Federal Shutdown: Key Information for Physicians

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Federal Shutdown: Key Information for Physicians

Today, October 1, 2025, the United States federal government shut down due to Congress’ inability to reach a consensus on a continuation spending plan. Although essential services will continue, delays in services and processing are expected. To help physicians and other team understand how the shutdown will impact the delivery of and payment for health care services and treatment, the Centers for Medicare & Medicaid Services (CMS) issued a Medicare Learning Network (MLN) Connects special edition that provides an update on Medicare operations for claims processing, telehealth, and the status of Medicare Administrative Contractors (MACs) during the government shutdown. 

According to the MLN special edition:

“When certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact on providers due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.

Absent Congressional action, beginning October 1, 2025, many of the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency will take effect again for services that are not behavioral and mental health services. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas and hospice recertifications that require a face-to-face encounter. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits. In the absence of Congressional action, practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage. Practitioners should monitor Congressional action and may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of Congressional action. Additionally, Medicare would not be able to pay some kinds of practitioners for telehealth services. For further information: https://www.cms.gov/medicare/coverage/telehealth."

This means that under Medicare, telehealth services are limited to rural areas as they were before the COVID public health emergency and that Medicare patients cannot receive telehealth services in their homes. Note, however, physicians in certain Medicare Shared Savings Program accountable care organizations (ACOs) can continue to provide and be paid for telehealth services. In addition, the ability to provide audio-only services to Medicare patients lapsed, as did the Acute Hospital Care at Home program. 

For the latest information, physicians should monitor their MAC’s website and this CMS webpage. You may also want to view the CMS contingency plan.

Early this morning, the State of Michigan passed a continuation bill that funds state operations for one-week to allow additional time for legislators to complete their budget work.