The Telehealth Cliff: What Ended, What Survived, and What Smart Practices Are Doing Next

October 1, 2025 quietly marked one of the biggest policy reset since the pandemic. Medicare’s broad PHE-era telehealth flexibilities expired, reshaping how primary care, behavioral health, and multispecialty practices get paid for virtual care. The end of one chapter doesn’t mean the end of telehealth; it means you need to know where the new rules live, and how to use them. When the federal public health emergency ended, CMS offered one final grace period for telehealth coverage through September 30, 2025. From October onward, the “telehealth cliff” began in earnest: most non-behavioral telehealth services reverted to their pre-COVID status. Medicare again requires that patients be in a rural area and inside a qualifying medical facility for many virtual visits to be billable.

Behavioral health remains the key exception. Psychiatrists, psychologists, and primary care teams delivering tele-behavioral health can still bill without geographic or originating-site restrictions, and audio-only can qualify when clinically appropriate. RHCs/FQHCs may continue distant-site billing under G2025 through CY2025 and (per the CY2026 PFS Proposed Rule) are anticipated to extend into CY2026, pending finalization. This is not a temporary slowdown; it’s a structural rebalancing.

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What That Means for Primary Care

Before the cliff, a small internal-medicine clinic might have handled a third of its follow-ups through telehealth. Those visits were easy for patients and efficient for staff. Now, that same clinic faces a double-bind: fewer reimbursable encounters and longer in-person backlogs, so patients who once joined a virtual follow-up from home may now need to travel to the office, or, worse, skip the visit entirely. No-show rates rise, schedules tighten, and the administrative load creeps back toward its pre-pandemic peak. For many practices, this shift will feel less like a “policy update” and more like a new operating reality. The visit-based telehealth model that thrived under the PHE simply doesn’t fit the reimbursement structure that replaced it.

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The Fine Print: Where Exceptions Still Exist

What’s received less attention is that not every practice faces the same limitations:

MSSP ACO waivers. Practices inside ACOs on Enhanced or Basic Tracks C–E with prospective assignment retain telehealth waivers that remove geography and originating-site restrictions. If you’re in a qualifying ACO, your patients can still be seen at home and billed as before - the waiver becomes a competitive advantage.

Behavioral health telemedicine. Continues without rural/site restrictions and supports audio-only as appropriate.

RHC/FQHC distant-site telehealth (G2025). Authorized through 2025 and proposed for 2026; treat 2026 as pending until the final rule is issued.

Another key piece of the puzzle lies in how CMS now classifies telehealth services. The Medicare Telehealth Services List distinguishes between Permanent and Provisional codes, a subtle but powerful change:

• Permanent codes are here to stay. They include behavioral health visits, virtual check-ins, remote physiologic and therapeutic monitoring, and select office-visit codes.
• Provisional codes, by contrast, are temporary additions that CMS is still evaluating (such as some hospital, emergency, and therapy-based teleconsults).

CMS even publishes a public list showing which codes fall into each category. It’s worth reviewing it line by line - because that’s where your billable future is defined.

The practical takeaway:

1. Know which codes you’re using.
2. Check if you can use MSSP ACO waivers.
3. Build workflows around permanent codes.
4. Transition provisional use cases into reimbursable pathways like Chronic Care Management (CCM), Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), Behavioral Health Integration (BHI/CoCM), or structured virtual check-ins/e-visits.

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What Payers Will Keep Covering

The cliff only applies to traditional Medicare: It does not uniformly apply to Medicare Advantage (MA) or commercial plans:

• MA plans can include telehealth as a core or supplemental benefit, and many do.
• Commercial payers operate under state parity laws: most states require some telehealth coverage, and many require payment parity for virtual vs. in-person services.

That means a patient with, for example, a plan like BCBS or UnitedHealthcare MA may still be fully covered for the same virtual visit that a Medicare FFS patient can’t bill. The difference isn’t clinical - it’s contractual, and sophisticated practices are already mapping these differences. They’re building payer matrices that flag which plans, in which states, still reimburse for home-based telehealth, and aligning scheduling rules accordingly. Telehealth isn’t dead; it’s selective.

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Finding the “Back Doors” in 2025-26

The 2025 telehealth cliff might have closed the door on casual, at-home virtual visits for many Medicare patients, but it didn’t lock the system entirely. CMS has deliberately left structured, policy-backed pathways, what we call “legitimate back doors”, that still allow practices to deliver virtual care, sustain patient access, and protect recurring revenue. The key? These “back doors” are not loopholes, they’re long-term care-management programs and exceptions written directly into federal rule. Each pathway aligns with CMS’s broader goal of rewarding continuity, care coordination, and outcomes rather than convenience-based telehealth.

