Medicare Telehealth Rules 2026: What Your Practice Needs to Know

The Short Version First

Medicare telehealth coverage in 2026 is broader than it was before the pandemic, narrower than it was at the peak of the public health emergency, and stable enough that you can finally plan around it. The geographic and originating-site restrictions that used to lock most of telehealth to rural patients in clinics are gone for behavioral health and largely paused for everything else. Audio-only is reimbursable for the right codes when video would create a real barrier. And the documentation bar is higher than it used to be.

The catch is that "telehealth" no longer means one thing under Medicare. Behavioral health follows one set of rules, primary care and specialty follow another, and Medicare Advantage plans can be more generous than traditional Medicare. This post walks the rules you actually need at the point of care: who can be seen, where, by whom, with what codes, and what to write in the note so the claim sticks.

What Medicare Actually Covers in 2026

Medicare reimburses telehealth services that appear on the official Medicare Telehealth Services List. That list has grown a lot since 2020 and continues to be revised each Physician Fee Schedule cycle. In broad strokes, you can expect coverage for the following categories in 2026.

• Office and outpatient evaluation and management. New and established patient visits in the 99202 through 99215 range are covered when delivered via real-time interactive video.
• Behavioral health and substance use disorder services. Psychotherapy, psychiatric diagnostic evaluation, family therapy, and SUD counseling are all on the list and have the most permissive rules of any category.
• Annual wellness visits and certain preventive services. Including the Initial Preventive Physical Examination and the Annual Wellness Visit when clinically appropriate.
• Chronic care management, transitional care management, and remote monitoring. These have always been remote-friendly and remain reimbursable.
• Prolonged services and complex care add-ons. Available when the underlying primary service is itself on the telehealth list.
• Virtual check-ins and e-visits. Brief HCPCS codes like G2010, G2012, and G2252, plus the 99421-99423 portal-message codes, sit alongside the main telehealth list and have their own rules.

What is not generally covered: services that physically require the provider to lay hands on the patient (most procedures), most inpatient hospital codes when the patient is admitted, and a handful of category-three codes that CMS has explicitly declined to permanently add. When in doubt, the Medicare Telehealth Services List on the CMS website is the source of truth. Bookmark it.

Originating Site and Geographic Rules

This is the rule that historically kept telehealth out of most practices. Before the pandemic, Medicare required the patient to be at a qualifying "originating site" (a clinic, hospital, or similar facility) located in a designated rural health professional shortage area. Your patient could not be at home, period, with narrow exceptions.

That restriction has been loosened or paused several times since 2020, and Congress has kept extending the broader flexibilities. As of 2026, here is the practical state of play.

• Behavioral health. The originating site restriction is permanently lifted. Patients may be seen at home, in any geographic location, for mental health and substance use disorder services. There is an in-person requirement for the first visit in some scenarios (more on that below).
• Non-behavioral telehealth. Geographic and originating-site restrictions are paused through the current Congressional extension. Patients may be seen at home regardless of urban or rural status. This pause has been extended multiple times and currently runs through the date specified in the latest Continuing Appropriations Act or successor legislation. Track the expiration date your billing team is using.
• Rural emergency hospital and FQHC/RHC special rules. Federally Qualified Health Centers and Rural Health Clinics can serve as distant-site providers for telehealth, not just originating sites. This was another pandemic-era flexibility that has held.

The translation: if you are practicing in 2026, you can probably see a Medicare patient at home over video the same way you would see them in your office, and bill the same evaluation and management code. Verify the current extension date and your MAC's policy before assuming a permanent rule.

Audio-Only Visits: Still Covered, With Limits

Medicare's stance on audio-only telehealth used to be a hard no for most services and a soft yes for a handful of behavioral health codes. That has shifted. Today, audio-only is reimbursable in defined circumstances.

The two conditions Medicare looks for:

1. The service must be on the list of telehealth codes for which audio-only is permitted. Most behavioral health codes qualify. A subset of E/M codes qualify when the patient cannot use video.
2. The patient must be either unable or unwilling to use video. This includes patients without a smartphone or camera, patients with low bandwidth or no broadband, patients who decline video for privacy or comfort, and patients with cognitive or sensory impairments that make video impractical. Document the reason.

Audio-only is typically billed with the standard service code plus the audio-only modifier (currently 93) or, for behavioral health in some circumstances, with the FQ HCPCS modifier. Your MAC will tell you which combination to use; don't guess. The note must clearly state that the patient was offered video and either declined or could not use it.

