Medicare telehealth waivers have expired. What occupational therapy practitioners need to know

Article updated 11/21/2025

Centers for Medicare and Medicaid Services (CMS) released additional guidance on processing for telehealth claims today. Providers should resubmit to CMS any telehealth claims that were previously returned on or after October 1, 2025 with CARC 16 and RARC M77 messages, as well as any claims that were held in anticipation of retroactive reimbursement. Additionally, CMS advises providers to identify any beneficiaries who were charged for telehealth services that are now retroactively payable for dates of service on or after October 1, 2025, submit those claims to CMS for payment, and issue refunds to the affected beneficiaries.

Article updated 11/14/2025

On November 12, 2025, Congress enacted legislation that extended Medicare telehealth waivers through January 31, 2026. Congress had directed the Centers for Medicare and Medicaid Services (CMS) to retroactively pay telehealth claims for dates of service on or after October 1. CMS has not yet released official guidance on the submission of held or returned telehealth claims; however, those claims will be retroactively reimbursed. AOTA will update this content once CMS releases additional details. For more information on the telehealth waiver extension and next steps, access AOTA's full news release here.

Article updated on 11/10/2025

As of October 1, Medicare waivers that allowed occupational therapy (OT) services via telehealth have expired, following Congress’s failure to extend them. As a result, therapy providers, including occupational therapy practitioners (OTPs), will not be reimbursed by Medicare for OT telehealth services provided to beneficiaries, unless Congress reinstates the waivers and makes coverage of these services retroactive.

These waivers—and other Medicare telehealth policies—were tied to the broader federal budget negotiations and expired when Congress failed to reach a compromise on how to fund the federal government. The Centers for Medicare & Medicaid Services (CMS) issued updated guidance on the expiration of the telehealth waivers on October 1.

On October 15, CMS instructed Medicare Administrative Contractors (MACs) responsible for paying Medicare claims to continue temporarily holding telehealth claims received for services rendered after October 1. On November 7, CMS announced that telehealth claims currently being held with dates of service on or after October 1, submitted on or before November 10, will be returned to providers. Practitioners may resubmit returned claims if anticipated Congressional action retroactively covers the services. For telehealth services beyond those for which Medicare currently pays, practitioners may also choose to continue holding unsubmitted claims until further guidance is provided.

We expect Congress to reinstate the waivers when it reaches a budget compromise. It is possible that when an agreement has been reached, Congress will authorize retroactive reimbursement for OT telehealth services provided during the lapse. However, retroactive coverage is not guaranteed.

With this lapse in Medicare telehealth coverage, OTPs should consider the following:

• Review your current caseload to identify clients who receive occupational therapy services via telehealth and may be affected by the shift back to in-person care.
• Consult with your employer or facility partners to determine options for meeting affected clients' therapy needs
• CMS has not issued specific guidance for Medicare Part A. If your facility decides to provide telehealth services for Medicare Part A patients, you must accurately document the services you provide.
• CMS is recommending that providers issue an Advance Beneficiary Notice of Non-coverage (ABN) to clients who request telehealth services under Medicare Part B. The ABN informs the client that the service may not be covered by Medicare and that they may be liable for payment for the service if Medicare denies the claim.

Please note that this situation is still evolving. AOTA will continue to monitor developments and share updates as new information becomes available—whether related to the waivers or CMS guidance on handling telehealth claims.