The government shutdown is already beginning to affect some therapists, and if you treat clients via telehealth, you could be one of them.

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September 30, 2025 was the deadline to extend the COVID-era telehealth waiver for clinicians treating clients covered by Medicare and Medicaid. Partly due to the shutdown, that deadline passed.

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Starting October 1st, 2025, mental health therapists must fulfill new in-person requirements when treating clients via telehealth. For therapists who run their own practices, this could mean making changes to day-to-day operations. Here’s what you need to know.

The end of the CMS telehealth waiver extension

In response to the COVID-19 pandemic, the Centers for Medicare & Medicaid Services (CMS) waived certain eligibility requirements for patients, allowing care providers to bill Medicare or Medicaid for telehealth services.

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As a result, mental health therapists could treat clients covered by CMS remotely. Many therapists moved large portions of their caseloads online. Others transitioned to running 100% remote therapy practices.

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The COVID-era waivers were extended multiple times. The last extension was due to expire on October 1, 2025 if Congress did not intervene. However, partly due to the October 1st government shutdown, no intervention took place, and the waivers expired.

What happens to telehealth therapy after October 1st?

The good news is that, compared to other healthcare practitioners providing telehealth services, the expiry of the telehealth waiver has minimal impact on therapists.

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The not-so-good news? If your practice is 100% remote, you will now need to find a way to occasionally treat clients in person.

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The new requirements for treating clients covered by CMS are:

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• New clients: You must treat a new client in person within six months of beginning telehealth treatment.

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• Existing clients: Once you start providing a client with telehealth treatment, you must see them for an in-person session at least once every 12 months.

Do existing telehealth therapy clients have in-person requirements?

If you were already treating a client via telehealth at the time of the October 1st deadline, you do not need to see them within six months of beginning treatment.

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That is, for existing telehealth clients, there is no need to immediately book an in-person session so that you can continue to bill CMS.

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However, existing telehealth clients do need to comply with the 12-month requirement. You must meet them for an in-person session within 12 months of the October 1st, 2025 deadline (so, before October 1st, 2026). You must also see them at least once every 12 months in the years following.

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Are there any exceptions to the new telehealth requirements?

If a client’s condition prevents them from seeing you in person, or if an in-person session would have a negative effect on patient progress, you may opt to forego the 12-month in-person visit requirement.

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However, you must document your reasons for skipping the required visit, and they must be supported by information in the client’s medical records.

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For a full breakdown of when and how this exception applies, review these guidelines from the APA.

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Also, if you run a group practice, you can meet the 12-month requirement by having your patient attend an in-person session with another therapist at your practice. The therapist must have the same level of training and licensure as you, including training in any relevant sub-specialties (eg. certain modalities).

What should I do if I only see clients remotely?

If your caseload consists entirely of clients you treat via remote sessions, and if any of those clients are covered by CMS, you will need to adapt your practice so that you can accommodate the new requirements for in-person sessions.

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• Communicate the new requirements to patients with CMS coverage, and work with them one-on-one to schedule in-person sessions

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• If you have CMS-covered clients who are unable or unwilling to attend in-person sessions, you may need to refer them out to another practice

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• When onboarding new clients with CMS coverage, make clear to them the requirement for an initial in-person session before beginning telehealth

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• If you work from home, look for local office-share or coworking options that offer private, comfortable rooms for occasional in-person sessions

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• If appropriate office-share or coworking options are not available, contact local therapy practices or healthcare clinics—they may be willing to rent you treatment rooms for a daily rate

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• Consider traveling to clients’ homes to provide in-person sessions

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Will the telehealth waiver return?

There is no concrete evidence to suggest that the telehealth waiver will be brought back once Congress is back in session.

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That does not mean that the situation will not change in the future. But, for the time being, the best plan of action is to comply with the new requirements and adjust your practice as needed.

Further reading

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• The telehealth waiver: What psychologists need to know
• Telehealth policy updates
• Fact Sheet: Telehealth Waivers   

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This post is to be used for informational purposes only and does not constitute legal, business, or tax advice. Each person should consult their own attorney, business advisor, or tax advisor with respect to matters referenced in this post. 

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Bryce Warnes is a West Coast writer specializing in small business finances.

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