Below are the six most practical and compliant ways to keep telehealth alive inside your business model through 2025–26:

1. ACO Telehealth Waivers (Enhanced and Basic Tracks C–E). If your practice participates in a Medicare Shared Savings Program (MSSP) ACO operating under the Enhanced Track or Basic Tracks C through E, you’ve retained one of the most valuable telehealth flexibilities available. These ACOs, with prospective beneficiary assignment, can continue delivering and billing for telehealth visits without geographic or site restrictions. Patients can still be at home, and the same office-based E/M codes apply.

Why it matters: ACO telehealth waivers transform what’s a limitation for competitors into a strategic advantage for you, and you can maintain virtual access for high-risk or mobility-limited patients, reducing missed visits and improving quality scores.

2. Behavioral Health Telemedicine (No Geographic or Site Restrictions). Behavioral and mental health care remains fully exempt from the geographic and originating-site rules that returned in 2025. Psychiatrists, psychologists, and primary care teams providing tele-behavioral health can continue to bill anywhere the patient resides, including audio-only encounters when clinically appropriate.Why it matters: behavioral health remains a cornerstone of virtual care equity and access; tele-behavioral visits are now permanently recognized as essential services. They continue to qualify for standard telehealth reimbursement, no matter where the patient is located.

3. Time-Based Care Management Codes (CCM, PCM, BHI, and CoCM). When telehealth restrictions tightened, care-management programs became CMS’s preferred alternative. These codes, the Chronic Care Management (CCM), Principal Care Management (PCM), Behavioral Health Integration (BHI), and Collaborative Care Model (CoCM), allow you to bill for non-face-to-face, longitudinal care delivered virtually or by phone. Why it matters: They are telehealth-agnostic, not bound by geographic, audio/video, or originating-site requirements. They create predictable monthly recurring revenue streams. They improve quality and outcomes while meeting value-based care goals.

4. Remote Monitoring Programs (RPM and RTM). Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) are not classified as “telehealth”. They’re governed under different parts of the Physician Fee Schedule, meaning they aren’t subject to the telehealth cliff rules at all, and, in facts, this is an area that we have seen CMS expand on. As a general reference, RPM (99453–99458) tracks physiological data such as blood pressure, weight, glucose, or oxygen levels, while RTM (98975–98981) tracks therapeutic data like adherence, pain scores, or respiratory metrics. Both use device-based, longitudinal monitoring, and can be billed regardless of patient location. Why it matters: They generate new monthly revenue while keeping patients safer at home; they reduce hospital readmissions and complement CCM and PCM workflows. They create real-time insight into patient progress - data that pays for itself.

5. Virtual Check-Ins and e-Visits (G2010, G2012, 99421–99423). Even outside full telehealth visits, CMS continues to support short virtual encounters through communication-based technology services (CBTS). These codes cover patient-initiated digital interactions like secure messages, quick follow-up calls, or image/video reviews. Why it matters: These codes allow clinicians to capture revenue for the micro-interactions that happen daily but often go unbilled. They help maintain access and continuity between visits, especially for patients managing chronic conditions.

6. RHC/FQHC Telehealth (G2025). Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) may continue billing for distant-site telehealth under HCPCS code G2025 through CY 2025 - and CMS has proposed extending this into CY 2026, pending final rule approval. Why it matters: For rural and underserved areas, this code keeps telehealth access open where in-person visits can be difficult or delayed. It preserves continuity for populations that need it most - the elderly, mobility-limited, and resource-constrained.

Each of these “back doors” represents a sustainable piece of the hybrid-care puzzle: rather than trying to force pre-2025 telehealth workflows into a post-cliff system, smart practices are pivoting to this mix of permanent, policy-secure pathways, with ACO waivers, behavioral health, care management, monitoring, and short virtual check-ins. The practices thriving in 2026 will be those that: treat these programs as core service lines, not stopgaps; build integrated workflows across all virtual modalities; and use unified platforms (like Lara Health) to manage them compliantly and profitably.

