Surviving the Telehealth Cliff of October 2025: What It Means for Your Practice and How to Prepare

Published on

September 25, 2025

It’s October 2, 2025, and the phones in your front office are ringing. Patients who relied on virtual check-ins for blood pressure follow-up or medication management are suddenly facing denials or higher out-of-pocket costs. What changed overnight?

This is the Telehealth Cliff: the expiration of pandemic-era Medicare telehealth flexibilities on September 30, 2025, unless Congress acts again. On October 1, 2025, policy for many non-behavioral telehealth services reverts to pre-PHE rules. Behavioral/mental health telehealth, however, keeps permanent flexibilities (home as originating site, audio-only options, and FQHC/RHC distant-site allowances).

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What exactly is the Telehealth Cliff?

Pre-pandemic baseline (the “old rules”). Before COVID-19, Medicare telehealth coverage was tightly constrained by statute. In most cases, patients had to be physically located at an approved “originating site” (e.g., a clinic or facility) in a rural area, and only certain services and practitioner types qualified. The patient’s home generally did not count as an originating site for non-behavioral telehealth, and audio-only services were rarely covered. These geographic, site, and modality rules kept traditional telehealth volumes modest, especially for primary and specialty care delivered to urban patients or to patients at home.

Pandemic-era waivers (what changed and why). When the Public Health Emergency (PHE) began, Congress and CMS used emergency authorities to temporarily waive many of these statutory limits so Medicare patients could be seen virtually. Key flexibilities included:

Home as the originating site for many services, removing travel barriers.
No rural/urban distinction for most non-behavioral telehealth.
Expanded provider eligibility, allowing FQHCs and RHCs to serve as distant sites for non-behavioral services.
Broader modality options, including audio-only coverage where appropriate.

Congress then extended these temporary flexibilities multiple times to prevent abrupt disruptions as the PHE ended. As of now, these broad non-behavioral telehealth flexibilities are scheduled to expire after September 30, 2025, the event widely referred to as the Telehealth Cliff. Importantly, behavioral/mental health telehealth received permanent carve-outs (e.g., home as originating site and audio-only allowances), so those services are not subject to the same cliff.

Why October 1, 2025 matters. Absent new legislation, Medicare policy for non-behavioral telehealth will revert on October 1, 2025 to its pre-PHE framework. Practically, that means:

The patient’s home generally stops qualifying as an originating site.
Geographic restrictions (largely rural) re-apply for many services.
Audio-only coverage narrows significantly for non-behavioral care.
Some temporary provider/site allowances (e.g., certain FQHC/RHC distant-site roles for non-behavioral telehealth) end.

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What are the potential scenarios and what could happen next?

While only Congress can change the statutory telehealth rules at scale, there are a few realistic policy pathways:

Full extension. Congress passes another extension, preserving the current broad flexibilities (home as originating site, no rural limit, wider modality allowances) past Sept 30, 2025. Practice impact: Minimal disruption in the near term; continue current virtual workflows. Still advisable to shore up durable programs (CCM/RPM) that are not waiver-dependent.

Targeted/partial extension. Congress extends some, but not all, flexibilities. For example, allowing home-as-originating-site to continue but tightening audio-only coverage or narrowing certain practitioner/site allowances. Practice impact: Mixed; some virtual use cases remain reimbursable while others scale back. Clinics will need clear triage rules by service line and patient segment.

No extension (reversion to pre-PHE for non-behavioral). Flexibilities expire; non-behavioral telehealth reverts to rural geography, facility originating sites, and limited modality rules. Behavioral telehealth carve-outs remain. Practice impact: Coverage narrows immediately; practices must pivot more patient touchpoints into durable, non-waiver programs (e.g., CCM, RPM) to preserve care continuity and revenue.

State and commercial variation (parallel context). Medicaid and commercial payer telehealth policies may diverge from Medicare and can persist or evolve independently. Practice impact: Expect a payer-specific mosaic. Build a payer policy matrix and default to nationally durable Medicare programs (CCM/RPM/AWV) for stability.

