The Looming Telehealth Cliff - Dietitian Direction

Originally Posted: September 9, 2025

Last Updated: September 29, 2025

What is the “Telehealth Cliff”?

The “telehealth cliff” refers to the potential expiration of Medicare telehealth flexibilities – a looming regulatory rollback sending us back in time to the pre-2020 Medicare telehealth restrictions. This dropoff of accessibility to care could be detrimental to many patients and healthcare businesses.

The use of telehealth has changed the landscape of healthcare in recent years. Prior to the COVID-19 pandemic, Medicare allowed some services to be provided via telehealth, but there were many restrictions, making it a very limited benefit. During the pandemic, Medicare enacted temporary telehealth flexibilities to expand telehealth coverage to help provide patients with better access to care without having to go to a medical office. These changes have transformed how many patients access healthcare well beyond the pandemic.

The federal government has pushed back the expiration dates of these flexibilities several times now, and they currently are set to expire on September 30, 2025. These dates are often pushed back last minute, so it is difficult for offices to prepare for potential changes. If changes do occur, there will most likely be little time to communicate this with patients.

Offices are unclear if they should discontinue telehealth services altogether, stop scheduling new patient telehealth visits, or just hope it all works out. There also seems to be a boy who cried wolf situation, where many organizations and providers are just assuming the flexibilities will be extended again, so they are not adequately preparing for potential change.

Pre-Pandemic Telehealth Restrictions

While Medicare technically allowed virtual care in certain circumstances prior to the pandemic, there were many restrictions that made telehealth look nothing like it does today. Here are some highlights:

Patients could only get care via telehealth if they were located in a rural or underserved area.
The patient could not attend the appointment in their home but rather a specific setting known as an “originating site” like a physician’s office, hospital, or skilled nursing facility. Therefore, the patient still had to travel to get care, it just wasn’t necessarily the same place the healthcare provider was located.
Telehealth could not be provided via telephone, with only some limited exceptions.
Many different provider types were not allowed to provide telehealth services, including:
- Physical therapists
- Occupational therapists
- Speech language pathologists
- Audiologists

Note that behavioral and mental health services have a lot less restrictions, and telehealth can permanently be provided in a patient’s home.

How Telehealth Restrictions Could Affect Insurance Beyond Medicare

Almost 20% of Americans have Medicare, so these changes would directly affect a significant amount of people. Furthermore, it will most likely have a ripple effect that will go well beyond Medicare beneficiaries.

Medicare guidelines are often looked to by other insurance companies to help them make decisions about coverage. If Medicare restricts the ability of services to be conducted via telehealth, other plans may follow suit.

Luckily, many states have telehealth parity laws to help prevent this rollback of coverage. There are two types of parity laws regarding telehealth:

Service parity – requires the same services be covered via telehealth as it would be covered if delivered in-person
Payment parity – requires the same payment rate to be reimbursed via telehealth as would be if the service had been delivered in-person

For example, if you provide care in a state that has service parity but not payment parity, the law requires that insurance companies pay for a service provided via telehealth if they would have paid for it in-person. However, they could choose to pay at a lower rate. Payment parity is less common compared to service parity.

To find out what telehealth laws your state has, check out The Center for Connected Health Policy.

It is important to note however, that these parity laws do not affect Medicare. Therefore, even if you live in a state that has a telehealth parity law, if the Medicare telehealth flexibilities expire, the parity laws do not change that.

How the Telehealth Cliff Affects Dietitians

Currently, because of the extended telehealth flexibilities, dietitians can meet with Medicare patients via telehealth while the patient is in their home. This is not only convenient for many patients, but it gives access to those patients that have mobility issues or lack of reliable transportation. It also opens up doors for dietitians that do not have physical office space; many dietitians are currently providing care via telehealth from their homes either on their own, through a group, or under a large telehealth platform.

Unlike some other services, Medical Nutrition Therapy (MNT) was allowed to be provided via telehealth prior to 2020. CPT codes 97802, 97803, 97804 and G0270 are all considered permanent telehealth services, meaning they can be provided via telehealth even if the extended flexibilities go away. However, all the rules and regulations effectively eliminate the ability of the majority of Medicare recipients to receive telehealth services while in their home.

Based on the old rules, the Medicare recipient can only receive telehealth services while in their home in certain situations including end-stage renal disease and substance use disorder. Otherwise, the patient has to travel to a specific location, such as a hospital. This is also only allowed if the location is considered to be in a health professional shortage area or a rural area. A rural area is considered as such if it is in a county that is not included in a Metropolitan Statistical Area.

Also, if we go back to pre-pandemic restrictions, MNT will no longer be able to be provided via a telephone call anymore as there is an audio-visual requirement. This can pose problems for Medicare recipients that have difficulty with technology or have an unreliable internet connection.

Finally, until December 31 2025, if a provider is in their own home while providing telehealth services, the enrolled practice location can be used as the billing location. For example, if a dietitian has an office location but stays home one day a week for telehealth visits, their office location can be used as the address for these claims. If no action is taken by the government to change this, starting in 2026, providers will have to start using their home address on claims in these instances, which many feel is a privacy and safety concern.

Telehealth-Only Business Models

Since 2020, many dietitians have started telehealth-only practices and started working for telehealth companies like Fay, Nourish and Berry Street. If the number of patients that have telehealth coverage declines, these companies will most likely see a decline in business as patients are forced to get in-person care.

Depending on who you ask, this could be seen as positive or negative. There are still many dietitians, including myself, that have brick and mortar offices and see patients in-person on a regular basis. Even for us, though, there are many patients that prefer to be seen via telehealth for a wide variety of reasons. This could include childcare or transportation concerns or just pure convenience. Also, patients may not have a dietitian in their area that specializes in their specific disease state.

What’s To Come

A continuing resolution has been released that, if passed, would extend telehealth flexibilities until November 21, 2025. However, we need real, permanent change rather than just extending pandemic-based rules. There is a bill, the CONNECT for Health Act of 2025, that would make this happen. If passed, it would remove geographic requirements and expand originating sites to include the patient’s home.

Overall Thoughts

The recurring threat of a telehealth cliff has exhausted healthcare organizations for quite some time now. Practitioners that only provide telehealth services are weighing if they should drop Medicare, take on the large expense of having an office, or just hope for the best.

Working in the healthcare industry has been especially volatile lately, and the unknowns about telehealth coverage has only added more precariousness. This is one more stressor that is leading to burnout and decreased job satisfaction in the industry.

The effect of the potential telehealth cliff on the general population is equally impactful. It is going to reduce access to care, require people to take off additional time from work to commute to appointments, and exacerbate health disparities. More and more healthcare professionals are choosing to drop Medicare, and telehealth uncertainties is just another reason to jump ship – this is the last thing Medicare beneficiaries need.