Lara Health brings all of these programs under one roof. It’s the connective tissue between compliance, care quality, and revenue, making it simple to deliver hybrid care that’s future-proof, data-driven, and policy-compliant. How Lara Health helps:

• Automating everything: time tracking, documentation, and billing for these programs, ensuring every care touchpoint counts. Whether you manage 50 patients or 1,000, Lara Health converts care coordination into a compliant, profitable revenue stream.
• Integrating device connectivity, data interpretation, and time tracking into one interface, enabling staff to review readings, log minutes, and bill compliantly, all within your EHR environment.
• Lara Health’s compliance engine automatically recognizes RHC/FQHC billing requirements, ensuring your telehealth claims under G2025 meet CMS documentation standards and stay audit-ready.

The telehealth cliff didn’t end virtual care. It just rewarded the practices that know how to adapt and follow the path indicated by CMS.

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Telehealth / Non-telehealth pathways matrix

*2026 outlook reflects the CY2026 PFS Proposed Rule as of Oct 2025. Always confirm with the Final Rule and the CMS Physician Fee Schedule Look-Up Tool for current guidance and locality-specific reimbursement rates.

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Turning Policy Shifts Into Revenue Strategy

Let’s put the numbers in perspective. Imagine your practice conducted 1,000 reimbursable telehealth visits per year before the October 2025 cliff. Each of those visits might have reimbursed, on average, $90–$100. That’s close to $95,000–$100,000 in annual revenue that can vanish overnight under the new rules, not because patients disappeared, but because the billing framework did. For practices that built telehealth into their care model, that feels like a gut punch, but here’s the reality: CMS didn’t eliminate the concept of virtual care, it redirected reimbursement toward programs that emphasize continuity, coordination, and outcomes.

Smart practices are already using those same patients and relationships to rebuild recurring, more predictable revenue streams, ones that are not dependent on geography, audio/video requirements, or originating-site rules.

CMS didn’t eliminate the concept of virtual care, it redirected reimbursement toward programs that emphasize continuity, coordination, and outcomes.

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Here’s what that looks like in action:

Notes: Figures are illustrative national non-facility averages for CY2025 and will vary by locality, payer, and code mix. Always validate rates with the CMS Physician Fee Schedule Look-Up Tool. PMPM = per member per month.

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Even if your practice converts only a fraction of those 1,000 lost telehealth encounters into ongoing care-management relationships, the math is compelling. A 40% conversion rate can replace - and even surpass - the revenue previously generated by single-visit telehealth appointments, and unlike episodic visits, these programs create steady, month-over-month revenue that compounds with patient retention and outcomes.
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Each of these programs taps into the long-term direction CMS is moving toward: value-based, longitudinal care, they reward providers for keeping patients stable, not just seeing them frequently:

• CCM and PCM turn the “time between visits” into structured, billable care.
• RPM and RTM capture real-time data and reinforce engagement.
• BHI and CoCM integrate behavioral health directly into chronic-care workflows.
  

These models don’t just protect revenue as they enhance quality scores, strengthen patient loyalty, and position your practice for shared-savings or risk-based contracts.

Shifting from telehealth visits to longitudinal programs requires infrastructure, and that’s where Lara Health makes the difference.The platform automates the entire care-management cycle:

• Identifies eligible patients from your existing telehealth roster.
• Automates consent capture, time tracking, and documentation.
• Integrates with your EHR for seamless enrollment and reporting.
• Generates real-time dashboards that show revenue recovery, compliance, and patient outcomes.
  

Practices that deploy Lara Health typically relaunch lost telehealth capacity within weeks, not months, replacing episodic visits with a steady stream of reimbursable, policy-proof services.

With Lara Health, that transition is not just possible, it’s easy to be operationalized. Your data, your workflows, and your revenue all live in one system built to adapt as regulations evolve. The telehealth cliff didn’t remove virtual care, it set new pathways to provide it. The practices that thrive in 2026 will be those that turn policy into strategy: transforming one-time visits into long-term care relationships that generate recurring revenue, improve outcomes, and align with CMS’s future-facing incentives.

The telehealth cliff didn’t remove virtual care, it set new pathways to provide it.

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Looking Ahead: What 2026 Will Reward

The 2026 proposed rule make the policy direction explicit:

• Extending RHC/FQHC distant-site telehealth (G2025) into 2026 (pending finalization).
• Making virtual direct supervision permanent.
• Expanding Community Health Integration (CHI) and Principal Illness Navigation (PIN) service codes.
• Slightly improving the conversion factor for time-based services.
  

