A lot of what was debated in 2026 actually takes effect in 2027, and most of it lands in the first few months of the year. When you line the changes up, they point in the same direction: regulators want to see that a licensed clinician is making the clinical decision, and they are building new ways to check. California is writing it into AI law, Medicare is putting platform relationships on every claim, DEA is moving toward registrations and recordkeeping for telehealth prescribing, and state boards are telling prescribers that paperwork doesn''t replace judgment.
Below is what''s coming in date order, who each change actually affects, and how we''d think about it.
January 1: DEA telemedicine prescribing flexibilities end
The current flexibilities that let practitioners prescribe controlled substances by telemedicine without an in-person evaluation expire December 31, 2026, which makes January 1 the first day without them unless DEA acts. A September update suggested DEA may be close to finalizing its special registration rule. The January 2025 proposal included separate registrations for clinicians prescribing Schedule III through V substances, for certain specialists prescribing Schedule II through V, and for platforms that dispense controlled substances, plus a state telemedicine registration for each state where patients are treated.
Who it affects: ketamine programs, testosterone and hormone programs, ADHD and behavioral health, and weight loss programs that prescribe controlled medications.
Our take: even the good outcome here means more registrations and more recordkeeping, not less. The companies that will handle it easily are the ones that already track prescribing by state and keep clean records, and the ones that will struggle are those that never had to show their work. Plan for two scenarios now, one where another extension or a final rule comes through and one where you need an in-person pathway on January 1.
January 1: California''s healthcare AI laws
AB 1979 requires health facilities, clinics, and physician offices to make sure a licensed provider exercises independent judgment whenever AI informs care, and treats AI performing licensed clinical functions on its own as unprofessional conduct. It also brings businesses offering consumer health chatbots under California''s medical privacy law. SB 503 requires developers and deployers of clinical decision support tools to identify and reduce biased impacts, with developers handing over documentation on training data, testing, and monitoring.
Who it affects: any practice or telehealth company treating California patients that uses AI for intake, triage, treatment recommendations, or patient messaging, and any consumer health app with a chat feature.
Our take: this is the corporate practice of medicine doctrine applied to software. The chatbot provision is the sleeper, because a lot of wellness apps have assumed health privacy rules didn''t apply to them, and in California that assumption ends on January 1.
January 1: New Medicare telehealth modifiers
Medicare telehealth claims now need the BB modifier when the billing clinician contracts with, or has a payment arrangement with, the company that owns the telehealth platform used for the visit, and the BC modifier for telehealth services billed incident to a physician or practitioner.
Who it affects: PC/MSO and platform models billing Medicare, and practices using incident-to billing for telehealth.
Our take: the modifiers don''t change what you can bill, but they make the relationship between clinicians and platforms visible on every single claim. That is a data set that didn''t exist before, and data sets like that tend to get used. Make sure your billing setup and your platform contracts describe the same arrangement.
January 1: Maine''s transaction approval law
Maine''s Health Care Consolidation Oversight Act requires 180 days of notice to, and approval from, the state before a private equity company, hedge fund, or MSO takes majority ownership or operational control of a health care entity. It joins California, which brought MSO/PC arrangements into its transaction notice law this year, and Rhode Island, which now requires notice for deals involving significant equity investors in a practice or MSO.
Who it affects: companies raising institutional money, MSOs acquiring or affiliating with practices, and anyone planning an exit.
Our take: for most founders this won''t come up until a raise or a sale, but that is exactly when it hurts to discover it. Build these timelines into the plan early, and keep your PC/MSO documents clean, because a buyer''s diligence will look at them either way.
February: FDA reviews five more peptides
FDA''s compounding advisory committee is scheduled to take up five more peptides in February, including GHK-Cu and Melanotan II. FDA still has to act on July''s vote in favor of six peptides, and an administration proposal for temporary access is drawing pushback from FDA''s own staff.
Who it affects: longevity, wellness, and med spa programs, and their prescribers.
Our take: expect 2027 to bring more process than access. FDA has to write the policy and build the monitoring before anything changes on the ground, and in the meantime state boards are filling the gap. Alabama, Mississippi, and South Carolina have already told prescribers not to use research-grade peptides, and we''d expect more states to follow with the same language.
July 1: California SB 947
SB 947 requires human review of automated employment decisions, so software output alone can''t justify disciplining or firing a worker.
Who it affects: healthcare employers using productivity scoring, scheduling, or performance tools on clinical and support staff.
Our take: this is a smaller item for most of our clients, but it is worth checking any HR or workforce tool that scores staff before the summer.
All year: CPOM and private equity pressure
The federal Stop Corporate Takeovers of Physicians Act would require physician owners to be present in the state and substantially engaged in delivering care, which would upend most multi-state telehealth structures. We don''t expect it to pass, but states keep moving in the same direction on their own, and Oregon''s CPOM law will reach existing arrangements by January 1, 2029.
Who it affects: multi-state telehealth companies and anyone with a friendly PC structure.
Our take: if your physicians actually review protocols, meet the clinicians they oversee, and own clinical decisions, the clinical-control pieces of these laws shouldn''t worry you much. The structures at risk are the ones where the physician owner exists on paper and nowhere else.
December 31: Medicare telehealth flexibilities end
Medicare''s current telehealth flexibilities, including home as an originating site, no geographic limits, and broader audio-only coverage, run through December 31, 2027. Starting in 2028, without another extension, patients will generally need to be in a rural area and a medical facility to receive Medicare telehealth, with behavioral health as the main exception, and physical therapists, occupational therapists, speech-language pathologists, and audiologists lose the ability to bill telehealth.
Who it affects: any practice with Medicare patients seen by telehealth.
Our take: extensions have historically come at the last minute, sometimes after a lapse. If Medicare telehealth is a meaningful share of your revenue, don''t build 2028 around the assumption that it will be extended again.
What to do before the year turns
- Decide your plan for controlled substance prescribing on January 1.
- Map where AI touches care in any program serving California patients, and document where a clinician reviews and can override it.
- Align your Medicare billing setup and platform contracts with the new modifiers.
- Put state transaction timelines into any 2027 fundraising or exit planning.
- Remove research-grade peptides from your formulary and confirm every pharmacy is licensed in the states you serve.
How Camino helps
Camino helps telehealth companies and practices get ready for changes like these before they take effect, from clinical oversight policies and vendor contracts to multi-state structures and the operational systems that keep a program running when the rules shift. If you want to walk through which of these apply to your program, reach out and we''ll walk you through it.
Related reading
- California''s New AI in Healthcare Laws
- State Medical Boards Are Putting Peptide Prescribers on Notice
- The Stop Corporate Takeovers of Physicians Act
References
- McDermott: DEA appears close to finalizing telemedicine special registration
- Gordon Rees: HHS and DEA extend telemedicine flexibilities through 2026
- Holland & Knight: Keeping Humans in the Loop
- CMS Telehealth FAQ, updated October 2026
- Becker''s: Private equity under the microscope
- Kirkland: California AB 1415
- Orrick: FDA Peptide Compounding Vote
- Sheppard Mullin: Stop Corporate Takeovers of Physicians Act of 2026
- Fuse Health: Corporate Practice of Medicine 50-State Guide
- Baker Donelson: Medicare telehealth waivers extended
This post is for general information only and is not legal advice. For guidance on your specific situation, talk with qualified healthcare counsel.