Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown 

In the absence of a federal budget bill or continuing resolution, the government shut down on 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. 

What are the changes? 

• Geographic limits: Telehealth services are restricted to those in designated rural areas, reversing the temporary expansion to all locations. 
• Location restrictions: Patients must now travel to an authorized medical facility, such as an office or clinic, to receive most telehealth services. Beneficiaries can no longer receive routine care via telehealth from their homes, though some specific services remain exempt. 
• Audio-only services: Coverage for audio-only (telephone) telehealth visits has lapsed, except for specific behavioral health services, which can still be conducted via two-way audio from a patient’s home. 
• Medicare general medicine telehealth services have reverted mainly to pre-COVID rules, including for home as an originating site and geographic waivers, expanded clinician eligibility, FQHC/RHCs as distant-site telehealth providers, audio-only allowances, and Hospital-at-Home waiver authority. 

Billing and claims during a shutdown 

While Medicare claims payments are not directly subject to the annual appropriations process, the shutdown has triggered a change in how claims for telehealth services are processed.  

• Temporary claims hold: CMS has instructed Medicare Administrative Contractors (MACs) to temporarily hold telehealth claims. This is to avoid having to reprocess a large number of claims if Congress retroactively extends the telehealth flexibilities once a funding bill is passed. 
• Possible billing impacts: If the shutdown is brief and Congress acts quickly, payment delays should be minimal. However, in a prolonged shutdown, payment delays could occur, and providers could face claim denials for services that no longer meet Medicare’s requirements. 
• Patient notices: Providers may offer patients an Advance Beneficiary Notice of Noncoverage (ABN) for now-uncovered telehealth services. This informs patients that they may be financially responsible for these services if Congress does not reinstate coverage.  

Experity will continue to monitor this topic for upcoming changes.