If you serve a lot of elderly or rural patients, audio-only is not a fallback. It is a real visit type that earns real reimbursement. Build it into your workflow. We wrote more about this in telehealth for elderly patients.

Behavioral Health Gets Its Own Lane

If you provide mental health or substance use disorder services, Medicare gives you the most generous telehealth rules of any specialty. Three things to know.

Patient location is wide open. No geographic restriction. No originating-site restriction. The patient may be at home, in another state if you are licensed there, or wherever they happen to be that day. Audio-only is broadly permitted.

There is an in-person requirement, but it has been delayed. Statute says behavioral health telehealth patients should have an in-person visit within six months prior to the first telehealth service, and at least every 12 months thereafter. Congress and CMS have repeatedly delayed enforcement of this requirement. Your practice should still document the rationale for telehealth-only care and any reason an in-person visit was not feasible, in case the delay ends and audits look back.

Marriage and family therapists and mental health counselors are now Medicare providers. MFTs and MHCs gained Medicare enrollment in 2024 and continue to be billable providers in 2026. They can deliver telehealth services within the scope of their license. If your group employs them, get their NPIs in your billing system and verify enrollment status.

For a deeper cut on behavioral telehealth workflows, see telehealth for therapists.

Codes, Modifiers, and Place of Service

Billing telehealth is mostly about getting three things right: the underlying CPT or HCPCS code, the modifier that flags the encounter as telehealth, and the place of service. Get one wrong and the claim either denies or pays at the wrong rate.

Most-used codes for office and outpatient telehealth

• 99202 through 99205: New patient office or outpatient E/M, leveled by medical decision making or time.
• 99212 through 99215: Established patient office or outpatient E/M, same leveling logic.
• 99441 through 99443: Telephone E/M codes (these were historically used for audio-only but Medicare now leans on modifiers with the standard E/M codes instead).
• 90791 and 90792: Psychiatric diagnostic evaluation, with or without medical services.
• 90832, 90834, 90837: Psychotherapy, 30, 45, and 60 minute units.
• G2010, G2012, G2252: Brief virtual check-ins and the longer virtual check-in.
• 99421 through 99423: Online digital E/M (portal-message-based visits).

Modifiers that matter

• Modifier 95. Synchronous telehealth via real-time audio-video. Append to the E/M or service code.
• Modifier 93. Synchronous audio-only telehealth. Use when the visit was conducted entirely by phone and the code permits audio-only billing.
• Modifier FQ. Audio-only behavioral health, in scenarios where MACs require it.
• Modifier FR. Telehealth distant-site service when the provider was supervising via two-way audio-video. Niche, but relevant for split-shared visits.
• Modifier GT. Mostly legacy at this point, retained by some MACs for institutional claims.

Place of service codes

• POS 10. Telehealth provided in the patient's home. Pays at the non-facility rate.
• POS 02. Telehealth provided in a location other than the patient's home (the patient is at a clinic or other site). Historically pays at the facility rate, though CMS has experimented with this.

The combination most office-based practices use in 2026 is standard E/M code + modifier 95 + POS 10 for a video visit with the patient at home. We covered the full code map in telehealth billing CPT codes for 2026.

Documentation That Keeps You Paid

Medicare audits telehealth more aggressively now than it did three years ago. The pattern most denials follow is not "the service wasn't covered" but "the documentation didn't establish that it was." Your note for a telehealth visit should include the following beyond the usual clinical content.

• Modality. State that the visit was conducted by real-time interactive audio-video, or by audio only, with the patient's location. Example: "Visit conducted via secure real-time audio-video. Patient in her home in Texas."
• Consent. Document that the patient consented to telehealth. A one-time consent on file is fine for most practices; reference it in the note. More on this in telehealth consent forms.
• Patient identity verification. Note how you confirmed who you were talking to. For established patients, recognition is enough. For new patients, document a verification step.
• Provider location. CMS requires you to track your distant-site address. This does not have to be in every note, but it must be on file and accurate, especially if you practice from home.
• Clinical content meeting the level billed. Same E/M leveling rules as in-person. If you bill 99214, the note must support a moderate-complexity medical decision-making encounter or 30-39 minutes of total time on the date of service.
• For audio-only. Document why video was not used. "Patient declined video due to lack of camera-equipped device" is enough. "Patient unable to use video" without a reason is not.
• For behavioral health. Track in-person visit history. Document the date of the most recent in-person visit and the planned follow-up cadence, even while enforcement of the requirement is delayed.

