The Telehealth Policy Cliff That Could Destroy Your Practice Revenue
As the COVID-19 public health emergency winds down, the healthcare industry faces a looming crisis: the telehealth policy cliff. This term refers to the upcoming expiration of pandemic-era flexibilities on September 30, 2025. These temporary measures, which allowed patients to receive care from home, provided providers with enhanced telehealth reimbursement and eased eligibility restrictions, are set to end unless Congress or CMS intervenes.
The urgency cannot be overstated. Practices that invested heavily in virtual care and patients who have relied on telehealth for convenience and safety may face major disruptions. Understanding this cliff, its origins, what’s at stake, and how to respond is critical for every stakeholder in the healthcare system.
Define the Telehealth Policy Cliff
The telehealth policy cliff is the sudden expiration of COVID-era rules that drastically increased access to telehealth services. These policies included flexibilities for:
- Relaxed patient location requirements to allow care from home
- Expanded reimbursement for virtual visits
- Looser provider eligibility to allow clinics and mental health providers to participate in telehealth services
Unless legislative action is taken, these policies will end on September 30, 2025. Practices could see a dramatic decline in revenue, patients could lose access to care, and any telehealth program procedures could be rendered useless.
The cliff metaphor makes sense: a cliff is a sudden drop, and the healthcare system may face an equally sudden drop in telehealth access and revenue.
Background: Why It Exists
The telehealth policy cliff exists due to temporary waivers not being meant to be permanent. At the start of the pandemic, in response to the continued continuity of care:
- Congress and CMS put in place an emergency process to ensure continuity of care.
- Telehealth was expanded to protect patients and protect the healthcare providers caring for them, eg., rural populations, elderly population, and immunocompromised population.
- Services like audio-only services, remote monitoring, and hospital-at-home programs were created or grown.
These expansions worked remarkably well, leading to wider adoption of digital health tools, improved patient satisfaction, and continuity of care. But with emergency declarations coming to an end, the entire process is reverting back to the way it was pre-pandemic, unless Congress acts to extend these flexibilities.
What’s at Stake if Rules Expire
Patient Location Rules
As of now, patients can utilize Medicare telehealth services from home, which minimizes their need to travel, wait for appointments, and risk exposure to others. Unfortunately, after September 30, 2025, many patients will have to resume the practice of travelling to a physical facility to receive their care at a time when we have made progress toward convenience and access. Disadvantaged populations, including individuals living in rural areas, the elderly, and those with disabilities, along with behavioral health patients, will certainly be impacted.
Telehealth Reimbursement
The temporary changes also provided a generous telehealth reimbursement amount and incentivized providers to practice telehealth, which without such reimbursement could revert to providing telehealth visits at an outpatient rate or without reimbursement. This change will greatly change practice revenue, particularly for practices which have increased their use of telehealth.
Provider Restrictions
Certain providers may benefit from the pandemic flexibilities ending, including:
- FQHCs (Federally Qualified Health Centers)
- RHCs (Rural Health Clinics)
- Mental health providers
Without these limitations, new federal regulations may dictate the type of services that can be offered remotely, further decreasing patient access and complicating practice operation.
Scope of Services
Several telehealth modalities are at risk, including:
- Audio-only visits, which many behavioral health patients rely on
- Hospital-at-home programs, providing acute care in patient residences
- Remote patient monitoring for chronic conditions
Losing these services would reduce care options, reverse health equity gains, and decrease practice revenue.
Impact Analysis
Patients
Patients in rural areas, seniors, disabled individuals, and behavioral health populations face disproportionate harm. Telehealth has allowed these groups to maintain access to care despite mobility, distance, or other barriers. Eliminating these services could result in delayed care, worsening chronic conditions, and lower overall patient satisfaction.
Providers
Healthcare providers face operational and financial challenges. Practices that invested in telehealth technology may face:
- Reduced patient volume
- Loss of reimbursement for virtual services
- Increased administrative burdens to revert to in-person visits
Without strategic planning, these losses could threaten the sustainability of small and medium-sized practices.
Health Equity
Telehealth has been crucial in promoting equity. Removing access risks widening disparities in underserved communities, undermining years of progress in digital health adoption, and reducing outcomes for populations that historically face barriers to care.
Legislative & Policy Landscape
Telehealth Modernization Act of 2025
This legislation seeks to extend key flexibilities through 2027. It aims to preserve:
- Home-based patient access
- Expanded reimbursement
- Provider eligibility
Its passage is critical to preventing sudden disruption in care delivery.
CMS 2026 Proposed Rule
CMS has proposed rules that partially maintain telehealth allowances. Some services may continue under Medicare, but restrictions remain, creating uncertainty about reimbursement and service eligibility.
The CONNECT Act
The CONNECT Act complements these efforts by focusing on telehealth expansion, reducing administrative barriers, and improving rural and underserved access. Providers and policymakers must closely track these initiatives to understand which services will continue and under what terms.
