The answer first: Medicare telehealth flexibilities, including audio-only coverage, now run through December 31, 2027. CMS has also proposed pushing the in-person mental health visit requirement to January 1, 2028.
The Consolidated Appropriations Act for FY2026, enacted by the 119th Congress on February 3, 2026, replaced the serial short-term telehealth patches with a genuine two-year extension. The CY 2027 Physician Fee Schedule proposed rule, CMS-1848-P, announced in a CMS fact sheet on July 14, 2026, operationalizes that extension. Billing teams finally get a stable planning window, and the smart ones will spend it preparing for the next cliff instead of celebrating this one.
The dated timeline: how the cliff moved
For three years, telehealth policy lived patch to patch, with expiration dates measured in months. Here is the sequence that changed the calendar, and the two dates that now define it.
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February 3, 2026Enacted law
Congress enacts the Consolidated Appropriations Act for FY2026
The 119th Congress ends the patch cycle. Geographic and originating-site waivers, expanded practitioner eligibility, and audio-only coverage are all extended in one package, through December 31, 2027. Patients can keep connecting from home, in any part of the country.
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July 14, 2026Proposed rule
CMS publishes the CY 2027 PFS proposed rule, CMS-1848-P
Per the CMS fact sheet of July 14, 2026, the proposed rule implements the extended flexibilities, including audio-only coverage through December 31, 2027, and proposes delaying the in-person mental health telehealth visit requirement to January 1, 2028. Proposed means proposed: the final rule can still change this.
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August 2026
You are here
Roughly 16 months of runway remain. This is the window to comment on CMS-1848-P, stabilize telehealth billing workflows, and build the renewal watch you wish you had before the last cliff.
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December 31, 2027The new cliff
Extended flexibilities expire
Absent further congressional action, the geographic and originating-site waivers, expanded practitioner list, and audio-only coverage all sunset on this date. Calendar it now, in your compliance tracker and your revenue forecast.
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January 1, 2028Proposed
In-person mental health visit requirement takes effect, if finalized
Under CMS-1848-P, the in-person visit requirement for mental health telehealth would begin here rather than earlier. Keep in-person scheduling capability on the shelf, not in the trash.
What exactly is extended through December 31, 2027
Geographic waiver
Rural-area restrictions on telehealth eligibility remain waived. Patients in urban and suburban locations stay covered.
RUNS THROUGH 12/31/2027Originating-site waiver
The patient's home continues to qualify as an originating site. No requirement to travel to a clinical facility to connect.
RUNS THROUGH 12/31/2027Expanded practitioner eligibility
The broadened list of practitioner types eligible to bill Medicare telehealth stays in place for the full extension window.
RUNS THROUGH 12/31/2027Audio-only coverage
Audio-only visits remain covered, per CMS-1848-P as described in the July 14, 2026 fact sheet. Critical for patients without reliable video access.
RUNS THROUGH 12/31/2027Two clocks, one calendar
A two-year window feels like forever in RCM time. It is not. Contract cycles, EHR configuration changes, and payer enrollment updates routinely consume quarters. Set both dates now and work backward.
The operator to-do list
- Calendar the cliff. Put December 31, 2027 in your compliance tracker today, with internal review checkpoints starting mid-2027. Do not wait for the next round of expiration headlines.
- Track the final rule. CMS-1848-P is a proposed rule. The January 1, 2028 mental health date is not final until the CY 2027 PFS final rule says so. Assign an owner to watch it.
- Keep audio-only billing clean. With audio-only covered through December 31, 2027, verify that your claims consistently distinguish audio-only encounters with the correct modifier and place-of-service coding, so payment integrity reviews find nothing to unwind.
- Audit practitioner eligibility. Confirm which of your billing practitioners rely on the expanded eligibility list, and quantify the revenue attached to them. That number is your exposure if the extension lapses.
- Do not dismantle in-person mental health workflows. The in-person visit requirement is delayed in a proposal, not repealed. Preserve the scheduling and documentation capability to switch it on.
- Separate Medicare from everything else. This extension governs Medicare. Commercial payers, Medicaid programs, and state telehealth parity laws run on their own calendars and must be tracked payer by payer.
Sources
Consolidated Appropriations Act for FY2026, 119th Congress, Congress.gov, enacted February 3, 2026. CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), CMS fact sheet, July 14, 2026, implementing the extended flexibilities including audio-only coverage through December 31, 2027 and proposing delay of the in-person mental health telehealth requirement to January 1, 2028.
Turn the two-year window into a two-year advantage
ASP-RCM Solutions runs telehealth revenue cycles for behavioral health, therapy, and multispecialty groups: eligibility verification, telehealth-specific claim scrubbing, denial prevention, and regulatory watch that flags dates like December 31, 2027 long before they hit your cash. If your telehealth billing grew up during the patch era, this is the window to rebuild it properly.
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