Final PFS Includes positive steps forward: expanded coverage, streamlined processes, and permanent adoption of key flexibilities
WASHINGTON, DC, NOVEMBER 3, 2025 – ATA Action, the advocacy arm of the American Telemedicine Association, today reacted to the final 2026 Medicare Physician Fee Schedule (PFS) posted by the Centers for Medicare & Medicaid Services (CMS).
“We are encouraged by CMS’ continued recognition of telehealth as a vital component of care delivery and are pleased to see many positive steps included in the final 2026 Medicare Physician Fee Schedule, including expanded coverage, streamlined processes, and permanent adoption of key flexibilities,” said Kyle Zebley, executive director of ATA Action and senior vice president, public policy of the ATA. “However, we have ongoing concerns that the issue of provider location and home address reporting has not yet been fully resolved, a change that could significantly impact providers across the country when the current flexibility expires on December 31. ATA Action will continue to engage with CMS on this issue seeking effective, practical solutions and clear guidance for providers delivering care from home.
“CMS did finalize an important provision that was not included in the proposed rule that we advocated for, which permanently allows teaching physicians to supervise residents virtually, when the patient, resident and supervising clinician are in separate locations, in all teaching settings,” added Zebley.
Other key final policies and provisions include:
- Permanently streamlined the process for adding services to the Medicare Telehealth Services List by removing provisional vs. permanent distinctions and focusing reviews on whether the service can be delivered via two-way interactive audio-video technology.
- Made several additions to the Medicare Telehealth Services List, as proposed.
- Updated telehealth codes and coverage, including not deleting coverage for Health Risk Assessment, as originally proposed.
- Removed critical care consultation services and certain inpatient/nursing facility telehealth frequency limits.
- Permanently adopted a direct supervision definition allowing “immediate availability” via real-time audio/video communication (not audio-only) for certain services.
- Finalized the proposed expansion of DMHT codes to include FDA-cleared or De Novo-authorized Digital Mental Health Therapeutic (DMHT) Devices for ADHD digital therapy, indicating that DMHTs will continue to be contractor priced and that the agency will work with Medicare Administrative Contractors (MACs) to “improve the understanding of the billing rules for HCPCS code G0552.”
- Temporarily allow MDPP suppliers to be virtual only and not be required to maintain in-person delivery capability through December 31, 2029, and establish a temporary “online delivery period” (2026-2029) to test asynchronous online delivery of Medicare Diabetes Prevention Program (MDPP) services.
- Finalized changes to allow billing for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) when data is collected for 2 to 15 days in a 30-day period (previously, a minimum of 16 days was required).
“On behalf of our members and the millions of patients relying on telehealth services for their care, we will continue to work with CMS to issue clear guidance on the provider location and home address reporting issue to ensure telehealth access remains seamless for both patients and clinicians,” Zebley said. “The Trump Administration has consistently supported telehealth and has a clear vision for how virtual care can modernize our healthcare system, with a focus on the treatment of chronic conditions, prevention and wellness strategies, and policies that promote advanced primary care and digital mental health treatments. We are grateful for their support and look forward to ongoing collaboration, as we continue to also push for the longest extension possible for the Medicare telehealth flexibilities and reinstatement of the Acute Hospital Care at Home program.”
About ATA Action
ATA Action recognizes that telehealth and virtual care have the potential to transform the healthcare delivery system by improving patient outcomes, enhancing the safety and effectiveness of care, addressing health disparities, and reducing costs. ATA Action is a registered 501c6 entity and an affiliated trade organization of the American Telemedicine Association (ATA).