Congress extended Medicare telehealth flexibilities through Dec. 31, 2027, including the ability to conduct hospice face-to-face (F2F) recertification encounters via telehealth. The extension was signed into law Feb. 3 as part of the FY 2026 spending package.
However, the law adds new hospice-specific guardrails that limit when telehealth can be used for the F2F.
For hospice F2F encounters occurring on or after Jan. 31, 2026, telehealth cannot be used if:
The hospice is subject to enhanced oversight (Provisional Period of Enhanced Oversight, or PPEO).
The patient is located in an area subject to a CMS hospice enrollment moratorium (there are currently no federal hospice enrollment moratoria in effect).
The hospice physician or nurse practitioner completing the telehealth F2F is not Medicare-enrolled or validly opted out.
Beginning Jan. 1, 2027, CMS will also require a claim modifier to indicate when a hospice F2F was conducted via telehealth.
What it means:
Ohio is one of six states where CMS has expanded enhanced oversight activity. Based on current national interpretation, the restriction appears to apply only to hospices that are actually placed under enhanced oversight (PPEO), not automatically to all hospices in Ohio.
If your hospice has not received formal notice that it is under PPEO, telehealth F2F may continue, provided the other statutory parameters are met.
CMS has not yet issued detailed implementation guidance, including enforcement expectations or modifier instructions.
What to do:
Confirm whether your hospice has been formally placed under PPEO.
Verify Medicare enrollment or opt-out status for physicians and NPs conducting telehealth F2Fs.
Prepare billing and EMR workflows for the 2027 modifier requirement.
Monitor CMS and MAC guidance for enforcement clarification.
LeadingAge Ohio will share updates as CMS releases additional direction.