Blog Post
Medicare Telehealth: What's Permanent and What's Not
Over 50 telehealth flexibilities were granted during the Public Health Emergency. Most expired in 2023, but a handful made it into permanent regulation.
When the Public Health Emergency officially ended on May 11, 2023, millions of Medicare beneficiaries who had grown used to virtual visits wondered what would remain. The swift, sweeping telehealth flexibilities granted during the pandemic were never meant to be permanent — but a meaningful core of them has now been locked into regulation.
The distinction matters because Medicare has historically required most services to be delivered in person and, for telehealth, required that the beneficiary be located in a designated rural area. The pandemic suspended those rules almost entirely. Now that normal operations have returned, CMS has drawn the line between what stays and what goes.
Here is what is now permanent for Medicare beneficiaries:
- Virtual check-ins (CPT 99421-99423) for established patients, letting you touch base with your care team remotely
- Annual wellness visits can be conducted virtually, expanding an important preventive touchpoint
- Medicare Advantage plans must offer 24/7 telehealth access as a covered benefit
- Certain behavioral and mental health services can be delivered via telehealth without geographic restrictions
The flexibilities that expired in 2025 are just as important to understand:
- New patient telehealth no longer allowed without a prior in-person visit first
- Cross-state provider licensing waivers have lapsed, so a doctor generally must be licensed in the state where you are located
- The temporary allowance for audio-only services for a broad range of visits narrowed back to specific situations
The practical impact: if you are 65 or older and rely on recurring virtual appointments, check whether your provider can still deliver that service remotely under the permanent rules. Not every service qualifies, and the rules differ based on whether you are in Original Medicare or a Medicare Advantage plan.
- Confirm with your provider which CPT codes they will bill and whether your visit qualifies
- Ask whether an in-person visit is required first for a new patient relationship
- Check that your provider is licensed to see you in your state, especially if you divide time between homes
Telehealth is not disappearing — it has been normalized for many of the most common interactions. But the safety rails are back. Understanding exactly which services remain virtual will help you avoid surprise denials and keep your care on track.
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The information here is general educational content. Your situation may have nuances that affect your optimal coverage strategy.
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