Telehealth for Therapists: What’s Permanently Approved & What’s Still Pending

Telehealth has transformed how therapy services are delivered, offering greater flexibility, improved access, and continuity of care for patients across settings. But as of October 2025, the future of telehealth for physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) under Medicare remains in flux.

This article walks you through what is approved today, what changes are coming, and how therapy practices can prepare, so you can stay compliant, protect revenue, and prepare your team and patients for what’s next.

1. The Current State of Telehealth for Therapy Providers

A. Temporary Extensions Through September 30, 2025

Thanks to legislative action, many Medicare telehealth flexibilities remained in place through September 30, 2025. According to the U.S. Telehealth Policy resource:

• Medicare patients were able to receive many telehealth services in their home, without geographic restrictions, through that date.
• PTs, OTs, and SLPs were included among the practitioners eligible under the extended waiver through that timeframe.

B. What Happens After September 30 / Into 2026?

Absent further congressional extension or statutory change, many of the telehealth flexibilities revert to the pre-COVID rules. Medicare’s official FAQ states that beginning in 2026 the restrictions on provider types, geographic limitations, and originating site rules will resume.

2. What’s Permanently Approved?

While much of the telehealth flexibility for therapy remains provisional, a few key categories are now permanently carved out under Medicare.

A. Behavioral & Mental Health Services

• Telehealth services for behavioral or mental health care are permanently allowed in patients’ homes, including audio-only platforms and no geographic restrictions for certain provider types.
• However: this does not automatically extend to PT/OT/SLP services unless those services fall under behavioral health or another qualifying category.

B. Communication Technology-Based Services (CTBS)

• CTBS (brief virtual check-ins, remote monitoring, etc.) remain available and may be used by therapy providers depending on payer policies, though they are not full telehealth under Medicare’s telehealth statute.
• Example: CPT 98016 (brief virtual check-in) may be billed under certain conditions.

Bottom line: For most therapy practices, full telehealth reimbursement under Medicare remains conditional, not yet permanent.

3. What’s Still Pending: Legislation to Watch

The good news? Rehab providers have prominent legislation in motion that could permanently change access.

Key bills include:

• Telehealth Modernization Act (H.R. 7623): Seeks to permanently include PTs, OTs, SLPs as telehealth providers and remove geographic/site restrictions.
• Expanded Telehealth Access Act (H.R. 3875 / S. 2880): Advocates for therapy professionals to be added to the authorized provider list.
• Expanding Americans’ Telehealth Options Act (H.R. 8151): Broadening eligible telehealth provider categories to include rehab professions.

Until one of these becomes law, the current waivers remain temporary. As a therapy business leader, your role includes monitoring these bills and engaging in advocacy.

4. Billing, Coding & Compliance Essentials

Telehealth for therapy isn’t just about whether you can deliver remotely; it’s about billing correctly and ensuring compliance.

A. Therapy CPT Codes & Telehealth Eligibility

• Codes such as 97110 (therapeutic exercise), 97530 (therapeutic activities), and 92507 (speech therapy) may appear on the Medicare Telehealth Services List, but eligibility depends on provider type and rule changes.
• If a PT/OT/SLP is not eligible to bill telehealth under Medicare after the waiver expires, claims may be denied.

B. Modifiers and Place of Service (POS) Codes

To bill valid telehealth services (where allowed):

• Modifier 95: Service furnished via interactive audio/video telehealth
• Modifier 93: Services furnished via audio-only when permitted
• POS 10: Patient is at home
• POS 02: Patient is at another location (non-home)

You must also document:

• Patient consent for telehealth
• Mode of communication (video/audio)
• Provider and patient location
• Clinical justification (why telehealth was appropriate)

C. Audit-Readiness & Risk Considerations

• Keep clear documentation of service justification, especially given the scrutiny on telehealth billing.
• Train staff on changing rules: what to do now, what may change, how to respond.
• Review payer policies (Medicare vs commercial) for telehealth eligibility in your state and setting.

5. Practical Action Steps for Therapy Practices

With the telehealth landscape shifting, here’s how therapy businesses can act now:

• Stay Informed: Subscribe to NARA’s policy alerts, attend webinars on telehealth compliance, and monitor CMS updates.
• Engage in Advocacy: Encourage your team and patients to support bills that would make telehealth permanent for PT/OT/SLP providers.
• Educate Patients: Make sure Medicare beneficiaries understand what telehealth options may change and what you’re doing to protect access.
• Build Contingency Plans: If telehealth eligibility ends, shift workflows, scheduling and services to in-person or hybrid models.
• Audit Systems Now: Ensure your billing workflows, documentation templates, and scheduling systems reflect current telehealth rules, and can be adapted quickly.

6. Strategic Considerations for 2026

As we look ahead:

• Develop a hybrid care strategy where feasible: e.g., in-person evaluation, virtual follow-ups when allowed, home-oriented check-ins under CTBS codes.
• Diversify payer mix: rely less on Medicare telehealth coverage and explore commercial payers or cash-pay models that support telehealth.
• Leverage telehealth now where commercially viable, while preparing for the possibility of rollback under Medicare.
• Use this time to measure outcomes: track patient satisfaction, access improvements, cost savings from virtual care, data you can use in advocacy and marketing.

Navigating Telehealth’s Future in Therapy

Telehealth remains a valuable tool in rehabilitation, enhancing access, improving continuity, and supporting patient-centered care. But as of October 2025, therapy providers must navigate a complex transition: many telehealth rules are still temporary, and full eligibility for PTs, OTs, SLPs under Medicare is not yet permanent.

By staying engaged, advocating for policy change, and proactively adapting your operations, you can position your therapy practice for success whether care happens through a screen, at home, or in-person.

For additional resources, compliance tools, and advocacy updates, visit the NARA Resources & Advocacy Hub.