How 2026 E/M and Telehealth Rules are Changing

The healthcare billing world is about to shift in 2026, and if you’re a provider, practice manager, or billing professional, you need to know what’s coming. The Centers for Medicare & Medicaid Services (CMS) has rolled out new rules for Evaluation and Management (E/M) services and telehealth that will affect how you document visits, code services, and get paid. These changes aren’t just minor tweaks. They represent a real transformation in how outpatient care gets billed and reimbursed.

Let’s break down exactly what’s changing, why it matters, and how you can prepare your practice for these updates.

What’s Happening with E/M Coding in 2026?

The E/M coding system has been through several updates in recent years, and 2026 brings another round of adjustments. CMS continues to refine how providers select the right level of service for office visits, consultations, and other outpatient encounters.

The biggest shift centers on documentation requirements and how medical decision-making (MDM) gets evaluated. For years, providers have juggled between time-based coding and MDM-based coding for established patient visits. The 2026 guidelines clarify these pathways even further, making it easier to choose the right code while still capturing the work you’re actually doing.

One major update involves the weight given to different elements of MDM. The number and types of problems addressed, the amount and nature of data reviewed, and the risk of complications all factor into your coding decision. In 2026, CMS is adjusting how certain diagnostic tests and treatment options count toward these categories. For example, ordering and reviewing specific imaging studies may carry different weight than before, and managing chronic conditions with multiple medication adjustments will have clearer guidelines.

Another key change affects new patient visits. The documentation requirements for establishing a new patient relationship are getting more specific. You’ll need to show not just that you saw the patient for the first time, but that you gathered appropriate historical information and made initial treatment decisions based on that data.

Time-Based Coding Gets More Flexible

Time-based coding has always been an option for E/M services, but the 2026 rules make it more practical for everyday use. Previously, you had to spend the entire visit on counseling and coordination of care to use time as your deciding factor. Now, total time spent on the date of the encounter counts, including time spent before and after the face-to-face visit.

This means tasks like reviewing records before the patient arrives, coordinating with other providers, or documenting the visit afterward all count toward your total time. For busy providers who spend significant time on these activities, this change could mean billing at a higher level when appropriate.

The time thresholds for each code level are also being refined. Make sure you’re familiar with the updated time ranges for codes 99202-99205 (new patients) and 99212-99215 (established patients). Even a few minutes can make the difference between code levels, which directly impacts reimbursement.

Telehealth Rules: What’s Staying and What’s Going?

Telehealth became a lifeline during the pandemic, and many of the temporary flexibilities that were put in place are now being made permanent or phased out. The 2026 rules clarify which telehealth services will continue to be reimbursed and under what conditions.

CMS is maintaining coverage for many audio-visual telehealth services, but with some new requirements. Geographic restrictions that were waived during the public health emergency are coming back in modified form. This means you’ll need to verify whether your patient’s location qualifies for telehealth reimbursement under the new rules.

Audio-only visits, which were temporarily covered during the pandemic, are facing new limitations. While some services can still be provided by phone, the reimbursement rates are lower than audio-visual visits, and the types of visits that qualify are more restricted. If your practice relies heavily on phone consultations, you’ll need to adapt your workflow.

The originating site requirements, which determine where a patient must be located to receive telehealth services, are also changing. Previously, patients had to be in specific healthcare facilities in rural areas. The 2026 rules expand this to include the patient’s home in many cases, but there are conditions attached. You’ll need to establish that the patient has an existing relationship with your practice and that the service is medically appropriate for telehealth delivery.

Mental Health and Behavioral Services Get Special Attention

One area where telehealth rules are actually expanding involves mental health and behavioral health services. Recognizing the ongoing need for accessible mental healthcare, CMS is making permanent many of the flexibilities for these services.

Behavioral health providers can continue offering services via telehealth to established patients in their homes. The frequency restrictions that limited how often these services could be provided remotely are being relaxed. This is great news for patients who struggle with transportation or who feel more comfortable receiving mental health services in their own environment.

However, prescribing controlled substances via telehealth is getting more scrutiny. The Drug Enforcement Administration (DEA) has proposed new rules that work alongside the CMS changes. Providers will need to meet specific requirements before prescribing certain medications through telehealth visits, including conducting an in-person evaluation in many cases.

