Lexology July 16, 2025
Hall Render Killian Heath & Lyman PC

On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2026 Medicare Physician Fee Schedule (“PFS”) proposed rule. Several of the PFS proposals are related to telehealth, signaling a continued investment and interest in telehealth policies and use post the COVID-19 pandemic. The proposed rule does not address or discuss the continued coverage of telehealth services via the pandemic waiver flexibilities, as this coverage was established through legislation unrelated to CMS’s PFS rulemaking.

Telehealth Proposal Overview

The proposed rule aims to streamline the overall processes for receiving services through telehealth. Among the most significant proposals are the permanent removal of frequency limitations for subsequent inpatient visits, nursing facility visits and critical care consultations delivered via...

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