If your EHR doesn't make this easy, build a telehealth visit template. Five fields you check off and one free-text reason field is enough. Saves time at the point of care and protects you in an audit.

Medicare Advantage Plays By Slightly Different Rules

About half of Medicare beneficiaries are now enrolled in Medicare Advantage plans, and those plans have flexibility to be more generous than traditional Medicare on telehealth. Many of them are.

What you can usually expect from a Medicare Advantage plan in 2026:

• Coverage for most or all of the same telehealth codes as traditional Medicare, often with broader audio-only allowances.
• No geographic or originating-site restriction, even if the federal pause expires. Plans can keep their own permissive rules.
• Some plans include telehealth as a supplemental benefit with zero copay, which is a marketing point for the plan and worth knowing about when scheduling.
• Plan-specific networks. Telehealth doesn't change who is in-network. Verify the patient's network before the visit.

What can trip you up: a few MA plans require their own modifier or place-of-service convention that differs from traditional Medicare. Always check the plan's provider manual or call the plan's provider line before assuming your traditional Medicare workflow applies. The denial you would get from getting this wrong is recoverable but annoying.

Don't Forget the State Layer

Medicare's federal rules tell you what Medicare will pay for. They do not authorize you to practice medicine across state lines. That is your state medical board's call.

Two practical reminders before you start seeing Medicare patients in multiple states.

• You must be licensed where the patient is located at the time of the visit. Not where the patient lives on their driver's license. Where they are sitting when the camera turns on. A snowbird in Florida is a Florida-licensure problem.
• Compacts help, but verify. The Interstate Medical Licensure Compact, PSYPACT, and the Nurse Licensure Compact streamline multi-state licensure for many providers. Verify your state and your patient's state are both in the relevant compact.

Medicare will pay the claim even if the state license issue is not visible to them at the claim level. That doesn't make it legal. An audit, a board complaint, or a malpractice claim later can surface it. See telehealth malpractice insurance for the related risk picture.

A Compliance Checklist for the Rest of 2026

Print this, or build it into your onboarding for new telehealth providers.

1. Confirm enrollment. Your NPI and the rendering provider's NPI are active in Medicare PECOS, with current distant-site addresses on file.
2. Verify the federal extension date your billing team is using. Don't assume the non-behavioral flexibilities are permanent. Know when the current authorization expires.
3. Maintain a current Medicare Telehealth Services List reference. Tie it into your scheduling so you don't book a visit for a code that isn't telehealth-eligible.
4. Have a written telehealth consent on file for every patient. Reference it in each note.
5. Build a telehealth visit template in your EHR. Modality, patient location, consent reference, identity verification, level supporting documentation, and a free-text "reason audio-only" field.
6. Know your modifier and POS conventions cold. 95 + POS 10 for home video. 93 (and FQ for behavioral health) for audio-only. Audit a sample of telehealth claims monthly.
7. Track state licensure for every active provider. Patients move. Snowbirds happen. Have a rule for what to do when a patient logs in from a state your provider is not licensed in.
8. BAA in place with every vendor that touches PHI. Your video platform, your scheduling tool, your transcription service. All of them. More on this in the HIPAA-compliant telehealth guide.
9. Document the in-person visit history for behavioral health patients. Even while the requirement is delayed, the audit trail protects you.
10. Subscribe to your MAC's bulletins. They publish local coverage decisions and clarifications that the national rule does not cover.

The Takeaway

Medicare telehealth in 2026 is workable. The hardest rule, the originating-site restriction, is largely out of the way. Audio-only has a real place in the workflow. Behavioral health has its own permissive lane. The bar that has gone up is documentation.

If you set up your visit template, your modifier conventions, and your state-licensure tracking once, the day-to-day operation is genuinely simple. The practices that struggle are the ones that try to remember the rules visit by visit. Don't do that. Bake them into the workflow and the claims pay themselves.

And if your telehealth platform is making any of this harder than it needs to be (no place-of-service guidance, no audio-only fallback, no clean consent capture, no documentation hooks), it's worth a second look. SimplyTelehealth is built around the realities of how a small medical practice actually bills. Video, phone dial-in, and SMS visits in one tool, with the metadata your billing team needs surfaced cleanly.