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The Centers for Medicare & Medicaid Services (CMS) has released its CY 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule, and with it comes a major shift in how supervision and telehealth services are regulated and reimbursed.
The proposal introduces long-awaited clarity around virtual direct supervision, builds on CMS’s evolving telehealth policies, and signals a permanent departure from some of the pandemic-era limitations. These changes could significantly impact radiology, diagnostic testing, outpatient imaging, and incident-to services across the country, especially in rural and underserved areas.
In this article, we’ll break down the proposed changes, what they mean for physician practices, and how healthcare organizations can prepare.
1. CMS Proposes Permanent Virtual Direct Supervision for Key Services
CMS is proposing to permanently adopt a definition of "direct supervision" that allows for real-time audio/visual telecommunications (excluding audio-only) for certain services. This rule would apply across:
- Incident-to services under § 410.26
- Diagnostic tests under § 410.32
- Pulmonary rehabilitation under § 410.47
- Cardiac and intensive cardiac rehabilitation under § 410.49
This change would codify the flexibility introduced during the COVID-19 Public Health Emergency and could transform how supervising physicians manage multi-site service delivery, especially for services involving contrast-enhanced imaging, diagnostic testing, and clinical staff workflows.
Excluded for Now: Services with a global surgical indicator of 010 or 090 would not be eligible for virtual direct supervision. CMS is also seeking feedback on whether 000 global indicator procedures should be excluded due to patient safety concerns.
2. Streamlined Telehealth Services Review Process
CMS is also proposing to simplify the process for adding services to the Medicare Telehealth Services List by:
- Removing the distinction between provisional and permanent services
- Focusing reviews solely on whether the service can be safely delivered using interactive two-way audio-video telecommunications
This could accelerate access to telehealth-reimbursable services and make it easier for emerging clinical services, including those in imaging, oncology, or chronic care management, to be adopted under Medicare.
3. Removal of Frequency Limitations for Inpatient and Critical Care Telehealth
In another move that aligns with long-standing provider feedback, CMS is proposing to permanently remove telehealth frequency limitations for:
- Subsequent inpatient visits
- Subsequent nursing facility visits
- Critical care consultations
This would give physicians and supervising practitioners more discretion to determine the appropriate cadence of virtual check-ins based on patient needs, not outdated frequency caps.
4. Implications for Radiology and Outpatient Imaging
For radiology groups, outpatient imaging centers, and hospital-based practices, these changes carry important implications:
- Virtual contrast supervision workflows, which rely on direct supervision for technologists administering contrast, could be permanently validated at the federal level under § 410.32
- Incident-to protocols that require on-site supervision (e.g., nurse-administered injections, diagnostic studies) could now permanently be supported via HIPAA-compliant video
- Scheduling flexibility would improve, as supervising physicians could permanently oversee services remotely without delaying care due to location constraints
If finalized, these rules would also provide a permanent regulatory foundation for platforms like Tether Supervision, which enable secure, compliant virtual oversight across multiple care sites.
5. Key Takeaways and Next Steps
Healthcare organizations should begin preparing for virtual supervision now if they haven't yet:
- Audit your supervision policies to identify services that could transition to virtual oversight
- Train staff on what virtual direct supervision entails, and ensure AV systems meet CMS requirements
- Identify your needs and consider whether choosing a virtual supervision provider is right for your organization
- Comment on the rule: CMS is actively soliciting feedback, particularly around services with a 000 global indicator. This is an opportunity to shape federal policy to reflect operational realities
Conclusion
The CY 2026 Medicare Physician Fee Schedule Proposed Rule marks a major milestone in the evolution of virtual supervision and telehealth policy. By aligning supervision rules with technology-driven workflows and expanding telehealth access, CMS is moving toward a model that reflects the realities of modern care delivery.
Whether you’re a radiology group, an outpatient imaging center, or a hospital network managing contrast-enhanced exams and incident-to services, these proposals offer new flexibility -- and a chance to rethink how your team delivers safe, scalable, and compliant care.
You can read the full 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule summary here.
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