The road from lapse to runway

What the February 2026 law locks in for therapy

• Originating site

  Home stays on the list

  The patient's home remains a valid originating site for non-behavioral telehealth services through December 31, 2027. No facility requirement, no return to pre-waiver site rules.

• Geography

  No geographic restrictions

  The rural-only limitation stays suspended for non-behavioral services. Urban, suburban and rural beneficiaries can all receive covered telehealth visits at home.

• Distant site

  PT, OT, SLP and audiology stay eligible

  Physical therapists, occupational therapists, speech-language pathologists, and audiologists continue as eligible distant-site practitioners for the full extension window.

Why 23 months changes the calculus

Month-to-month stopgaps forced therapy practices to hedge. Nobody builds a hybrid scheduling model, renegotiates a commercial payer contract, or hires for virtual visit capacity when the billing rules could vanish in six weeks. A runway through December 31, 2027 is long enough to amortize those decisions. Hybrid plans of care, tele-eval workflows where state practice acts permit them, and payer contracting conversations that reference Medicare's posture all become defensible investments instead of gambles.

The other reason the window matters: it is finite, and the ending is already visible. The CY 2027 Physician Fee Schedule proposed rule is where CMS telegraphs its preferred permanent telehealth policy. Practices that read that signal early will negotiate 2028 from a position of preparation rather than surprise.

The operator to-do list

1. Reconcile the lapse window. Pull every telehealth claim with dates of service from October 1, 2025 through the H.R. 5371 restoration. Identify what was held, what was denied, and what was never submitted, then rework and resubmit under current guidance before timely filing clocks run out.
2. Confirm POS and modifier conventions per payer. Medicare conventions and commercial payer conventions are not guaranteed to match. Verify, payer by payer, which place-of-service code and which telehealth modifier each contract expects, and document the answer in your billing SOP rather than in one biller's head.
3. Calendar the next cliff now. Put December 31, 2027 on the executive calendar today, with an internal checkpoint in mid-2027 to reassess before the deadline politics begin.
4. Track the CY 2027 PFS proposed rule. Assign someone to read the telehealth provisions when the proposed rule publishes and to brief leadership on where CMS is steering permanent policy.
5. Make the hybrid decision deliberately. With rules stable through 2027, decide what share of visits, evals and plans of care belong in a virtual or hybrid model, and align staffing and scheduling to that answer instead of hedging month to month.