Bottom line for preparation: counting on another extension is not a strategy. Regardless of what Congress decides, every practice benefits from hardening a post-cliff operating model that relies on permanent, CMS-backed programs, not temporary waivers. That means:

Using AWVs to identify risk and eligibility.
Enrolling appropriate patients in CCM (monthly, phone/video-friendly) and RPM (device-driven), with clean time attribution and audit-ready documentation.
Embedding phone/video inside care-management workflows (not as standalone telehealth visits), so patient engagement continues even if traditional telehealth billing narrows.

If an extension comes, you’re stronger and more diversified. If it doesn’t, you’re already where you need to be.

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What’s at risk for practices

The Telehealth Cliff is more than just a policy footnote. For many practices, it represents a fundamental change in how patients can access care and how clinics can be reimbursed. If current flexibilities expire on September 30, 2025, the following risks will materialize immediately:

1. Reimbursement shrinkage

Urban patients lose coverage. Medicare telehealth for non-behavioral services would again be largely limited to rural areas. For practices in suburban and urban markets, this means the majority of telehealth visits could no longer be billed.
Home no longer an originating site. Patients would need to travel to an eligible facility (like a clinic or hospital) to receive telehealth, cutting off the convenience that drove adoption in the first place.
Audio-only billing restricted. Phone visits that became lifelines for older or tech-limited patients (particularly in rural areas with poor broadband) would no longer be reimbursable except in behavioral health.‍
Practice impact: Expect a drop in billable encounters and higher denial rates for visits that previously qualified.

2. Patient access barriers

Rural patients face new hurdles. While some rural telehealth remains covered, requiring an “originating site” instead of the home can mean long travel distances, particularly burdensome for patients with mobility challenges.
Technology disparities worsen. Without audio-only options, patients without reliable internet or devices are effectively excluded.
Behavioral health is protected, but other chronic care isn’t. Patients with diabetes, heart failure, COPD, and hypertension will see fewer reimbursable touchpoints, even though they often benefit most from frequent follow-up.‍
Practice impact: No-show rates could rise, as patients who can’t make in-person visits disengage from care.

3. Operational disruption

Workflow fragmentation. Practices will need to split telehealth visits into “covered” and “not covered” categories, creating confusion for schedulers and billing staff.
Revenue unpredictability. Telehealth volume built during the PHE may vanish, creating a financial cliff for clinics that leaned heavily on virtual care.
Staff productivity loss. Nurses, MAs, and front office staff may spend more time troubleshooting coverage questions, rescheduling patients, and handling denials.‍
Practice impact: Expect billing complexity and staff strain as practices navigate a patchwork of rules.

4. Strategic risk

Dependence on temporary waivers. Practices that have not diversified into permanent CMS programs (like CCM and RPM) may find themselves scrambling.
Competitive disadvantage. Organizations that preemptively shift to AWV/CCM/RPM workflows will retain patient engagement and stable revenue, while those clinging to traditional telehealth codes could fall behind.‍
Practice impact: A clinic’s ability to sustain virtual engagement becomes a differentiator in a competitive, value-based care environment.

Bottom line: If the flexibilities expire, practices face a triple hit: reduced reimbursement, diminished patient access, and heavier administrative burden. That’s why building a sustainable, waiver-independent revenue model (CCM, RPM, AWVs) isn’t optional. It’s urgent.

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How to prepare now (and be sustainable regardless of Congress)

The Telehealth Cliff highlights a central truth: practices cannot build their business model on temporary waivers. Whether Congress extends flexibilities or not, your clinic needs a durable framework that protects revenue and keeps patients engaged. Here’s how to prepare.

1. Reframe “telehealth” as care management, not just visits. Think beyond billable video encounters. With Chronic Care Management (CCM) and Remote Patient Monitoring (RPM), phone and video check-ins become part of reimbursable care-management time, not standalone visits. This shift ensures virtual touch points remain sustainable, even if traditional telehealth billing narrows. Action step: Train staff to log every call, follow-up, and video touchpoint into CCM or RPM workflows with time capture.

2. Make CCM the backbone of virtual care. Permanent and CMS-backed since 2015, CCM pays for ≥20 minutes/month of non-face-to-face care coordination for patients with two or more chronic conditions. It’s flexible: calls, med checks, lab scheduling, and coaching all count, provided they are medically necessary and documented. Action step: Start enrolling eligible patients now (often 60–70% of a Medicare panel). Script the CCM introduction during Annual Wellness Visits (AWVs) so enrollment becomes routine.