Documentation Requirements Are Getting Stricter

Across the board, whether you’re billing for telehealth or in-person services, documentation requirements are becoming more detailed. CMS wants to see clear evidence that the service was medically necessary, appropriately delivered, and correctly coded.

For telehealth visits, you’ll need to document not just the clinical encounter but also technical details.

For in-person E/M visits, your documentation needs to clearly support the level of service you’re billing. If you’re using MDM to determine your code level, make sure your notes spell out the problems addressed, the data reviewed, and your assessment of risk. If you’re using time, document your total time and what activities you performed.

Reimbursement Rates and Payment Models

The 2026 Physician Fee Schedule includes payment adjustments for both E/M services and telehealth. While some codes are seeing increases, others are facing cuts. The overall impact on your practice will depend on your specialty and patient mix.

E/M codes for primary care services are generally seeing modest increases, reflecting CMS’s goal of supporting primary care providers. Specialist consultations are facing more varied changes, with some complex visit codes getting higher reimbursement while others remain flat.

Telehealth services are moving toward parity with in-person visits for many codes, but not all. Audio-visual visits for established patients will generally reimburse at the same rate as office visits, but new patient telehealth visits and audio-only services will reimburse at lower rates in many cases.

Alternative payment models (APMs) are also being updated to account for telehealth. If your practice participates in an APM or accountable care organization (ACO), check how these telehealth changes affect your quality metrics and shared savings calculations.

Technology and Platform Requirements

To bill for telehealth services in 2026, you’ll need to use technology that meets certain standards. CMS requires that telehealth platforms be HIPAA-compliant and provide adequate audio and visual quality for clinical assessment.

The relaxed rules that allowed providers to use consumer-grade video applications like FaceTime or OpenLoop are being phased out. You’ll need to use a platform specifically designed for healthcare that includes proper security features and privacy protections.

Your electronic health record (EHR) system also needs to be ready for these changes. Make sure your EHR can properly document telehealth encounters, track time spent on services, and support the new coding requirements. Many EHR vendors are releasing updates specifically for the 2026 changes, so stay in touch with your software provider.

Preparing Your Practice for 2026

Getting ready for these changes takes planning. Start by reviewing your current billing patterns. Which E/M codes does your practice use most frequently? How many telehealth visits are you providing? What’s your typical documentation process?

Training your staff is critical. Your providers need to know the new documentation requirements, your billing staff needs to apply the correct codes, and your front desk needs to verify patient eligibility for telehealth services. Consider bringing in an expert for training sessions or enrolling key staff in continuing education courses focused on the 2026 changes.

Review your technology setup. Test your telehealth platform to make sure it meets the new requirements. Verify that your EHR system is updated. Check that your internet bandwidth can handle multiple simultaneous video visits if needed.

Update your practice policies and patient communications. If you’re changing how you offer telehealth services, let your patients know. If you’re adjusting scheduling procedures to account for time-based coding, make sure your staff is aware.

Common Pitfalls to Avoid

As practices adjust to the new rules, certain mistakes keep showing up.

How Medwave Can Help

The 2026 E/M and telehealth changes affect every aspect of your revenue cycle, from coding to billing to reimbursement. At Medwave, we specialize in billing, credentialing, and payer contracting. Our team stays current on all regulatory changes so you don’t have to.

We can review your documentation to make sure it supports your coding decisions. We handle claims submission and follow-up, ensuring you get paid correctly for the services you provide. Our credentialing services keep your providers enrolled with payers and ready to bill for both in-person and telehealth services. And when it comes to payer contracting, we negotiate to make sure you’re getting fair reimbursement under the new rules.

Summary: E/M and Telehealth Rules are Changing in 2026

The 2026 E/M and telehealth changes are significant, but they’re manageable with the right preparation. Focus on documentation, train your staff, update your technology, and stay informed about the specific rules that affect your specialty.

These regulations are designed to ensure that providers get paid fairly for the work they do while maintaining quality and accountability. By adapting your practice to meet these new standards, you’ll be positioned for financial stability and growth in the years ahead.

Start preparing now. Review the final rules, assess your practice’s readiness, and identify areas where you need support. Whether you handle billing in-house or work with a partner like Medwave, make sure everyone on your team knows what’s changing and how to implement the new requirements.

The healthcare payment system will keep changing, but practices that stay informed and adaptable will continue to thrive. The 2026 updates are just another step in that ongoing process.