The telehealth flexibilities set to expire include:
 

• Audio-only coverage for some non-behavioral/mental telehealth services: Prior to the pandemic, a telehealth visit required a video and audio connection. Removing the video requirement made it easier for patients in low-broadband areas to access telehealth visits.
• No geographic restrictions for originating site for non-behavioral/mental telehealth services: Prior to the pandemic, telehealth visits were only reimbursable if the patient was in a designated rural area and a healthcare clinic at the time of the visit. This flexibility allowed patients in any geographic region and location (most importantly, their homes) to conduct a telehealth visit.
• Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can serve as a distant site provider for non-behavioral/mental telehealth services: Prior to the pandemic, FQHCs and RHCs were originating sites, meaning providers had to be in the clinic to be reimbursed for telehealth. This flexibility allowed FQHCs and RHCs to serve as distant sites, meaning providers working for a FQHC or RHC could provide services from other locations, like their homes.
• An in-person visit within six months of an initial behavioral/mental telehealth service is not required: Prior to the pandemic, patients had to have an in-person visit to be eligible for telehealth visits. This requirement was removed during the pandemic to extend access when in-person care is limited.
• Telehealth services can be provided by all eligible Medicare providers: Prior to the pandemic, only certain licensed providers could provide telehealth care. This flexibility allowed more clinicians, including physical therapists, speech-langue therapists, occupational therapists, and audiologists, to provide and be reimbursed for telehealth services. 

The American Telemedicine Association has urged Congress to make the telehealth flexibilities permanent because of telehealth’s “critical role in our evolving healthcare system by expanding access to care, reducing costs, and mitigating the negative impact of provider shortages, effectively making the health care system more efficient.” However, it’s unlikely that Congress will act on telehealth during an election year. The more likely scenario is that the flexibilities will be extended again until more permanent action can be taken.

In the meantime, providers are forced to navigate an uncertain landscape without assurance that the telehealth flexibilities will continue. Many providers have told us that they intend to keep providing telehealth because they don’t feel comfortable taking it away from their patients or clinicians. They’ve seen better patient engagement and higher patient retention due to telehealth, and they don’t want to jeopardize that.  

However, the uncertainty around reimbursement is easier for some providers to navigate than others. Providers that are in majority risk or value-based contracts can continue to bet on telehealth. Providers that are largely still fee-for-service will likely maintain existing investments (like virtual visits platforms) rather than expand their telehealth programs.