CMS is rewarding models that integrate virtual touchpoints into comprehensive, longitudinal care that reduces cost and improves outcomes. Smart practices will stop chasing telehealth parity and start owning population health. In other words, the next iteration of virtual care isn’t about convenience: in the post-cliff world, the practices that win aren’t the ones waiting for parity, they’re the ones building continuity.

Lara Health helps independent practices operationalize care coordination and remote- monitoring programs that thrive regardless of policy shifts. Our platform automates CCM, RPM, RTM, PCM, BHI/CoCM, and other preventive workflows, embeds them within your EHR, and provides real-time dashboards for compliance and revenue. Want to learn how to map your permanent vs. provisional telehealth codes? Identify ACO or RHC/FQHC flexibilities? Convert lost telehealth visits into predictable 2026 income?Get in touch, and book a practice readiness session with Lara Health.

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Policy status note: This article reflects Medicare and CMS guidance as of 31 October 2025. Some 2026 items are proposed and may change at final rule.

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Sources

CM. List of List of Telehealth Services

CMS. CY 2026 Medicare Physician Fee Schedule Proposed Rule. July 2025.

National Conference of State Legislatures. Telehealth Parity Laws by State. 2025.

CMS. Medicare Telehealth Services List CY 2025 Quarter 3 Update

42 CFR § 425.613. Telehealth Expansion Waiver for MSSP ACOs.

42 CFR § 422.135. MA Supplemental Telehealth Benefits.

Centers for Medicare & Medicaid Services (CMS). Medicare Telehealth Services Fact Sheet. Aug 2024.

CMS. CY 2025 Medicare Physician Fee Schedule Final Rule. Nov 2024.

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Frequently Asked Questions

What is the 2025 Telehealth Cliff and when did it happen?

The “telehealth cliff” refers to the end of Medicare’s pandemic-era telehealth flexibilities on October 1, 2025. After that date, most non-behavioral telehealth services reverted to pre-COVID rules, meaning patients must be in a rural area and in a qualifying medical facility for the visit to be reimbursed. Behavioral health, ACO waivers, and specific care management programs remain covered.

What types of telehealth visits are still reimbursable after October 2025?

Medicare continues to cover behavioral-health telemedicine, RHC/FQHC telehealth (G2025), ACO waiver visits, and certain permanent telehealth codes on the CMS Telehealth Services List. In addition, programs like Chronic Care Management (CCM), Remote Patient Monitoring (RPM), and Remote Therapeutic Monitoring (RTM) are not classified as telehealth and can be billed regardless of patient location.

Does the Telehealth Cliff affect Medicare Advantage or commercial payers?

No. The cliff only applies to traditional Medicare (Part B). Medicare Advantage (MA) plans and commercial insurers may continue covering telehealth under state parity laws or as supplemental benefits. Many payers still reimburse home-based virtual visits, coverage now varies by plan and state.

How can medical practices replace lost telehealth revenue?

Practices can convert former telehealth patients into longitudinal care programs that are policy-proof and recurring, like CCM, RPM, Behavioral Health Integration (BHI), and Principal Care Management (PCM)

Which telehealth codes are permanent and which are temporary?

CMS labels each service on the Medicare Telehealth Services List as Permanent or Provisional (temporary). Permanent codes include behavioral-health visits, virtual check-ins, remote monitoring, and some office-visit E/M codes. Provisional codes (ike certain hospital or therapy teleconsults) may expire after CMS review, so practices should align workflows with permanent codes.

What are the “back doors” for continuing telehealth in 2025–26?

CMS left several legitimate, compliant pathways open:

• ACO telehealth waivers (Enhanced, Basic C–E)
• Behavioral health telemedicine (no geo/site limits)
• Care management programs (CCM, PCM, BHI, CoCM)
• RPM/RTM remote monitoring programs
• Virtual check-ins and e-visits (G2010, G2012, 99421–99423)
• RHC/FQHC distant-site telehealth (G2025) through 2025, proposed through 2026.

How does Lara Health help practices stay profitable after the Telehealth Cliff?

Lara Health helps in several ways, some key advantages are: it unifies all major remote care programs (e.g. CCM, RPM, RTM, PCM, BHI/CoCM, APCM) in one platform. It automates time tracking, consent, documentation, and billing, identifies eligible patients, and integrates with EHRs, and accelerates the implementation. The result: compliant workflows, predictable recurring revenue, and a future-proof hybrid care model that thrives regardless of policy changes.