The pandemic made telehealth ordinary. Six years later, the harder question is which parts of that overnight transformation were actually built to last — and which were only ever a temporary bridge that policy kept re-flooring at the last minute. Virtual care 2026 looks less like a revolution in progress and more like a settlement: a smaller, steadier footprint than the 2020 peak, propped up by a Medicare telehealth policy landscape that has lurched from cliff to cliff rather than landing on permanent ground.
For health systems, payers, and vendors trying to plan budgets and staffing around telehealth 2026, the honest answer is that some pieces are now close to durable while others remain one budget fight away from disappearing. This piece walks through where utilization has settled, what the current Medicare telehealth extension actually covers, how hybrid care and remote monitoring have matured, and where access gaps persist.
Utilization has settled well above pre-pandemic levels, but far below the 2020 peak
The clearest data point from the last several years is that telehealth did not return to its pre-2020 near-zero baseline, but it also never sustained its pandemic peak. Research using national claims and survey data has generally shown telehealth’s share of outpatient visits jumping sharply in 2020, drifting down through 2022 and 2023, and then stabilizing at a mid-single-digit percentage of overall visits — commonly cited in the range of roughly 6-7% across primary care and outpatient medicine broadly, with wide variation by specialty.
That aggregate number masks a much more concentrated reality. Behavioral health has become the center of gravity for virtual visits: mental health services account for a large share of all telehealth claims, with utilization rates for behavioral health running many multiples higher than for most other specialty categories. Endocrinology, primary care follow-ups, and certain chronic-disease management visits also show meaningfully elevated telehealth use compared with surgical or procedural specialties, where an in-person encounter is often unavoidable.
The practical takeaway for planners: virtual care in 2026 is not a single trend line. It is a set of specialty-specific equilibria, and behavioral health’s telehealth-heavy pattern is doing a lot of the work in keeping national averages from settling even lower.
The Medicare telehealth policy status is still not fully permanent — proceed carefully
Nothing about virtual care planning matters more, or is harder to state simply, than the Medicare telehealth flexibility timeline. The pandemic-era waivers were never made fully permanent by Congress. Instead, lawmakers have repeatedly extended a subset of them through short-term continuing resolutions and appropriations packages, creating recurring “telehealth cliffs” — deadlines where flexibilities technically lapse before being retroactively restored, sometimes after a gap of days or weeks that created real billing and compliance uncertainty for providers.
As of this writing, the most recent legislative action extended a broad package of Medicare telehealth flexibilities for non-behavioral health services — including elimination of geographic and originating-site restrictions, expanded eligible practitioner types, FQHC/RHC distant-site billing, and audio-only coverage — into calendar year 2027, following a pattern of continuing resolutions that has already produced at least one brief lapse-and-retroactive-restoration cycle in the 2025-2026 period. Separately, many behavioral/mental health telehealth flexibilities — including no geographic restrictions, home-based originating sites, and audio-only delivery — have been placed on more durable footing, while the specific requirement for an in-person visit within six months of an initial behavioral telehealth encounter has itself been repeatedly delayed rather than permanently eliminated.
Given how frequently these dates have moved, treat any specific expiration date as provisional. Practices, billing teams, and health-IT vendors building claims logic or patient communications around Medicare telehealth should verify the current status directly against CMS’s telehealth guidance before finalizing anything tied to a hard cutoff date, and should build workflows that can tolerate another short-notice extension, lapse, or retroactive fix rather than assuming any single legislative action is the final word.
Medicare Advantage plans and many commercial payers have used their own flexibility to maintain broader telehealth coverage than fee-for-service Medicare requires, which has partly insulated patients in those plans from the federal cliff dynamics — but it also means telehealth coverage in 2026 varies meaningfully by payer, not just by service type.
Hybrid care, not “virtual-first,” is the operating model that stuck
The most durable strategic shift from the pandemic era is not that care went virtual — it’s that most organizations stopped treating virtual and in-person care as competing models and started designing them as one integrated pathway. Purely virtual-first ventures that scaled aggressively during 2020-2022 have generally right-sized or merged their virtual offerings into hybrid networks that pair video or asynchronous visits with in-person follow-up, labs, and procedures.
Health systems report that the operational work has shifted from “should we offer telehealth” to harder questions: which visit types belong on video, how scheduling and triage route patients to the right modality, how documentation and billing stay consistent across modalities, and how care teams — often including nurses, pharmacists, and care coordinators — handle the follow-up load that virtual visits generate. Hybrid scheduling and staffing, rather than a standalone telehealth product, is where much of the current investment is concentrated.
This also shows up in specialty patterns: behavioral health and chronic-disease follow-up lean virtual by default, while new-patient workups, procedural specialties, and anything requiring hands-on exam or imaging lean in-person, with video used for triage, pre-visit intake, or post-procedure check-ins rather than as a full substitute.
RPM and RTM are the growth engine, and AI is starting to change what “monitoring” means
While video visit volume has plateaued, remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) billing has continued to expand, driven by an aging Medicare population with multiple chronic conditions and by payment codes that reward continuous data collection rather than episodic visits. CMS has periodically adjusted the specific day-count and time thresholds tied to RPM/RTM billing codes, so the exact minimum monitoring days and management-time requirements should be checked against the current Medicare Physician Fee Schedule rather than assumed to be static year over year.
