136) will be deleted from the list if the proposal is finalized.

Frequency Limitations

Permanent Removal of Frequency Limits

CMS proposes to permanently remove prior frequency restrictions for subsequent inpatient and nursing facility visits, and critical care consultations furnished via telehealth. CMS determined that clinicians are best positioned to determine how frequently telehealth visits are appropriate, depending on each patient's clinical needs. This approach aligns with the broader CMS philosophy of emphasizing professional judgment and individualized care, while also reducing unnecessary regulatory constraints.

Payment Policy Updates

Originating Site Facility Fee

CMS proposes to increase the telehealth originating site facility fee (HCPCS Q3014) will increase to $31.85 in CY 2026, reflecting a 2.7% increase in the Medicare Economic Index (MEI).

The increase based on the MEI is a standard economic adjustment to reflect inflation and changes in practice costs. This ensures that payment keeps pace with economic realities and supports access to telehealth services at originating sites. 

Direct Supervision and Teaching Physician Policies

Direct Supervision

CMS proposes to permanently allow "direct supervision" to be met via real-time audio/video technology (excluding audio-only) for most services, except for procedures with a 10- or 90-day global period.

CMS believes that allowing direct supervision to be met via real-time audio/video will increase flexibility and access, while excepting high-risk procedures (those with global periods) will maintain patient safety.

Teaching Physician Billing

CMS proposes to revert to pre-pandemic policy for teaching physicians in urban areas, requiring physical presence for billing, with continued flexibility for rural locations.

CMS believes requiring in-person supervision in urban teaching settings will ensure appropriate oversight and involvement by teaching physicians, fulfilling their statutory obligations for hands-on supervision. However, CMS understands that flexibility is required for rural settings, recognizing unique challenges in rural healthcare and the need to support access to education and services.

Comments

CMS is soliciting comments on the above proposals, especially regarding clinical appropriateness, patient safety and any concerns relating to specific services or supervision modalities. Comments can be submitted electronically to http://www.regulations.gov and will be due on September 15, 2025.