The Medicare telehealth flexibilities that allowed home health face-to-face (F2F) encounters to be conducted via telehealth have expired as of January 30, 2026. These flexibilities had been extended several times, with the most recent extension issued in November 2025, which extended the rules through January 30, 2026. With the expiration, agencies must now follow the standard Medicare rules, which generally require in-person F2F visits.
The good news is that The U.S. House of Representatives passed a consolidated appropriations bill (H.R. 7148) on January 22, 2026, which includes provisions to extend Medicare telehealth flexibilities through December 31, 2027.
However, the bill has not yet passed the Senate or been signed into law, so it is uncertain when or if the extension will officially take effect.
What this means for HHAs
- Potential Retroactive Coverage
If H.R. 7148 becomes law, it might retroactively apply telehealth flexibilities back to January 30, 2026, but this is not guaranteed. Agencies should not assume retroactive coverage yet. - F2F encounters return to pre-pandemic rules
With the expiration of telehealth flexibilities on January 30, F2F encounters must be conducted in person to qualify for home health admission under current Medicare rules.
Unless H.R. 7148 is enacted and applied retroactively, telehealth F2F encounters documented after January 30 may be considered invalid, and claims based on them could be denied or not affirmed. To minimize risk, agencies are advised to conduct all F2F encounters in person whenever possible.
With the expiration of telehealth flexibilities, in-person F2F encounters remain the safest option unless Congress or CMS issues new guidance. The best approach is to communicate proactively with practitioners and patients, flag potential risks, and watch closely for updates that could affect billing and compliance. While a retroactive extension remains possible, agencies should not assume they will happen — planning ahead now is the safest course of action.
