CMS ENDS KEY FLEXIBILITY ENABLING MORE AFTER-HOURS TELEHEALTH, ADDS NEW BURDENS ON CLINICANS
ALLIANCE STATEMENT
NOVEMBER 3, 2025
The Alliance for Connected Care is disappointed that the Centers for Medicare and Medicaid Services (CMS) announced changes that will make it more difficult for a Medicare-enrolled practitioner to offer telehealth services from an alternative location. CMS plans to change billing rules, enabled by the Trump Administration in 2020, that allowed clinicians to be more available to their patients through telehealth when they are not in the office – such as after-hours telehealth visits from their homes.
For the past five years, CMS has allowed a telehealth practitioner to report and bill using their currently enrolled practice location even when offering a telehealth service from their home or another location. This policy helped reduce administrative complexity in Medicare billing and strengthened continuity of care by allowing patients to continue seeing their existing practitioners.
CMS did not renew this policy in the final CY2026 Physician Fee Schedule (page 172). If this change goes into effect in January 2026, many telehealth visits offered by practitioners from locations other than their enrolled billing location will end. Those who continue providing such care would need to separately enroll and bill for each location from which they deliver telehealth services. This is administratively difficult and will dramatically increase regulatory burden on both these practitioners and organizations with payment systems that are not designed to accommodate this reality.
While we appreciate CMS action to mitigate concerns about the release of clinicians’ home addresses, we believe privacy and clinician safety risks of unintended disclosure remain. Additionally, we believe the significant operational burden created by this policy has unfortunately been largely overlooked.
In a survey of Alliance members, it was estimated that this change will result in up to a fortyfold increase in the number of billing addresses tracked and reported to CMS by a health system. Multiple health systems estimated the resulting operational costs of this change at approximately $1 million in labor. CMS itself would also have significant operational costs related to the processing of additional documentation that would be submitted to the agency.
The Alliance shares CMS Administrator Oz’s vision for reducing administrative burden and empowering clinicians to focus on what matters most – caring for the patients they serve. We strongly support efforts to streamline regulations, simplify documentation requirements, and modernize federal policies that no longer reflect how care is delivered in today’s connected environment. This change is the antithesis of that vision and should be immediately corrected through sub-regulatory guidance.
For more on the Alliance’s work to advance access to comprehensive telehealth care, please visit https://connectwithcare.org/provider-location/.
Alliance Letter to Congressional Leadership Urging Retroactive Payment for Medicare Telehealth Services
The Alliance for Connected Care sent a letter to Congressional leadership, urging immediate action to clarify that retroactive payment will be offered for expanded telehealth services provided during the lapsed period due to the government shutdown.
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Open in new tab Alliance and 60 Organizations Letter to Congress Urging Urgent Action for Patient Access to Medicare Telehealth Services
The Alliance for Connected Care and 60 organizations, sent a letter to Congressional leadership, urging for immediate action to mitigate the negative impacts on Medicare beneficiaries as a result of the government shutdown and related lapse in Medicare telehealth flexibilities.
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Alliance Sends Letter to Governors Rural Health Transformation Fund
The Alliance for Connected Care sent a letter to Governors, highlighting an important opportunity to prioritize new and emerging technologies and data and technology-driven solutions that help rural providers furnish high-quality health care services.
The Alliance strongly encouraged States to consider:
- Support for state action to design and implement telehealth registry capabilities that enable more cross-border care;
- Support for rural hospitals to better leverage out-of-state specialists through telehealth to augment their community capabilities;
- Efforts to expand national clinical trial participation at rural hospitals;
- Facilitate the cross-border sharing of prescription data for safety, and/or
- Funding to leverage remote physiologic monitoring (RPM) services and empower patients to prevent and manage their chronic disease.
The ability for licensed, credentialed health care professionals to provide patient care across state lines via telehealth helped maintain continuity of care, promoted patient choice, helped address workforce shortages, and improved access and care coordination. Increased telehealth access across the country also helped improve patient access to primary and specialty care, boosted patient and caregiver engagement, reduced missed appointments, and improved post-operative care.
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Alliance for Connected Care Response to CY26 OPPS
The Alliance for Connected Care responded to the Centers for Medicare and Medicaid Services (CMS) Calendar Year (CY) 2026 Hospital Outpatient Prospective Payment proposed rule.
The Alliance urged CMS to recognize payment for genetic counselors providing care virtually, expand its proposal on virtual cardiac rehabilitation, and allow for outpatient reimbursement for RPM care management services. We believe these steps will improve the overall quality of care, lower costs, and improve the experience of Medicare beneficiaries.
Read the full letter here or below:
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Alliance for Connected Care Response to CY26 Medicare PFS
The Alliance for Connected Care responded to the Centers for Medicare and Medicaid Services (CMS) Calendar Year (CY) 2026 Medicare Physician Fee Schedule proposed rule. The Alliance respectfully urged CMS to continue to work with Congress and other federal agencies to ensure long-term certainty and access to the full spectrum of virtual care options for Medicare beneficiaries.
The Alliance appreciated the strong support of virtual care by the Trump Administration and emphasized the following:
- The Alliance is disappointed that CMS did not address provider enrollment and billing concerns related to the reporting of address for a telehealth service offered from a provider’s home or other non-clinical location. This policy will end December 31, 2025. A lapse in current policy will dramatically affect the virtual care workforce, while creating substantial new administrative burdens on health care providers offering virtual care.
