Are Medicare telehealth flexibilities permanent?

No. The extension runs through December 31, 2027. Congress would need to act again to extend or make them permanent.

Do commercial payers follow Medicare telehealth rules?

Not necessarily. Commercial payers and state Medicaid programs set their own rules for covered services, place of service, modifiers and audio-only visits, so check each payer.

Which modifiers do telehealth claims need?

It depends on the payer. Common ones include 95 (synchronous audio-video), 93 (synchronous audio-only) and, for some payers, GT. Always confirm the payer’s current policy.

Medicare Telehealth Through 2027: Billing Checklist

The Consolidated Appropriations Act, 2026 (H.R. 7148), signed February 3, 2026, extended key Medicare telehealth flexibilities through December 31, 2027, after a brief lapse beginning January 31, 2026 that the law covered retroactively.

By Bill For You RCM · Published October 23, 2026. Educational information, not legal, coding or tax advice. Rules change; confirm with CMS and each payer.

What the extension covers

Patients can receive telehealth from home, without geographic or rural-area restrictions.
Expanded originating sites beyond traditional clinical facilities.
FQHCs and Rural Health Clinics can serve as distant-site providers.
Audio-only telehealth continues for certain services when appropriate.
The in-person visit requirement for Medicare tele-mental health is delayed; reporting indicates it would apply to new mental health telehealth patients starting in early 2028.

Telehealth billing checklist

Confirm the payer’s policy for the service, specialty and patient location before the visit.
Use the right place of service. Many payers use POS 10 when the patient is at home and POS 02 for other telehealth locations; confirm each payer’s rule.
Add the required modifier (for example 95, 93 or GT) when the payer requires it.
Document the essentials: patient location, provider location, technology used (video or audio-only), consent where required, and start/stop time for time-based codes.
Check state licensure for the provider and patient state; Medicare flexibilities do not override state law.
Verify eligibility and benefits for telehealth, including visit limits and copays.
Track the 2027 rule changes. CMS has proposed new telehealth modifiers; see our 2027 fee schedule article.
Plan for the sunset. Build workflows so you can adjust if flexibilities lapse after 2027.

Behavioral health practices should also read our behavioral health billing guide.

Sources and where to verify

Consolidated Appropriations Act, 2026 (H.R. 7148), signed February 3, 2026.
CMS Medicare telehealth FAQs and the CY 2027 Physician Fee Schedule proposed rule: CMS fact sheet
Verify current payer policies directly with each payer.

Medicare Telehealth Through 2027: A Billing Checklist