Operationalizing telehealth waiver updates: Tips from the NAHRI Advisory Board
On October 1, Medicare telehealth policy reverted to its pre-COVID-19 PHE state. Although the remaining PHE-era telehealth waivers were set to expire September 30, many stakeholders expected Congress and CMS to take action to extend them. However, lawmakers failed to pass a funding bill for fiscal year 2026, leading to a government shutdown and, therefore, reversion of Medicare’s telehealth policy to pre-COVID-19 PHE rules.
CMS released a special edition of MLN Connects® via email on October 2 to offer guidance during the shutdown. But organizations are still grappling with how to operationalize the changes, what this means for Medicare Advantage and commercial payers, what this will mean for reimbursement, and numerous other questions.
Several members of the NAHRI Advisory Board shared how their organizations are currently managing Medicare telehealth claims.
“We are continuing operations as usual, with the hope that coverage will be reinstated retroactively to October 1,” says Tiffany LaPlante, RMC, RMM, system manager revenue integrity, charge capture, at Bronson Healthcare Group in Kalamazoo, Michigan. “At this time, we are holding claims for select payers—Medicaid, Medicare, Medicaid HMOs, and Medicare Advantage plans.”
LaPlante adds that her organization received a bulletin from one Medicare Advantage payer stating that it will continue to follow CMS guidance for telehealth coverage and that if the government extends the waivers, it will align. Her organization is awaiting clarification and clarifying the commercial plans as well.
Michele Bear, DBA, CHRI, CRCR, CHC, CPC, executive director of revenue integrity, CDM, RCAR, QA, education and team member engagement at Baptist Health in Jacksonville, Florida, says her organization is doing much the same, with the exception that they are now requiring that Medicare patients come in for services.
Revenue integrity professionals can also urge their representatives to take action to restore coverage and reimbursement for affected telehealth services, says Denise Williams, COC, CHRI, SVP revenue integrity services at Revant Solutions, Inc., in Leland, North Carolina. There are two bills that are already under consideration:
- CONNECT for Health Act of 2025 (S.1261; HR 4206). This bill would make telehealth flexibilities permanent.
- Telehealth Coverage Act of 2025 (S. 2709; HR 2263). This bill would extend telehealth flexibilities through September 30, 2027.
Because the situation may change rapidly, revenue integrity professionals should carefully monitor communications from all payers and their Medicare Administrative Contractors (MAC). Work closely with colleagues across the revenue cycle and clinical leaders to ensure telehealth services are appropriately and compliantly furnished, documented, coded, and billed.
NAHRI will continue to provide updates as the situation unfolds. On Thursday, October 16, 2-3 p.m. Eastern, NAHRI members may also join a members-only call with their peers to discuss strategies for managing the reversal of telehealth waivers. Register for the call here.