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Medicare Telehealth Flexibilities Extended Through 2027: Telehealth Gets a Two-Year Lifeline in Fiscal Year 2026 Spending Package

By Sukrti Thonse & John W. Kaveney on February 12, 2026
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Medicare telehealth received a critical, if temporary, reprieve with the enactment of new legislation that extends key pandemic-era telehealth flexibilities that were set to expire on January 31, 2026, to December 31, 2027. In this Client Alert from our healthcare team, learn more about the impacts of the new law and why providers, health systems, and digital health companies should use this window to assess compliance, billing, infrastructure, and long-term strategy in anticipation of potential policy shifts after 2027.  

Photo of Sukrti Thonse Sukrti Thonse

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and…

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and private equity sponsors on compliant corporate structuring, operational strategy, and growth initiatives. She provides guidance to healthcare start-ups, physician practices, and hospital systems on day-to-day operational, regulatory, and strategic matters, and assists clients in navigating complex and novel regulatory issues in highly regulated, multi-jurisdictional environments, including multi-state regulatory compliance and expansion.

In her corporate practice, Sukrti assists with the formation and capitalization of business structures and prepares key documents for fundraising, financing, and investor negotiations. She provides support on M&A transactions and in the structuring and implementation of Management Services Organization-Professional Corporation (MSO–PC) and Friendly PC models, ensuring compliance with Corporate Practice of Medicine (CPOM) doctrines, fee-splitting laws, and state ownership restrictions. Her work frequently involves advising on management services arrangements, equity structuring, rollover investments, and platform acquisitions involving physician-owned entities and private equity-backed healthcare companies.

Sukrti also has significant experience in physician and provider contracting, including drafting and negotiating employment agreements, independent contractor arrangements, professional services agreements, and compensation models (including wRVU-based structures), with careful attention to regulatory compliance and commercial reasonableness. Her practice includes coordinating regulatory due diligence and assisting with disclosure requirements, including for entities operating in FDA-regulated sectors.  She regularly structures and negotiates compensation arrangements with physicians in connection with employment and exclusive contracting arrangements, medical directorships, physician recruitment initiatives, office and equipment leases, and other key operational documents that support healthcare delivery and scalable platform growth.

She has developed particular strength in healthcare privacy and HIPAA compliance and works closely with firm partners to advise on federal and state regulatory frameworks. Sukrti regularly conducts multi-state regulatory analyses, including 50-state surveys addressing licensure, supervision, telehealth, reimbursement, and scope of practice considerations, enabling clients to expand across jurisdictions while mitigating regulatory risk.

Results may vary depending on your particular facts and legal circumstances.

Contact information:

sthonse@greenbaumlaw.com | 732.476.2480 | vCard

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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Photo of John W. Kaveney John W. Kaveney

Partner, Healthcare and Litigation

John provides legal guidance to healthcare sector clients on a broad variety of topics, including Medicare/Medicaid reimbursement issues, corporate compliance, data privacy and cybersecurity concerns, healthcare provider licensure and medical staffing concerns, involuntary commitment laws, and general healthcare regulatory…

Partner, Healthcare and Litigation

John provides legal guidance to healthcare sector clients on a broad variety of topics, including Medicare/Medicaid reimbursement issues, corporate compliance, data privacy and cybersecurity concerns, healthcare provider licensure and medical staffing concerns, involuntary commitment laws, and general healthcare regulatory support. He represents a diverse roster of healthcare entities, including for-profit and nonprofit hospitals and health systems, academic medical centers, individual physicians and physician groups, ambulatory surgery centers, ancillary service providers, medical billing companies, skilled nursing and rehabilitation facilities, behavioral health centers and pharmacies.

John advises on Medicaid reimbursement matters before the New Jersey Division of Medical Assistance and Health Services (DMAHS), which administers the state’s Medicaid programs, and handles Medicare reimbursement disputes, both in New Jersey and in numerous other states, before the federal Provider Reimbursement Review Board (PRRB).

In the area of corporate compliance, John supports clients on matters including the implementation of new, and the assessment and improvement of existing, compliance programs. He assists healthcare clients in navigating compliance audits, internal investigations, and governmental investigations related to compliance issues, including potential violations of the federal Stark Law, Anti-Kickback Statute (AKS), and Civil Monetary Penalties law (CMP). He further provides general guidance concerning compliance and regulatory matters under state and federal healthcare laws.

On issues related to information privacy and cybersecurity at the intersection of healthcare law, John assists providers with issues arising under the Health Insurance Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH). This includes the implementation and assessment of privacy and security policies and procedures to ensure the proper protection and utilization of protected health information (PHI) both by healthcare providers and the business associates with which they contract. In addition, he represents healthcare clients in investigating, reporting, and remediating information breaches and the liability such breaches create under various information privacy and security laws.

John also counsels healthcare providers with professional licensure issues and advises hospitals and health systems regarding their medical staff bylaws and corresponding policies and procedures, as well as assisting with internal investigations of medical staff members and the corresponding disciplinary process. He further provides legal guidance related to New Jersey’s involuntary commitment laws, and provides representation in civil litigation.

John serves as Editor-In-Chief of Healthcare Perspectives, Greenbaum’s blog covering issues of interest to the healthcare industry.

Results may vary depending on your particular facts and legal circumstances.

Contact information:

jkaveney@greenbaumlaw.com | 973.577.1796 | vCard | LinkedIn

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Healthcare Perspectives
  • Organization:
    Greenbaum, Rowe, Smith & Davis LLP
  • Article: View Original Source

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