Telehealth and the Proposed 2026 Physician Fee Schedule

On July 14, 2025, CMS released the proposed 2026 Medicare Physician Fee Schedule (PFS), and it brings some notable updates for telehealth and digital health programs. As always, this is a proposal – what is included in the Proposed 2026 PFS may not be approved or may be changed significantly. Regardless, here's what you need to know based on the proposed 2026 PFS—what’s changing, what’s staying, and how to prepare.

Permanent COVID Flexibilities

The first and most significant change is the proposed addition of a number of COVID-era flexibilities as permanent. As of this writing, most of these flexibilities have been extended multiple times, but their status as temporary has led to some reluctance among providers to adopt telehealth as a care modality. The changes are described briefly below:  

• Elimination of the “provisional” list: CMS plans to remove the distinction between provisional and permanent telehealth services. Now, any service that meets basic criteria (separately payable, allowable under Section 1834(m), and suitable for 2-way audio‑video) can be permanently added to the list.
• Frequency limits lifted: Inpatient, SNF, and critical-care telehealth visits can be delivered via telehealth without limitations—no arbitrary caps like “one per X days.”
• Virtual direct supervision: Real-time audio-video can now satisfy the “direct supervision” requirement for most incident‑to services and for FQHCs & RHCs—this flexibility becomes permanent as of January 1, 2026.

These changes have the potential to reduce administrative burdens and give clinicians more flexibility in implementing telehealth models. It also signals CMS’s broader intention to treat virtual care with parity and permanence rather than extending its use on an ad hoc basis.

Expanded Telehealth Services & Facility Fees

Additionally, the 2026 PFS has proposed adding a number of new telehealth services. These services are primarily focused on mental and behavioral health, which have been adapted well to digital care. There is also a proposed increase in facility fees for originating sites. The services and facility fee changes are described briefly below:

• The telehealth list now proposes adding:
• Multiple-family group psychotherapy (CPT 90849)
• Group obesity counseling (G0473)
• Infectious disease add-on (G0545)
• Facility fee increase: The originating-site facility fee (Q3014) is set to climb to approximately $31.85 — up ~2.7%

New service lines and better facility reimbursement send a message: telehealth is here to stay and expanding, beyond pandemic-era stopgaps.

Remote Monitoring & Digital Therapeutics

Remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) have both been addressed specifically in most recent PFS. This year is no different – there is an expansion of what is considered a billable service and has requested comment on other ways that remote monitoring should be used.

• RPM/RTM codes: CMS proposes to pay for defined spans of remote monitoring (e.g., 2–15 days of data collection per 30-day period) with assigned reimbursement amounts.
• Digital mental health devices: The rule broadens digital mental health treatment codes to now include devices used for ADHD, and introduces payment options for other FDA-cleared digital therapeutics targeting chronic disease.
• Future exploration: CMS is requesting comment on expanding payment frameworks further—for example, adding eye-tracking tech for ASD diagnoses or facilitating digital tool reimbursement for lifestyle/mental health plans.

These developments signal CMS embracing the digital health toolbox—paying not just for visits, but for ongoing monitoring and tech-enabled care plans.

What This Means for You & Your Telehealth Program

While these are still proposed changes, it is important to understand the potential impacts on a telehealth program. A few hypothetical impacts are described below:

What’s Next?

CMS is seeking comments on the proposed 2026 PFS. If you have any comments to share on these changes, you can share them here until the open comment period ends on September 12, 2025.  

Further Information:

• Centers for Medicare and Medicaid (CMS) - Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (CMS-1832-P) Fact Sheet
• American Telehealth Association (ATA) - FIRST LOOK AT 2026 DRAFT MEDICARE PHYSICIAN FEE SCHEDULE DEMONSTRATES POSITIVE STEPS FORWARD FOR VIRTUAL CARE, SAYS ATA ACTION
• American Association of Family Physicians - Medicare proposed rule includes changes to telehealth coverage