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Telehealth billing has never been simple, but 2026 brings a fresh set of rules that make it even easier for claims to get denied if a practice isn’t paying close attention. Between updated Medicare Physician Fee Schedule policies, new in-person visit requirements for telemental health, and ongoing confusion around originating site rules, billing teams are being asked to keep up with more moving parts than ever.
For practices that rely on virtual visits as a meaningful part of their patient volume, understanding these changes isn’t optional. A single overlooked rule can mean a wave of denials that takes weeks to untangle.
Unlike in-person visits, telehealth billing depends on several extra variables: where the patient was located during the visit, what technology was used, whether the service qualifies under the current Medicare telehealth list, and whether payer-specific rules match or diverge from Medicare’s approach. Every one of these variables can change from year to year, and 2026 is no exception.
CMS issued the CY 2026 Medicare Physician Fee Schedule final rule effective January 1, 2026, updating payment policies for telehealth, therapy, behavioral health, and other services paid under the Physician Fee Schedule. Practices that don’t update their billing workflows to reflect these changes are likely to see a rise in denials tied to outdated assumptions from prior years.
CMS extended, through December 31, 2026, the ability for Federally Qualified Health Centers and Rural Health Clinics to bill for medical, non-behavioral health telehealth visits, including audio-only visits, using code G2025. These services continue to be paid based on the Physician Fee Schedule methodology rather than the Prospective Payment System or All-Inclusive Rate. Billing teams at FQHCs and RHCs need to keep using G2025 correctly through the end of the year rather than assuming a permanent change was made, since CMS declined stakeholder requests to make PPS or AIR reimbursement permanent for these medical telehealth visits, unlike the policy already in place for mental health visits.
One of the more disruptive changes for 2026 involves telemental health services at FQHCs and RHCs. Following the expiration of Medicare’s telehealth waivers on September 30, 2025, CMS finalized new in-person visit requirements for telemental health services furnished by these facilities. Under the finalized policy, an in-person visit must occur within six months before the first telemental health service, and at least once every twelve months afterward, unless the provider and patient document that the risks and burdens of an in-person visit outweigh the benefits.
This creates a documentation requirement that didn’t exist during the pandemic-era flexibilities, and practices that don’t track these visit intervals risk denials tied to a missing in-person encounter.
Provider location has become its own billing complication. CMS acknowledged concerns raised in public comments about provider privacy and the use of home addresses when enrolling as distant-site telehealth providers, but declined to extend the temporary allowance that let providers use their practice location instead of a home address. Providers billing as a distant-site telehealth provider from a home office need to be aware of this enrollment requirement, and practices should reference CMS guidance on suppressing address information from public display if privacy is a concern.
Payment differences based on where a service is delivered remain a factor practices need to track closely. Site-neutral payment policies affect how much a service reimburses depending on the setting, and rate differences between originating sites can catch billing teams off guard if claims aren’t coded to reflect the correct location.
Medicare’s telehealth policy is only one piece of the puzzle. State Medicaid programs and commercial payers often set their own telehealth billing rules, which don’t always match Medicare’s approach. A service that qualifies for telehealth reimbursement under Medicare might require different documentation, different modifiers, or might not be covered at all under a specific commercial plan.
Telehealth claims depend heavily on accurate use of modifiers and place of service codes, and small mismatches are a frequent source of denials.
Not every payer treats audio-only visits the same way as video visits, and some services that qualify for audio-only billing under Medicare don’t qualify under commercial plans. Billing staff need a clear reference for which services can be billed audio-only under each payer’s current policy, since submitting an audio-only claim under a code that requires video documentation is a common and avoidable denial reason.
Telehealth makes it easier for patients to see providers across state lines, but billing and licensure requirements don’t always follow. A provider licensed in one state may not be able to bill for a telehealth visit with a patient physically located in another state, depending on that state’s licensure rules and payer policies. This is especially relevant for practices with a growing telehealth patient base that spans multiple states.
Telehealth documentation needs to support both medical necessity and the fact that the visit met the technical requirements for telehealth billing, such as confirming the patient’s location or noting that a required in-person visit occurred within the applicable window. Missing this documentation is one of the fastest ways a telehealth claim ends up denied or flagged during an audit.
Extended budget disruptions have affected telehealth claims processing, creating uncertainty around Medicare fee-for-service telehealth coverage. Practices need to stay prepared for potential coverage gaps or delays tied to broader federal budget and policy decisions, rather than assuming current flexibilities will continue indefinitely.
A few structural habits make telehealth billing far more resilient to these ongoing changes:
Keeping up with telehealth billing rules that change year to year, and sometimes payer to payer, takes constant attention that most practices don’t have time to give. At IPIRCM, our Medical Billing service is built to keep telehealth claims accurate, properly coded, and aligned with the latest CMS and payer policies, so practices aren’t left chasing denials caused by outdated rules. If telehealth billing has become harder to manage, reach out to IPIRCM at 877-422-7221 or visit ipircm.com to schedule a free consultation.
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