3. Scale RPM alongside CCM. RPM reimburses for tracking and reviewing physiologic data like blood pressure, glucose, weight, and oxygen saturation. It creates a steady PMPM revenue stream while providing clinical insight that can trigger interventions before a crisis. Action step: Start with one or two device types (e.g., cellular blood pressure cuffs, scales) to keep it simple. Pair RPM with CCM to build a hybrid revenue stream that covers both coaching and data review.

4. Use AWVs as your patient pipeline. AWVs remain fully reimbursable and offer the best opportunity to identify patients eligible for CCM and RPM. Every AWV should end with a CCM/RPM eligibility screen and, if appropriate, a same-day consent conversation. Action step: Update AWV templates to include a CCM/RPM referral checklist, ensuring no eligible patient is overlooked.

5. Create clear internal rules and scripts. Staff need a “minutes map”: what counts for CCM, what counts for RPM, what goes under BHI (behavioral health integration). Build scripting so MAs, RNs, and coordinators know how to explain CCM/RPM to patients consistently. Action step: Hold a 1-hour training with your team and post laminated “minutes maps” at workstations.

6. Invest in dashboards and audit readiness. Congress may extend some flexibilities, but payers will be watching compliance closely. Practices need audit-ready documentation: consent, supervision notes, time logs, care-plan updates. Action step: Use Lara Health dashboards to track AWV completion, CCM/RPM enrollment, minutes logged, and revenue by service line — so you can manage weekly, not just reconcile quarterly.

7. Build flexibility into staffing. If Congress extends telehealth, you’ll want staff ready to keep scaling virtual visits. If not, you’ll need staff focusing more on CCM/RPM follow-up. Action step: Cross-train one or two staff members now, and consider leveraging Lara Health’s US-based virtual care managers for overflow or continuity when in-house bandwidth is tight.

Preparing now means anchoring your virtual care strategy in permanent, CMS-backed programs (CCM, RPM, AWVs). Whether Congress grants another extension or not, your patients still need continuous engagement, and your practice still needs stable revenue. By reframing “telehealth” as care management and embedding it into AWV/CCM/RPM workflows, you future-proof your practice against policy cliffs.

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How Lara Health makes the pivot straightforward

The looming Telehealth Cliff doesn’t have to be a disruption. Lara Health is purpose-built to help practices transition from temporary telehealth dependence to permanent, CMS-backed programs like CCM, RPM, and AWVs. Our platform and services make the pivot seamless:

Phone and video built into care management workflows

With Lara Health, phone and video visits aren’t standalone telehealth encounters that risk denial after October 1, 2025.
Every call or video interaction is tagged directly to CCM, RPM, BHI, or TCM minutes, ensuring it is audit-ready and attributable to the correct CPT code.
This means your virtual touch-points remain reimbursable and compliant, even if Medicare tightens telehealth visit coverage.

Compliance rails baked into the system

Consent prompts: Patients are automatically reminded and documented for CCM/RPM/BHI participation.
Time capture: Minutes are tracked in real time and allocated to the right service line, eliminating double-counting risk.
Supervision attribution: The platform ensures that services billed under general supervision meet CMS requirements.
Audit readiness: Every report is stored and exportable, so you’re prepared for payer review or CMS audit at any time.

Seamless EHR integration

Lara Health syncs notes, care-plan updates, orders, and patient activity back to your EHR.
Staff avoid swivel-chair documentation, saving hours each week.
The result: fewer errors, fewer missed billable minutes, and a more streamlined clinical workflow.

Flexible staffing options

In-house support: If you want to use your own staff, Lara Health trains them to run CCM, RPM, and AWVs through our platform.
Virtual care team augmentation: If you’re short-staffed or want to scale fast, you can leverage Lara Health’s US-based, licensed, and highly experienced virtual care managers. They operate as part of your team, following your workflows and reporting back to your physicians.
No recruiting, no backfilling, no disruption: just consistent program execution for better health outcomes and revenue growth.

Scalability without overwhelm

Lara Health supports practices whether you have 200 eligible patients or 20,000.
Bulk patient identification tools flag every eligible CCM/RPM candidate.
Outreach workflows and enrollment checklists streamline the patient journey from AWV, to consent, to program enrollment, to monthly follow-up.
Dashboards show real-time enrollment, minutes logged, gap closures, and revenue, so you can manage at the practice, provider, or patient level.

