Urgent Update: Telehealth Flexibilities Restored – Effective Through January 30, 2026

November 17, 2025 

Congress has passed the Continuing Appropriations and Extensions Act, 2026 (CR), ending the government shutdown and reinstating COVID-era telehealth flexibilities for home health and hospice services. 

According to the National Alliance for Care at Home, these flexibilities are now effective retroactively (as if they never lapsed) to October 1, 2025, and extended through January 30, 2026. 

What This Means for Providers: 

• Hospice Providers: Required Face-to-Face (F2F) encounters before the third or later benefit periods can now be performed via telehealth by a physician or nurse practitioner 

• Home Health Agencies: F2F visits can again occur via telehealth without geographic or originating site restrictions. Home Health Agencies (HHA) are not specifically mentioned in the CR because the change in the law impacts providers who can bill for telehealth services. HHAs are encouraged to use telehealth but cannot bill for the visits. 

Background

Before the COVID-19 Public Health Emergency (PHE), federal law required telehealth patients to be located at an “originating site,” such as a physician’s office or a critical access hospital, and limited services primarily to rural or underserved areas. During the PHE, these restrictions were lifted—eliminating both the originating site and geographic location requirements. This flexibility allowed clinicians to deliver and bill for telehealth services directly to patients in their homes, making care more accessible and streamlining the F2F encounter process. Without an extension of these flexibilities, telehealth reverted back to the “dark ages.” 

Keep Informed

The current temporary extension preserves these critical flexibilities, offering much-needed relief for providers delivering care at home and for the patients who depend on it. However, this is not a permanent solution. The Alliance continues to advocate for lasting legislative changes to ensure uninterrupted access to telehealth services for all patients. 

(Original Post from September 26, 2025 remains below for reference) 

September 26, 2025

As of today, the U.S. government is facing a high risk of a partial shutdown beginning October 1 due to stalled negotiations on a funding bill. With current funding set to expire on September 30, providers should prepare for a temporary gap in telehealth flexibilities—particularly those impacting home health and hospice services.

According to a recent update from the National Alliance for Care at Home, unless Congress reaches a last-minute agreement, telehealth flexibilities will not be extended past September 30. While this disruption may be short-lived, it could significantly impact compliance and care delivery.

What Providers Need to Do Now

Hospice Providers:

• Review all Face-to-Face (F2F) encounter due dates for patients entering their third or subsequent benefit period.
• If the F2F encounter falls within October 1–30, and you plan to use telehealth, complete the encounter by September 30 to remain compliant.

Home Health Agencies:

• Telehealth use for F2F encounters is more complex due to the 90-day before/30-day after start-of-care window.
• If any upcoming encounters fall within this timeframe and telehealth is preferred, alert practitioners and patients now so they can act before the September 30 deadline.

Important Note

Telehealth policies for Medicaid are determined at the state level and are not impacted by the federal September 30 deadline.

Stay Informed

The Alliance will continue to provide updates as the situation evolves. In the meantime, we strongly encourage all providers to plan for a gap in telehealth availability and adjust workflows accordingly.