The more consequential shift is qualitative: RPM and RTM platforms are increasingly layering AI-driven analytics on top of raw device data — blood pressure, glucose, weight, activity, and therapeutic-adherence signals — to flag deterioration risk and prioritize which patients need a clinician’s attention first, rather than simply routing every data point to a nurse’s queue. Vendors describe this as moving from data collection toward triage automation: instead of a care team reviewing uniform, low-signal readings, algorithms surface the smaller subset of patients whose trends suggest real risk.
This matters for durability because it addresses RPM/RTM’s biggest historical bottleneck — the staff time required to review continuous data streams manually. If AI-assisted triage genuinely reduces that burden without degrading safety, it strengthens the economic case for RPM/RTM as an ongoing chronic-care tool rather than a pandemic-era novelty. It also raises new questions worth watching, including how algorithmic risk-scoring is validated, disclosed to patients, and audited for bias — none of which have settled industry-wide standards yet.
Behavioral health telehealth looks like the most durable clinical use case
Across nearly every utilization dataset, behavioral and mental health telehealth stands out as the segment least likely to contract. It combines several durability factors that other specialties lack: high patient acceptance of video-only encounters, a persistent national shortage of in-person behavioral health providers that virtual delivery helps address, and — as noted above — the most favorable and increasingly permanent policy treatment among Medicare telehealth categories.
That said, “durable” does not mean unconditional. The in-person visit requirement tied to initial behavioral telehealth encounters has been a recurring point of legislative back-and-forth rather than a settled question, and providers should not assume it has been permanently waived without checking current guidance. Audio-only behavioral telehealth — important for patients without reliable video access — has also depended on specific waiver language rather than a categorical, permanent allowance, reinforcing the broader theme: even the most resilient corner of virtual care still sits on a policy foundation that requires periodic verification.
Access and equity gaps have narrowed in some places and hardened in others
The pandemic’s virtual care expansion was supposed to close access gaps for rural and underserved patients; the actual record is mixed. Research consistently finds that broadband availability, not patient willingness, is the dominant barrier to telehealth use in rural and low-income communities — the Federal Communications Commission has estimated tens of millions of Americans still lack broadband adequate for reliable video visits. Surveys have repeatedly found that rural and lower-income patients express willingness to use telehealth at rates similar to urban and higher-income patients, which points toward an infrastructure and affordability problem rather than a preference problem.
Metro-area patients continue to use telehealth at roughly double the rate of patients in small towns and rural areas, a gap that has proven stickier than early pandemic-era optimism suggested. Digital literacy, device access, language access, and the availability of audio-only options (particularly relevant for older adults and for behavioral health) remain practical determinants of whether the policy flexibility described above translates into actual access. Federal broadband expansion funding and state-level digital-equity programs are the primary levers being used to close this gap, but progress has been incremental rather than transformative.
What’s durable versus what’s contracting: a working summary
Putting the threads together, a few patterns hold up across the data: behavioral health telehealth, RPM/RTM for chronic disease management, and hybrid scheduling models look structurally embedded in how care is delivered. Pure virtual-first primary care as a standalone business model, high-volume low-acuity urgent care video visits, and the assumption of frictionless, permanent Medicare telehealth billing all look more contested — either economically pressured, substitutable by in-person alternatives, or dependent on policy that has not yet been made permanent.
For anyone building products, budgets, or clinical workflows around virtual care in 2026, the operating assumption should be: design for the policy environment that exists today, build enough flexibility to absorb another short-term extension or brief lapse, and verify Medicare telehealth specifics against primary CMS sources immediately before any date-sensitive decision — not against a static article, however recently it hedges its dates.
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Frequently Asked Questions
Is Medicare telehealth coverage permanent now?
Not entirely. Many non-behavioral-health flexibilities have been extended through continuing resolutions and appropriations packages into 2027, while some behavioral health flexibilities are more durable. Because Congress has repeatedly used short-term extensions rather than permanent legislation, always confirm current status directly on cms.gov before making date-sensitive decisions.
Has telehealth utilization gone back to pre-pandemic levels?
No. Utilization dropped substantially from the 2020-2021 peak but has stabilized well above pre-pandemic levels, commonly cited around a mid-single-digit percentage of overall outpatient visits. Behavioral health remains a notable exception, with sustained telehealth use running many multiples higher than in most other specialty categories.
What does “hybrid care” mean in practice for a health system?
Hybrid care means designing a single care pathway that intentionally blends virtual and in-person steps — for example, video intake or triage followed by an in-person exam, or in-person diagnosis followed by virtual follow-up — rather than offering telehealth as a separate, siloed service line.
Why is behavioral health telehealth considered the most durable use case?
It combines strong patient acceptance of video-only visits, a persistent shortage of in-person behavioral health providers that virtual care helps offset, and comparatively more favorable Medicare policy treatment, including permanent provisions for home-based originating sites and expanded eligible provider types.
What is the biggest barrier to telehealth access in rural areas?
Research points to broadband infrastructure and affordability, not patient willingness, as the primary barrier. Surveys show rural and low-income patients are about as willing to use telehealth as other populations, but many lack the reliable internet access needed to do so.
