Telehealth After the Waivers: What Primary Care Needs to Know Now

Medicare’s pandemic-era telehealth waivers have expired. That means no more home-based visits for most primary care, and geographic restrictions are back. If your clinic relied on virtual care, it’s time to pivot—strategically and compliantly.

ProTrust Billing Partners LLC

10/15/20252 min read

The COVID-19 pandemic transformed telehealth from a niche offering into a mainstream lifeline. But as of September 30, 2025, many Medicare flexibilities have expired—leaving primary care providers facing a new reality. If your practice relied on virtual visits for chronic care management, check-ins, or access for homebound patients, it’s time to reassess your workflows, billing, and compliance strategy.

What Changed on September 30, 2025?

The expiration of Medicare’s pandemic-era telehealth waivers means:

Home-based telehealth visits are no longer reimbursable for most primary care services.

Geographic and originating site restrictions are reinstated: patients must be in rural areas and at qualifying medical facilities.

Audio-only visits and expanded provider eligibility (e.g., PTs, OTs, SLPs) are no longer guaranteed.

Behavioral health services retain some flexibilities, but primary care faces stricter limits.

These changes stem from the end of temporary waivers authorized during the Public Health Emergency (PHE). Unless Congress acts to extend them, providers must revert to pre-pandemic rules.

What Counts as a "Rural Area" for Telehealth?

Under reinstated Medicare rules, telehealth services must originate from a qualifying medical facility located in a rural area. CMS defines rural areas as:

• Locations outside a Metropolitan Statistical Area (MSA).

• Or, within a Health Professional Shortage Area (HPSA) designated for primary care.

To verify eligibility, providers can use the Medicare Telehealth Payment Eligibility Analyzer, entering a patient’s address to determine if it qualifies

Operational and Financial Impacts

For primary care practices, the implications are immediate and far-reaching:

Denied Claims: Visits that were reimbursable last month may now be rejected.

Access Gaps: Homebound, elderly, and rural patients may lose access to care.

Revenue Disruption: Practices that relied on telehealth for chronic care management or check-ins may see reduced reimbursement.

Compliance Risk: Billing errors may increase as teams navigate reinstated restrictions.

Strategic Steps for Primary Care Teams

To stay compliant and resilient, primary care teams should:

1. Audit Telehealth Workflows

Identify services that are no longer reimbursable and adjust scheduling, documentation, and coding accordingly.

2. Educate Staff and Patients

Communicate clearly about what services must now be in-person and what exceptions remain.

3. Explore Alternative Programs

Consider Chronic Care Management (CCM), Remote Patient Monitoring (RPM), or in-home visits under different billing codes.

4. Advocate for Change

Join professional associations pushing for legislative action to reinstate or extend telehealth flexibilities

Looking Ahead: Compliance Meets Compassion

The telehealth cliff is more than a billing issue—it’s a test of adaptability, equity, and strategic foresight. Primary care providers must now balance compliance with compassion, finding new ways to serve patients who benefited most from virtual care.

At ProTrust Billing Partners, we’re helping independent clinics navigate this transition with clarity, confidence, and compliance. Whether it’s refining workflows, educating teams, or advocating for policy change, we’re here to anchor your practice through uncertainty.