The telehealth cliff has arrived: What’s changing and what to watch

The telehealth cliff has arrived: What’s changing and what to watch 
Healthcare Law Blog; by Sheppard Mullin Richter & Hampton LLP, co-author Joel Dankwa; 10/9/25
On October 1st, certain key telehealth flexibilities created during the COVID-19 public health emergency (“PHE”) expired as the government shutdown began. The Centers for Medicare & Medicaid Services (“CMS”) issued a number of telehealth waivers during the PHE, some of which were extended through September 30, 2025 by the Full-Year Continuing Appropriations Act, 2025 (“CAA”). The flexibilities expired as legislative efforts to once again extend the flexibilities, including through the House Committee’s stop-gap government funding Continuing Resolution, failed to pass. The flexibilities that expired on October 1, after being extended by the CAA, are:

• Definition of “Originating Site”: ...
• Definition of “Practitioner”: ...
• RHC and FQHC Telehealth Services: ...
• In-Person Visit Requirement for Telehealth Mental Health Services: ...
• Audio-Only Telehealth: ...
• Recertification of Eligibility for Hospice Care: ...
• Hospital at Home: ...