- The Alliance is very concerned by the potential end of virtual supervision for teaching physicians and requests that CMS provide a year extension of this flexibility prior to making any decision that would so drastically affect the medical workforce and the preparation of new clinicians to offer telehealth. The Alliance appreciates the broader modernization of virtual supervision in the rulemaking.
- The Alliance applauds CMS for its proposal to streamline the telehealth service list review process. As the Alliance commented in our response to the CY 2023 and 2024 Physician Fee Schedule, there should not be a need for CMS to separately evaluate whether providing a service itself provides clinical value, and it can meet all clinical requirements when offered through telehealth.
- The Alliance applauds CMS for its changes to address the sustainability and access to remote patient monitoring in Medicare. We support the new codes, and the use of the CY2026 OPPS geometric mean cost (GMC) data for valuation, as long as some tweaks are made to this proposal. On a related point, we continue to call for a broader review of technology and software-driven practice expenses in Medicare.
- The Alliance supports CMS actions to expand virtual care as part of the Ambulatory Specialty Model and Diabetes Prevention Program, however recommends specific changes to accelerate virtual care and potentially dramatically strengthen the outcomes of both programs.
Read the full letter here or below:
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Preventing Burdensome Location Reporting Requirements on Telehealth Practitioners
The Alliance for Connected Care sent a letter, expressing concern with the omission of a continuation of telehealth location reporting flexibility for telehealth practitioners in the proposed CY2026 Physician Fee Schedule. Without prompt action by CMS, this important telehealth policy will end and dramatically increase administrative burden for both practitioners offering telehealth services while increasing costs for CMS.
The Alliance requested CMS leadership in ensuring that telehealth practitioners working from a home-based location are not mandated to report their private residence to the federal government for purposes of enrollment or billing. More specifically, we asked CMS to:
- Extend permanently current telehealth flexibility that allows a practitioner to bill for telehealth services from a location at which the clinician is capable of offering in-person care to patients, even when the practitioner is practicing at a different location, such as the home. Without action from CMS, this flexibility will end on December 31, 2025.
- For practitioners without a physical practice location, we request CMS work with stakeholders to develop an alternate method of determining location for the purposes of payment that does not mandate the reporting of a home address. One potential option would allow a business address to be reported for purposes of enrollment, and a geographic indicator such as a zip code to be reported for payment adjustment by geographic cost and wage index.
- Work with the Drug Enforcement Administration to encourage a complementary solution for medical practitioners who report a practice location while prescribing a controlled substance. As you know, the DEA also requires a physical billing location for some telehealth visits – greater alignment across these program requirements would reduce administrative burden.
Read the full letter here or below:
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Alliance for Connected Care Leads 350 Health Care Stakeholders Urging Congress to Extend Medicare Telehealth Access Before September 2025 Deadline
In a strong show of national consensus, 350 health care stakeholder organizations have signed a letter urging Congressional leadership to take immediate action to preserve access to Medicare telehealth services beyond their scheduled expiration in September 2025. The letter calls on Congress to enact the longest possible extension of existing telehealth authorities, with a minimum two-year extension needed to ensure continuity of care and operational stability for patients, providers, and the health care system at large.
The 350 signers — including patient groups, hospitals, medical societies, behavioral health providers, community health centers, digital health companies, and other health care organizations — stress that while permanent telehealth access remains the goal, a multi-year extension is the most practical step to ensure seamless care delivery in the near term. Importantly, the letter emphasizes that extending Medicare telehealth services continues a bipartisan policy sustained over the last five years and would not introduce new federal costs.
Without action before September 2025, the expiration of current flexibilities would risk widespread confusion, especially among providers and patients in rural and underserved communities.
“For millions of seniors, telehealth is not a convenience—it’s a lifeline. Yet today, many are asking their clinicians a painful question: will my care disappear after September? We call on policymakers to act now to protect the remote care access seniors depend on without interruption.” Chris Adamec, Executive Director, Alliance for Connected Care
Read the full letter here or below:
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Alliance Asks Congress to Differentiate Medicare Telehealth “Cliff” from Federal Funding Deadlines
The Alliance for Connected Care sent letters to Congress asking that Congress work to differentiate the Medicare telehealth “cliff” from the federal funding deadlines. If there is a short extension until December, we ask that you seek to mitigate the significant patient/provider disruption caused by the potential for a lapse.
Read the full letter to the Senate Finance Committee below:
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Alliance Leads Over 200 Organizations Letter to New DEA Administrator on Telehealth
The Alliance for Connected Care led a letter signed by over 200 organizations in a letter to Terry Cole, Administrator of the Drug Enforcement Administration (DEA), requesting his leadership in ensuring that millions of Americans continue to have access to medically necessary health care through telemedicine after the current access deadline of December 31, 2025.
We are only 23 weeks away from access to the telemedicine services the DEA oversees ending. Given this approaching deadline, and widely recognized challenges with previous policy proposals, we encourage action by the DEA to:
- Engage directly with experts and stakeholders on policymaking that would continue access to telehealth while preventing diversion; and
- Ensure a plan is in place by the Fall of 2025 to prevent millions of Americans from losing access to their medical treatments in December of 2025.
“Expanding access to comprehensive telehealth services with clinically appropriate prescribing was a major policy achievement of the first Trump Administration. We urge Administrator Cole to take swift action to prevent its expiration in December.” – Chris Adamec, Executive Director, Alliance for Connected Care
Read the full letter below or here:
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