Medicare Telehealth Originating Site Rules: What Changed for 2026 and 2027

For most of the past year, telemedicine providers have been asking the same question about Medicare: will the patient’s home still count as a valid place to receive care? The answer, for now, is yes. Congress extended the flexibilities through December 31, 2027. That settles the patient side of the equation. It does not settle the provider side, and that is where a lot of practices are getting caught.

What The Extension Covers

Before the pandemic, Medicare paid for most telehealth services only when the patient sat in a rural area and connected from an approved clinical site, called the originating site. A home did not qualify. Those restrictions were waived in 2020 and have been renewed in pieces ever since.

The Consolidated Appropriations Act, 2026 pushed the current waivers to the end of 2027. During that window, patients can receive covered non-behavioral telehealth services at home, with no requirement that they live in a designated rural area. Audio-only visits remain payable for those services when video is not possible. Federally Qualified Health Centers and Rural Health Clinics can keep serving as distant-site providers, and the annual in-person visit requirements tied to these services stay suspended.

Behavioral and mental health care sits on firmer ground. Home-based access to those services was already permanent, and audio-only delivery and FQHC and RHC distant-site billing for them are now permanent as well. If you run a telepsychiatry or counseling practice, the 2027 date matters much less to you than it does to a primary care or specialty group.

Anything with a sunset date deserves a contingency plan. A practice whose Medicare revenue depends on non-behavioral home visits should know what its patient mix looks like if Congress lets the waivers lapse at the end of 2027. CMS is also expected to introduce new telehealth billing modifiers next year, so how you record the way each visit was delivered will matter more for audits.

The Provider Side Is Where Practices Get Tripped Up

The originating site rules describe where the patient is. Medicare also cares where you are, and that is tied to your enrollment record. Your enrolled practice location determines your Medicare Administrative Contractor, your payment locality, and what CMS believes about where your services take place.

For 2026, CMS said that virtual-only practitioners whose only physical practice location is their home must enroll that home address. Some groups had been billing home-based telehealth under the group’s address and were surprised to learn that flexibility ended January 1. Providers working across several states have reported backlogs when trying to add locations.

In August, CMS made a permanent enrollment flexibility official. A practitioner can provide qualifying telehealth from home without reporting the home address on enrollment and claim forms, and continue billing from an enrolled location. The condition is a separate physical practice location associated with a Medicare Part B enrolled group practice. It applies only to services that meet Medicare’s definition of telehealth, meaning services ordinarily furnished in person. Remote services that are not ordinarily done in person, such as teleradiology or remote monitoring, remain subject to location-specific enrollment.

Read that condition carefully. The relief goes to practitioners who can point to a real physical practice location. A virtual-only provider whose home is the only address on file still has to report it. Many physicians and NPs would rather not have their residence in a public-facing enrollment record, and that preference is reasonable.

Practical Steps For a Remote Provider

Start by finding out exactly which address your current Medicare enrollment lists and whether it is a location where you actually practice. Then confirm that your PECOS record, your NPI record, your DEA registration, and your state licensing address all tell the same story. Mismatches between those records cause more delays than almost any rule change.

If you bill through a group, ask whether the group’s enrolled location satisfies the physical practice location condition for your state. If you are a solo provider, decide whether you want your home on file or a separate professional address you can defend to a reviewer. A compliant address needs to be a real location where you can furnish services and keep records, not a mailbox.

Finally, treat the December 2027 date as a planning milestone. Providers who tidy up enrollment now will be in a much better position if the rules change again.

Where Arizona Fits

For providers based outside Arizona who treat Arizona Medicare patients, a qualified physical medical address in the state can serve as the practice location on file with Medicare, DEA, and the licensing board, while your day-to-day work stays wherever you are. Viva MedSuites offers that kind of address for providers working through Arizona compliance. Telemedicine memberships start at $199 a month. You can read more at vivamedsuites.com/telemedicine-az-address/ or call 480-616-2400.

John Groberg is the founder of Viva MedSuites, Arizona’s largest medical coworking community, with locations in Scottsdale and Mesa serving independent practitioners since 2017.