The Flexibility Deadline
Simplify Your Home Care Operations
CareCade helps DDA and HCBS providers manage scheduling, EVV, and billing in one platform.
According to CMS and federal guidance, many Medicare telehealth flexibilities that were established during the COVID-19 public health emergency are set to expire on January 30, 2026.
After January 31, 2026, the rules change significantly:
| Before January 31, 2026 | After January 31, 2026 |
|---|---|
| Patients can receive non-behavioral telehealth at home | Patients must be in a medical facility |
| Any geographic location eligible | Must be in rural area (most services) |
| Broader range of eligible services | Reduced service list |
| Established patient relationships only | Same restriction continues |
For behavioral and mental health services, home-based telehealth continues. But for other healthcare—including some services relevant to home care populations—the location requirements return.
What This Means for Home Care
Direct Impact
Home care agencies primarily serve patients in their homes. When telehealth must be delivered from medical facilities:
- Reduced convenience: Patients must travel for telehealth appointments
- Transportation barriers: Clients with mobility challenges face access issues
- Coordination complexity: In-home caregivers can't facilitate telehealth as easily
- Care fragmentation: Home-based and facility-based care become more separate
Indirect Impact
The broader healthcare ecosystem affects home care:
- Physicians may be less available for home health orders and certifications
- Care coordination telehealth may require facility visits
- Remote monitoring oversight may face new restrictions
- Clinical consultations during home visits may be limited
The Exceptions
Behavioral Health Continues
Telehealth from home remains available for:
- Mental health services
- Substance use disorder treatment
- Behavioral health consultations
- Psychiatric services
For clients with co-occurring behavioral health and developmental disability needs, these services can continue via telehealth from home.
Established Patients
The patient must have an established relationship with the provider:
- Prior in-person visit within specified timeframe
- Existing patient-provider relationship
- Not for new patient intake (generally)
Rural Originating Sites
Some services continue to be available via telehealth if the patient is in a designated rural area and at an approved facility type.
State-Level Variations
Federal Medicare rules set the floor, but states have flexibility for Medicaid:
Washington State
According to the Washington State Department of Health and Health Care Authority, Washington has enacted telehealth parity laws that affect Medicaid and commercial coverage:
- Audio-only telemedicine is defined and reimbursable under certain conditions
- Informed consent documentation is required for remote patient monitoring
- Medicaid fee-for-service has established reimbursement for audio-only services
- State laws may provide broader access than federal Medicare minimums
For DDCS providers serving Medicaid populations, Washington's state rules may be more relevant than Medicare's—but understanding both frameworks matters for agencies serving multiple payer types.
What Providers Should Do
Assess Your Telehealth Use
Inventory how telehealth currently supports your operations:
- Clinical consultations: Do you coordinate telehealth for client medical needs?
- Remote monitoring: Are you involved in technology-enabled care oversight?
- Behavioral health coordination: Do you support mental health telehealth?
- Training and supervision: Do you use telehealth for staff training?
- Family communication: Are telehealth tools part of family engagement?
Understand Your Payer Mix
The impact depends on who pays for services:
| Payer | Telehealth Impact |
|---|---|
| Medicare | Federal restrictions apply January 31, 2026 |
| Medicaid (Washington) | State rules may differ; check HCA guidance |
| Private insurance | State parity laws and individual contracts govern |
| Self-pay | No regulatory restrictions |
Plan for Transitions
If telehealth is integral to care delivery:
- Identify which services are affected by the cliff
- Develop contingency plans for affected services
- Communicate changes to clients and families
- Coordinate with clinical partners on adjustments
Advocate
Policy can still change:
- The Telehealth Modernization Act and other legislation could extend flexibilities
- Industry associations are advocating for permanent expansions
- State-level advocacy can affect Medicaid telehealth policies
The Bigger Picture
The telehealth cliff represents the tension between:
Emergency Flexibility
The pandemic forced rapid telehealth expansion. Regulations were waived because circumstances demanded it. Questions remained about quality, access equity, and appropriate use.
Pre-Pandemic Restrictions
Before COVID, telehealth rules were restrictive based on:
- Fraud prevention concerns
- Quality assurance requirements
- Geographic equity considerations (ensuring in-person access in rural areas)
- Technology readiness assumptions
Finding the Balance
The policy debate continues:
- Expansion advocates: Telehealth improves access, reduces costs, meets patient preferences
- Caution advocates: Quality concerns, equity issues, potential for fraud, importance of in-person care
The January 2026 cliff represents the current policy equilibrium—but it may not be the final word.
Washington-Specific Considerations
HCA Telehealth Policy
The Washington Health Care Authority maintains Medicaid telehealth policy:
- Audio-only telemedicine is covered under specified conditions
- Provider types eligible for telehealth reimbursement are defined
- Documentation requirements are specified
- Technology standards are established
Home Health Program
For Medicaid Home Health services in Washington:
- WAC 182-551-2125 addresses services delivered through telemedicine
- Face-to-face encounter requirements have specific rules
- Telehealth may supplement but not replace required in-person services
DDCS Services
For developmental disabilities community services:
- Service delivery typically requires in-person presence
- Telehealth may support coordination, training, and behavioral health
- Check with DSHS on any telehealth-specific guidance for DDCS
How CareCade Helps
While CareCade isn't a telehealth platform, we support the coordination and documentation that enables effective care delivery—whether in-person or hybrid.
Care Coordination
Keep all care—in-person and remote—coordinated:
- Scheduling visibility: Everyone knows the care plan
- Team communication: Coordinate between in-person and remote providers
- Family portal: Families stay informed about all care
Documentation Continuity
Complete records regardless of how care is delivered:
- AI session notes: Thorough visit documentation
- Activity tracking: Record what occurs during in-person visits
- Goal progress: Monitor outcomes across all care modalities
In-Person Excellence
When more care must be in-person, optimize delivery:
- Smart scheduling: Efficient caregiver routing
- EVV compliance: Verified in-person presence
- Mobile tools: Caregivers have everything they need on-site
- On My Way notifications: Families know when to expect caregivers
Looking Ahead
The telehealth landscape will continue evolving. Key developments to watch:
- Congressional action: Legislation to extend or make permanent certain flexibilities
- CMS rulemaking: Administrative changes to telehealth policy
- State action: Washington and other states expanding Medicaid telehealth
- Technology evolution: New modalities affecting policy discussions
For home care providers, the core mission remains unchanged: delivering quality care where clients live. Telehealth is one tool among many—important, but not the whole picture.
The agencies that thrive will be those that use technology effectively while maintaining the irreplaceable value of in-person, relationship-based care.