Telehealth Just Got a Two-Year Reprieve. Here’s What Your Practice Needs to Do Before You Rely on It.

A Practice Owner’s Annual Ritual: Watching Congress

Every fall for the past several years, Dr. Ruiz has done the same thing: she has pulled up her calendar, counted the weeks until the next Medicare telehealth deadline, and braced herself. Elena runs a solo counseling practice outside Phoenix, and roughly a third of her caseload is older adults who see her by video because driving in for a weekly session isn’t realistic for them. Each time Washington flirted with letting the telehealth flexibilities lapse, she drafted a contingency plan: which clients she’d have to see in person, which she might lose altogether, and how she’d explain a sudden policy change to people already anxious about their care. This year was different. In 2026, Congress folded a two-year extension of Medicare’s telehealth flexibilities into the Consolidated Appropriations Act, pushing the expiration date out to December 31, 2027. For the first time in a long time, Elena isn’t refreshing news alerts every ninety days. But the relief comes with a catch worth understanding before any private-practice owner gets too comfortable.

Why This Matters Beyond Medicare

Telehealth is no longer a pandemic-era workaround; it’s infrastructure. Across the country, video and phone sessions now make up a substantial share of all behavioral health visits, and clients increasingly expect the option even when they could technically come in person. The policy landscape has matured to match. As of mid-2026, 42 jurisdictions, including 40 states, the District of Columbia, and the Commonwealth of the Northern Mariana Islands, participate in PSYPACT, the interstate compact that lets licensed psychologists see clients across state lines without collecting a new license in every state. Montana joined as recently as October 2025. That kind of multi-state reach was unthinkable for a solo or small-group practice a decade ago, and it changes the math on how far a practice’s referral radius can realistically extend. At the same time, regulators haven’t simply waved telehealth through unconditionally. The extension comes bundled with sharper verification and documentation expectations, and states continue to set their own rules on consent, licensure, and what counts as an established versus a new patient relationship.

The Fine Print That Affects Your Growth Plans

Here’s the detail worth building into your planning: under the newly extended rules, patients who began receiving behavioral health telehealth services on or before January 30, 2026, are treated as established patients, subject only to the standard annual in-person visit requirement. Patients who start with you after that date, however, may trigger a different set of requirements, including an in-person visit before or shortly after care begins, depending on how your specific payer and state interpret the update. For a practice actively marketing telehealth as a way to reach new clients, especially across state lines under a PSYPACT authorization, this distinction matters. A prospective client who finds you online, books a first session, and expects to stay entirely virtual may be surprised to learn an in-person visit is required somewhere in that process. Handled proactively, in your intake materials and your marketing copy, this is a minor operational adjustment. Handled reactively, after a client has already scheduled and then discovers the requirement, it becomes a trust problem and a scheduling headache. The opportunity here isn’t just compliance risk management; it’s a chance to build a genuinely stronger intake process before growth makes the gaps more expensive to fix.

Why This Is Worth an Afternoon of Your Time

A two-year policy window is long enough to justify real investment, but short enough that you shouldn’t assume it renews itself automatically. Practices that treat this stretch of stability as permission to finally formalize their telehealth systems, consent language, documentation habits, and multi-state compliance, will be positioned to keep growing their reach without a scramble. Practices that keep treating telehealth as a temporary accommodation will find themselves doing the same anxious calendar-watching Dr. Ruiz did, except now with more clients depending on getting it right. The upside is concrete: a wider geographic pool of potential clients, fewer missed sessions from clients who simply couldn’t get into the office, and a referral base that includes colleagues and clients in other PSYPACT states. None of that requires raising your fees or seeing more people back to back; it comes from removing friction between the people who need care and your ability to reach them.

Your Action Plan: 6 Steps to Telehealth-Proof Your Practice

1. Audit your consent forms by state. Pull your current telehealth informed consent language and check it against the requirements in every state where you see clients, not just your home state. Consent content, and how often it needs to be renewed, varies significantly, and a form that satisfies one state may fall short in another.
2. Map who counts as an established patient. Go through your active caseload and flag which clients began telehealth care on or before January 30, 2026. For everyone else, confirm with your specific payers whether an in-person visit is required and build that step into your intake workflow rather than discovering it mid-treatment.
3. Update your intake and marketing language. If you’re promoting telehealth availability to attract new clients, especially across state lines, say plainly whether an initial in-person visit is part of the process. Clarity here protects the relationship before it starts.
4. Confirm your PSYPACT or multi-state authorization is current. If you’re licensed in a PSYPACT state, verify your authorization is active and budget for the renewal fee increase that took effect in January 2026. If you’re seeing clients in a non-PSYPACT state like California, Hawaii, Iowa, Massachusetts, or New York, confirm you hold the full license that state requires.
5. Document your telehealth platform’s compliance basics. Make sure whatever platform you use supports the privacy, security, and documentation standards your state and payers expect, and that you have a written record of that review for your own files.
6. Put a reminder on next year’s calendar anyway. December 31, 2027, feels far off, but policy windows have a way of arriving faster than anticipated. Set a review date now so this never becomes an emergency again.

The Bottom Line

For years, telehealth in private practice has felt like borrowed time. This extension is the closest thing to solid ground clinicians have had since the flexibilities first appeared, and it rewards practices that use the stability to build real systems rather than just breathe a sigh of relief. Take the afternoon. Audit your forms, map your caseload, and tighten your intake process. The practices that do this well won’t just avoid headaches, they’ll be the ones ready to serve clients a state away who never could have found their way into a waiting room otherwise.

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Photo by Vitaly Gariev on Unsplash

Written by AI & Reviewed by Clinical Psychologist: Yoendry Torres, Psy.D.

Disclaimer: Some blog posts may contain affiliate links, earning Sana Network a commission at no additional cost to you. These recommendations reflect our honest opinions about products or services we find helpful and trustworthy. This content is informational and not legal nor medical advice; consult an attorney or healthcare provider for personalized guidance.

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