Future-proofing your revenue

By anchoring virtual touch-points inside CCM, RPM, and AWV workflows, Lara Health ensures you’re not exposed to the on/off switch of Congressional extensions.
Practices that pivot now can maintain stable, recurring revenue, and build resilience into their financial model, regardless of what happens on October 1, 2025.

Lara Health makes it easy to replace risky, waiver-dependent telehealth billing with a sustainable, compliant, and scalable virtual care model.

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Practical next steps (checklist)

The Telehealth Cliff is imminently upon us. Waiting for Congress to decide means taking on unnecessary risk. Here’s a phased checklist your practice can start now to protect both patients and revenue.

Step 1: Audit your current telehealth exposure

Inventory visit types: Run a 6–12 month lookback to see how many telehealth visits you bill today, by CPT code and service type.
Segment by patient population: Identify which groups (urban, rural, tech-limited, chronic condition cohorts) will be most affected if flexibilities expire.
Map revenue dependency: Calculate the percentage of your Medicare revenue tied to non-behavioral telehealth codes likely to expire.

Step 2: Stand up CCM as a default pathway

Build an eligibility list: Patients with ≥2 chronic conditions expected to last 12+ months are CCM candidates, often 60-70% of a Medicare panel.
Script enrollment at AWVs: Add CCM eligibility prompts to your AWV template and train staff to introduce CCM before checkout.
Document consent: Capture consent in writing or electronically, and store it in your EHR or Lara Health platform.

Step 3: Launch or expand RPM

Start simple: Begin with one or two devices (e.g., cellular blood pressure cuffs and scales) to reduce complexity.
Pair with CCM: Use RPM data to enrich monthly CCM calls, so coaching and monitoring go hand-in-hand.
Train staff on device support: Ensure your team knows how to troubleshoot connectivity and walk patients through setup.

Step 4: Optimize AWVs as your pipeline

Set completion targets: Aim for ≥70% AWV completion in year one, climbing toward 80–90%.
Automate outreach: Use EHR or Lara Health’s tools to flag patients due for AWVs and trigger reminders.
Link to CCM/RPM: Every AWV should end with a same-day enrollment conversation for eligible patients.

Step 5: Train your team on time attribution and scripts

Create a “minutes map”: Post a simple chart showing what counts as CCM, RPM, BHI, or TCM minutes.
Standardize patient scripts: Train staff on how to explain the value of CCM/RPM and handle questions about copays.
Role-play consent conversations: Build staff confidence in obtaining informed consent without slowing down workflows.

Step 6: Implement dashboards and quality tracking

Track weekly, not quarterly: Use Lara Health’s dashboards to monitor AWV completion, CCM/RPM enrollment, and minutes logged in real time.
Close the loop: Monitor % of AWV-generated orders completed within 60 days (e.g., labs, vaccines, referrals).
Tie KPIs to incentives: Align metrics with MIPS, Star Ratings, or ACO benchmarks so financial impact is visible.

Step 7: Build staffing resilience

Cross-train in-house staff: Ensure at least one MA/RN can run both AWV intake and CCM documentation.
Leverage virtual support: Consider Lara Health’s US-based care managers to smooth out staff shortages or scale rapidly.
Plan for surges: As deadlines near, expect patient demand for telehealth alternatives to increase; prepare staffing and scheduling capacity now.

Treat this checklist as your 90-day action plan to pivot from telehealth dependency to care-management sustainability. With Lara Health’s tools and care team support, every step, from auditing risk to enrolling patients and tracking ROI, becomes easier, faster, and audit-ready.

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Conclusion

The Telehealth Cliff of October 1, 2025 is a looming deadline that could reshape how your practice delivers and gets paid for virtual care. If Congress acts, you may get breathing room. If it doesn’t, Medicare telehealth coverage for non-behavioral services will shrink overnight, cutting off home-based visits, urban coverage, and audio-only reimbursement. Either way, waiting to see what happens is a gamble with your patients’ access and your practice’s revenue.

