On the Precipice: The Telehealth Modernization Act and the Looming Policy Cliff
As the September 30, 2025 deadline approaches, the U.S. healthcare system faces a profound turning point. Unless Congress acts, pandemic-era telehealth flexibilities—credited with revolutionizing care access and delivery—will expire. This “policy cliff” threatens to undo years of progress, restricting patient access, straining provider capacity, and deepening health inequities.
The bipartisan Telehealth Modernization Act of 2025 (H.R. 7623 / S. 2016) offers a clear path forward. The legislation would not only preserve the gains of the last five years but also cement telehealth as a permanent fixture of U.S. healthcare delivery.
From Fringe to Foundation: Telehealth Before and After COVID-19
For decades prior to 2020, federal policy limited telehealth to a narrow set of circumstances. Medicare reimbursement was largely restricted to patients in rural areas or designated Health Professional Shortage Areas, and only when those patients received care in specific facilities known as “originating sites.” Patients’ homes were excluded, and audio-only visits were rarely covered (American Hospital Association [AHA], 2025a).
As a result, adoption remained low. In 2016, only 14% of physicians reported using telehealth, a figure that held steady until the pandemic forced systemic change (American Medical Association [AMA], 2023).
When the federal government invoked Section 1135 waivers in March 2020, these barriers fell away. Medicare temporarily covered telehealth in all geographic areas, permitted the home as an originating site, and expanded provider eligibility to include therapists, audiologists, and other clinicians (Centers for Medicare & Medicaid Services [CMS], 2025). Adoption surged: by 2022, 80% of physicians were offering virtual care, compared with fewer than 20% before the pandemic (AMA, 2023).
Equally transformative was the Acute Hospital Care at Home (AHCaH) waiver, which enabled hospitals to deliver inpatient-level care in patients’ homes. Evaluations found AHCaH patients experienced lower mortality rates, reduced costs, and fewer hospital-acquired infections compared to traditional inpatient stays (Mass General Brigham, 2024).
The Looming Policy Cliff
Congress has since extended many of these flexibilities, most recently through September 30, 2025, under the Consolidated Appropriations Act (AHA, 2025b). But these are temporary fixes. Without the passage of new legislation, Medicare rules will snap back to their pre-2020 restrictions.
If that happens:
Patients will once again need to travel to specific facilities in rural or shortage areas for covered telehealth visits.
Audio-only visits—a lifeline for patients without broadband or smart devices—will no longer be reimbursed.
AHCaH programs will lose Medicare reimbursement, forcing patients back into already strained hospitals.
Providers such as physical therapists, occupational therapists, and audiologists will lose their ability to deliver care virtually.
The implications are serious. In 2023, 12.6% of Medicare beneficiaries used telehealth, far exceeding pre-pandemic levels (Telehealth Resource Center, 2025). Eliminating access would disproportionately harm older adults, low-income patients, and rural residents—26% of Medicare beneficiaries lack access to a computer or smartphone and rely on audio-only visits (Kaiser Family Foundation, 2023).
The Telehealth Modernization Act: A Data-Driven Solution
The Telehealth Modernization Act of 2025 provides a durable solution by making permanent the most effective pandemic-era flexibilities (Carter, 2025):
Eliminating geographic and originating site restrictions so all Medicare beneficiaries can access telehealth from any location.
Extending AHCaH reimbursement through 2030, providing stability for hospitals and patients.
Retaining expanded provider eligibility, ensuring therapists and other clinicians remain part of the virtual care workforce.
Making audio-only visits permanently reimbursable for patients who cannot access video care.
Securing reimbursement for Federally Qualified Health Centers and Rural Health Clinics, stabilizing access in underserved areas.
These provisions are grounded in evidence. A systematic review found telehealth improved accessibility, reduced costs, and increased efficiency across patient populations (ResearchGate, 2025). Patient satisfaction is consistently high, with 85% citing convenience and 80% reporting better scheduling flexibility (Journal of Medical Internet Research, 2020). And in the case of AHCaH, CMS reported lower mortality and post-discharge costs compared to traditional inpatient care (AMA, 2025).
What Still Lies Ahead
While the Act represents a crucial step, challenges remain. Interstate licensure continues to limit cross-state practice, broadband disparities persist, and concerns about patient privacy demand ongoing vigilance (American Bar Association, 2021; Federal Communications Commission, 2024). Telehealth’s long-term success requires not only legislative action but also infrastructure investments and state-level reforms.
Conclusion: A Call to Action
The evidence is clear: telehealth is no longer experimental—it is essential. By passing the Telehealth Modernization Act of 2025, Congress can prevent a rollback of progress, stabilize healthcare delivery, and ensure virtual care remains accessible for the patients who need it most.
As the September deadline approaches, the choice is stark: either retreat to a fragmented, inequitable past or move forward toward a resilient, patient-centered future. The Telehealth Modernization Act is the bridge to that future.
References
American Bar Association. (2021). Potential legal implications of telemedicine and telehealth. https://www.americanbar.org/groups/law_practice/resources/law-technology-today/2021/implications-of-telemedicine-and-telehealth/
American Hospital Association. (2025a). Fact sheet: Telehealth. https://www.aha.org/fact-sheets/2025-02-07-fact-sheet-telehealth
American Hospital Association. (2025b). Fact sheet: Telehealth waivers. https://www.aha.org/fact-sheets/2025-02-07-fact-sheet-telehealth-waivers
American Medical Association. (2023). AMA telehealth policy, coding, and payment. https://www.ama-assn.org/practice-management/digital-health/ama-telehealth-policy-coding-payment
American Medical Association. (2025). Hospital at home saves lives and money: CMS report. https://www.ama-assn.org/delivering-care/population-care/hospital-home-saves-lives-and-money-cms-report
Carter, B. (2025). Text of the Telehealth Modernization Act. https://buddycarter.house.gov/uploadedfiles/tma_bill_text.pdf
Centers for Medicare & Medicaid Services. (2025). Coronavirus waivers & flexibilities. https://www.cms.gov/coronavirus-waivers
Journal of Medical Internet Research. (2020). Determining if telehealth can reduce health system costs: Scoping review. https://www.jmir.org/2020/10/e17298/
Kaiser Family Foundation. (2023). Telehealth utilization among Medicare beneficiaries. https://www.kff.org/medicare/
Mass General Brigham. (2024). Study of national data demonstrates the value of acute hospital care at home. https://www.massgeneralbrigham.org/en/about/newsroom/press-releases/study-of-national-data-demonstrates-the-value-of-acute-hospital-care-at-home
ResearchGate. (2025). The impact of telemedicine on patient outcomes during the COVID-19 pandemic: A systematic review and meta-analysis. https://www.researchgate.net/publication/388285768
Telehealth Resource Center. (2025). The telehealth policy cliff: Preparing for October 1, 2025. https://telehealthresourcecenter.org/resources/the-telehealth-policy-cliff-preparing-for-october-1-2025