Scenarios for October 2025
Full Rollback
If Congress does not act, all temporary flexibilities expire:
- Major disruption in telehealth services
- Significant revenue decline for providers
- Patients lose convenient access, particularly in rural and underserved areas
Partial Extension
Some services may be preserved temporarily:
- Providers face a patchwork system of coverage
- Planning and investment remain uncertain
- Patients experience inconsistent access
Full Extension / Modernization
If legislation passes to modernize telehealth:
- Continuity of care is preserved
- Predictable reimbursement for providers
- Telehealth becomes a sustainable, long-term care model
Strategic Responses for Stakeholders
Providers
- Audit telehealth reliance: Identify services and patient populations most dependent on telehealth.
- Plan hybrid models: Combine in-person and virtual visits to reduce operational risk.
- Communicate with patients: Educate patients on potential changes, alternative access, and continued care options.
Policymakers
- Act swiftly: Extend flexibilities before the cliff arrives.
- Protect vulnerable populations: Ensure rural, elderly, disabled, and behavioral health patients retain access.
Tech & Digital Health Players
- Prepare for uncertainty: Adapt platforms and offerings in anticipation of regulatory changes.
- Advocate for continuity: Engage with lawmakers to support telehealth expansion and modernization.
The Financial Imperative: Protecting Practice Revenue
Telehealth has evolved into a fundamental source of practice revenue. Practices that offered telehealth services:
- Expanded patient access,
- Increased visit volume,
- Improved operational efficiency.
Reducing telehealth reimbursement would create immediate financial stress for the practices. Without action, practice closure, employee layoffs, and fewer services could emerge for small- and medium-sized practices.
Patient Experience and Care Quality
Besides finances, patient experience is also at stake. Telehealth has:
- Improved adherence to care plans
- Decreased missed appointments
- Facilitated chronic disease management
- Supported continuity of behavioral health
If you take away telehealth access, you’re jeopardizing patient outcomes, especially for those that depend on it the most.
Regulatory and Compliance Considerations
Providers must also focus on compliance:
- HIPAA telehealth flexibilities provided during COVID may tighten
- Platforms must meet full privacy and security standards
- Audio-only and multi-state services may face restrictions
Non-compliance could result in penalties, fines, and additional operational costs.
Looking Ahead: Long-Term Telehealth Strategy
Assuming potential extensions, physicians will need to take a long-term approach:
- Hybrid care delivery models utilizing in-person, video, or remote monitoring
- Predictive analytics to improve efficiency and revenue
- Investing in patient engagement and education
Providers who take action will not only withstand the cliff but also make themselves the future leaders in modern and equitable patient-centered care.
Conclusion
The telehealth policy cliff presents a significant threat to patient access, provider sustainability, and healthcare equity. Upon the expiration of COVID-era flexibilities on September 30, 2025, patients may no longer be able to receive coordinated care at home, their healthcare provider may have a drop in revenue, and underserved communities may have greater gaps to fill in access to care. Telehealth has proved to be an integral part of improving outcomes in chronic and behavioural health management and increasing overall efficiency of care delivery. More than just convenience, preserving these services is about desiring continuity, promoting equity, and realizing long-term modernization efforts in health care.
Providers, policy makers, and technology stakeholders must act quickly. Clinics should audit their reliance on telehealth for care; they should also begin hybrid care model implementation, including notifying patients about changes. Legislators should modernize policies or extend some variation of telehealth policies to avoid disruption.
Technology and digital health platforms must prepare for a reality of uncertainty and work within their regulatory and policy realms to advocate for future telehealth policy to be in place, uninterrupted. Involving patients, clinicians, and patient advocacy voices into the conversation is even more necessary to ensure we preserve telehealth as accessible, equitable, and sustainable for our healthcare workforce as much as it is to protect delivery of care and revenue for practice.
FAQs: Telehealth Policy Cliff
1. What is the telehealth policy cliff?
The telehealth policy cliff occurs on September 30, 2025, with the end of the pandemic's flexibilities across patient location, reimbursement, and provider eligibility.
2. How does this affect telehealth reimbursement?
Some temporary policies supporting reimbursement for telehealth services could also end resulting in denials or reductions in payments for virtual visits and loss of revenue.
3. Who is most impacted?
Patients living in rural communities, older adults, people with disabilities, and patients receiving behavioral health treatment, along with Federally Qualified Health Centers, Rural Health Centers, and providers who deliver behavioral health services will face the most difficulties.
4. What legislation could prevent disruption?
The Telehealth Modernization Act of 2025 and the CONNECT Act will support flexibilities for telehealth utilization to help to maintain patient and provider access to care.
5. How can providers prepare?
Review your telehealth utilization, explore hybrid patient care delivery models, communicate with patients about using telehealth, confirm your telehealth services comply with HIPAA, and build and engage with your policymakers to support telehealth services.