The smart path forward is to build resilience into your model now. That means anchoring virtual care inside permanent, CMS-backed programs like Chronic Care Management (CCM), Remote Patient Monitoring (RPM), and Annual Wellness Visits (AWVs). These services are not waiver-dependent. They are policy-backed, reimbursable, and designed to pay you for the exact kind of between-visit engagement patients need most, and this is where Lara Health makes the difference:

Future-proofing your workflows. With Lara Health, every phone call or video visit is captured and correctly attributed to CCM, RPM, or BHI minutes, so you can continue engaging patients virtually, even if traditional telehealth billing narrows.
Compliance built-in. Consent prompts, time capture, supervision rules, and audit-ready reports are part of the platform, reducing risk and giving you confidence when payers review your records.
Scalable staffing. Whether you run programs with your in-house team or lean on Lara Health’s US-based, licensed virtual care managers, you’ll never have to pause growth due to staff shortages or turnover.
Operational clarity. Dashboards show AWV completion, CCM/RPM enrollment, minutes logged, care-gap closures, and revenue, so you can manage performance weekly, not guess quarterly.
Patient-centered continuity. Your patients stay connected through phone and video inside Lara Health’s portal, ensuring continuity of care and reducing avoidable ED visits and disengagement.

The Telehealth Cliff doesn’t have to be a threat. For practices that pivot now, it’s an opportunity to leave behind the uncertainty of temporary waivers and step into a sustainable, compliant, and recurring revenue model. With Lara Health, you don’t just survive the cliff: you build a stronger, more resilient practice that thrives in the new landscape of virtual care. Book a demo with Lara Health to see how we can help you turn October 1, 2025 into the day your practice took control of its future.

FAQ

What is the Telehealth Cliff in 2025?

The Telehealth Cliff refers to the expiration of Medicare’s pandemic-era telehealth flexibilities on September 30, 2025. Starting October 1, 2025, coverage for many non-behavioral telehealth services reverts to pre-pandemic rules unless Congress extends the waivers.

What will change after October 1, 2025?

Without an extension, Medicare will restrict non-behavioral telehealth to rural patients at approved “originating sites.” Home-based visits may no longer qualify, and most audio-only visits will not be reimbursed. Behavioral and mental health telehealth flexibilities are permanent and will remain in place.

How will the Telehealth Cliff affect medical practices?

Practices risk losing reimbursement for urban telehealth visits, home-based care, and audio-only check-ins. This could lead to revenue loss, increased no-shows, and reduced patient access, especially for seniors and those with limited internet access.

Is there a chance Congress will extend telehealth flexibilities?

Yes. Congress has already extended flexibilities multiple times, most recently through September 30, 2025. Lawmakers may act again, but there is no guarantee, so practices should not rely on an extension.

How can practices prepare for the Telehealth Cliff?

Practices can prepare by building programs that are permanent and CMS-backed:

Chronic Care Management (CCM) for monthly non-face-to-face care coordination.
Remote Patient Monitoring (RPM) for device-based tracking and follow-up.
Annual Wellness Visits (AWVs) to identify eligible patients and build a care-management pipeline.

What is the role of Lara Health in preparing for the Telehealth Cliff?

Lara Health helps practices pivot to sustainable virtual care models by:

Embedding phone and video inside CCM/RPM workflows, so virtual touchpoints remain reimbursable.
Providing audit-ready compliance tools (time capture, consent, supervision).
Offering US-based, licensed virtual care managers to expand capacity without hiring.
Delivering dashboards that track AWV completion, CCM/RPM enrollment, care-gap closures, and revenue.

Will behavioral health telehealth be affected by the Telehealth Cliff?

No. Congress made behavioral and mental health telehealth flexibilities permanent. This includes allowing the home as an originating site, reimbursement for audio-only visits, and coverage when services are delivered by FQHCs and RHCs.

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Sources

NCTRC - “The Telehealth Policy Cliff: Preparing for October 1, 2025.” (2025).

HHS Telehealth - “Telehealth policy updates.” (Updated Mar 2025).

CMS - MLN “Telehealth & Remote Patient Monitoring.” (2025).

CMS - Telehealth FAQ (Apr 2025): FQHC/RHC billing (G2025) through 9/30/2025.

AAFP - “Will Congress extend Medicare telehealth flexibilities in 2025?” (Sep 2025).

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