Give remote days a place in the practice
You want to add telepsychiatry days while keeping an in-person practice that already works. Start with the patients and appointments you would consider for remote care, using your clinical judgment and the practice’s procedures. Decide how those days will connect with clinic days. Give the work between visits a place in the schedule.
Review how the practice handles a failed connection and how a patient can reach the team afterward. Establish the approved process for confirming location and responding when an urgent local need arises. Discuss who provides in-person follow-up when you are working remotely, including during an absence from your usual clinic. These are arrangements to settle with the people who will use them before opening additional remote appointments.
Keep a dated policy review beside the calendar. Telepsychiatry rules in 2026 and 2027 involve separate questions about permission to practice, prescribing, and Medicare requirements, as reflected in the distinct HHS, DEA, and CMS guidance1,2,3. Review each for the service you plan to provide. A change in a coverage rule should prompt a check of that rule without being taken as a change in every other requirement.
Check telehealth across state lines
HHS says clinicians must meet requirements where they are located and be licensed or legally permitted to practice where the patient is located1. Build the location check into the practice’s scheduling and visit process. A patient’s usual address leaves a question open when that person is traveling. Confirm the actual location relevant to the encounter.
For a patient planning time in another state, check that state’s board before arranging remote visits there. HHS describes several possible interstate pathways, including a full license, compacts, and certain registrations or exceptions where available4. Review the route that applies to you rather than assuming a general exception. Keep the board’s requirements attached to the plan for that patient’s period away.
A patient’s usual address leaves a question open when that person is traveling.
Consider the practical consequences for an established panel. Ask the team how it will identify travel plans early enough to arrange an appropriate alternative if a remote visit cannot proceed. Make the instructions understandable to the people booking appointments. Before adding another state to your remote schedule, resolve both the permission to practice and the local support arrangements your clinical work may require.
Track the DEA telemedicine prescribing date
DEA’s December 31, 2025 announcement extends the specified telemedicine prescribing flexibilities through December 31, 20262. Under those conditions, DEA-registered practitioners may prescribe Schedule II–V controlled medications through audio-video encounters without a prior in-person evaluation, while complying with applicable federal and state requirements2. Check the conditions against the care you intend to provide. Keep the extension’s end date separate from the patient’s next routine follow-up.
The announcement’s audio-only permission is narrower and concerns specified Schedule III–V narcotic medications approved for opioid use disorder treatment2. Avoid treating an audio-only appointment as interchangeable with an audio-video encounter for every prescribing situation. Review the relevant rule with the practice’s policy lead when building a workflow. Make sure the appointment format supports the service being considered.
The cited extension establishes permission through the end of 2026 and does not settle what will govern 20272. Set a year-end review date and identify patients whose follow-up arrangements could depend on the next rule. Develop options within current requirements without predicting a further extension. Recheck DEA’s published guidance before relying on temporary flexibility for a later appointment.
Read Medicare’s dates separately
CMS’s FAQ, internally dated October 8, 2026, says the broader Medicare telehealth location flexibilities continue through December 31, 20273. The same document explains that behavioral health’s removal of geographic and place-of-service restrictions is permanent3. Keep those policies distinct when reviewing your practice’s plan. Behavioral health cannot be understood simply by applying the general telehealth end date to every service.
The FAQ places the statutory prior in-person visit requirement for initial home mental health telehealth services after December 31, 2027, and describes separate treatment of patients who began receiving those services by that date3. It also describes subsequent in-person visit requirements and exceptions3. Have the practice review the applicable service and patient situation directly. Keep requirements for different practice settings visible during that review.
Use a brief dated policy sheet to record the rules your team is applying, including any unresolved question about a particular service. Give prescribing its own line and Medicare requirements their own line, with the relevant official pages attached. Assign someone to recheck them before the year changes and whenever an official update appears. Before opening the first 2027 remote clinic dates, review that sheet with the people responsible for scheduling and clinical policy.
