Insights

Telemedicine Billing in 2026: What Practices Must Prepare for Now

By: Mick Polo | Read Time: 5 minutes

Telehealth is here to stay — but how you bill for it is changing.

With recent regulatory shifts from Centers for Medicare & Medicaid Services (CMS) and ongoing payer policy evolution, 2026 will likely look different than the pandemic‑era billing surge. This article walks you through what’s confirmed, what’s changing, and how to prepare.

What’s Confirmed for 2025–2026 Telemedicine Billing

Medicare Telehealth Flexibilities Extended — But Expiration Is Near

CMS extended many of the telehealth flexibilities through January 30, 2026. That means traditional Medicare will continue covering certain telehealth services from home or other locations until at least that date. (Baker Donelson+2Medicare+2)
For example:

Audio-only and video telehealth for behavioral / mental health remains covered. (Medicare+2Centers for Medicare & Medicaid Services+2)
Real-time video telehealth with teaching physicians remains permissible under 2025–2026 CMS physician fee‑schedule rules. (Holland & Knight+1)

New Telehealth‑Specific CPT Codes Are Available (But Not Universally Accepted)

In the 2025 CPT edition, new telemedicine‑specific codes (e.g. audio-video and audio-only codes) were introduced to report virtual E/M visits. (The Rheumatologist+1)
However, as of early 2025, CMS declined to adopt most of these for Medicare telehealth claims — meaning many Medicare providers must still bill using standard E/M codes (99202‑99215) with telehealth modifiers, when allowed. (Simitree Health Care+1)

Telehealth Billing Requires Ongoing Documentation and Compliance Awareness

With shifting payer policies and varied coverage by state, practice, and payer type, telemedicine billing remains more complex than in‑person visits. Providers are advised to verify coverage per payer and ensure documentation supports medical necessity, especially for non-behavioral telehealth. (McDermott+2CCHP+2)

What’s Changing Now — And What You Should Watch Closely

Because telehealth policy remains in flux, some of the items below are not yet universally enforced — but are gaining traction among payers and regulatory bodies. These are best treated as “prepare‑for‑possible‑change” items.

Trend	What It Means for Billing / Compliance
More restrictive originating‑site & rural/urban limitations post‑January 2026	Under current Medicare telehealth policies, coverage for some services may revert to pre‑pandemic limitations when flexibilities expire. Centers for Medicare & Medicaid Services+2McDermott+2
Variation in payer acceptance of new CPT telemedicine codes	Some commercial insurers may adopt 98000–98015 codes; others may require traditional E/M codes or specific modifiers. Practices must maintain payer‑specific billing logic. The Rheumatologist+2Simitree Health Care+2
Increased documentation scrutiny for audio-only / audio-video telehealth	Proper documentation must reflect consent, modality (audio/video), time spent, and medical decision making to support coding — especially if payers audit more aggressively. (Current guidance from telehealth‑coding resources.) American Academy of Family Physicians+1
Ongoing evolution of CPT codes, remote monitoring, and digital health codes	The 2026 CPT update introduces dozens of new codes for remote monitoring, digital health, and connected care — practices should align telehealth workflows with these emerging services. ama-assn.org+1

How to Prepare Your Billing Workflow Now

Given this mix of confirmed and evolving changes, here’s a practical prep checklist to safeguard telehealth revenue in 2026:

Audit recent telehealth claims — track which modifiers, POS codes, or E/M codes were accepted or denied. This helps anticipate payer-specific behavior.
Maintain payer-specific billing logic — don’t assume one-size-fits-all. Different payers (Medicare, MA, commercial, Medicaid) may treat telehealth differently.
Update documentation templates — ensure consent, modality, time spent, medical necessity, and provider location (or supervision details) are captured.
Train staff (clinical + billing) — make sure everyone knows telehealth rules: from front desk to billing team. Include audio-only and video‑visit special requirements.
Monitor regulatory updates — CMS and payers may release quarterly or mid-year updates; stay enrolled in their newsletters or partner with a billing firm that tracks changes.

How NCDS Supports Telehealth Billing Continuity

At NCDS, we treat telemedicine as a core piece of a modern revenue cycle — not an afterthought. Here’s how we help clients stay ahead:

Real-time payer‑policy tracking for Medicare, MA, commercial, and state payers

Coding logic adjustments tailored to each payer’s telehealth requirements

Documentation templates and compliance training for providers and staff

Denial prevention workflows — especially for audio-only and remote visits

Proactive alerting for legislative or regulatory shifts that may impact billing coverage

We don’t wait for denials to catch up. We help prevent them.

Telehealth Is Evolving — Your Billing Should Too

Telemedicine went from “emergency solution” to “standard offering.” But now as flexibility expires and rules evolve, billing workflows must evolve too.

Don’t let outdated assumptions become a revenue leak.

Audit your telehealth billing today
Adjust coding, documentation, and workflows now
Stay alert for policy shifts — and partner with a team that adapts with you