What Changed

• Telehealth is still allowed—but not guaranteed beyond January 2026
• Care management services must now be billed through specific CPT/HCPCS codes
• Grant funding favors operational performance, not new access points
• Patient affordability pressure will likely increase uncompensated care demand

Where Risk Is Concentrating

• Telehealth models that don’t match billing reality
• Care delivered but not fully captured or reimbursed
• Reporting burden increasing while decision clarity decreases
• Leadership relying on flexibility without a contingency plan

What “Ready” Looks Like in 2026

• Clear visibility into which services drive margin and access
• Aligned clinical, billing, and documentation workflows
• Reduced dependence on temporary policy allowances
• Leadership dashboards that show trends, not just compliance metrics

Bottom Line

2026 will reward organizations that treat policy change as an operating model signal, not an administrative task.