Medicare Administrative Contractors Status During the Shutdown 

In anticipation of possible Congressional action, CMS has instructed all Medicare Administrative Contractors (MACs) to continue to temporarily hold claims with dates of service of October 1, 2025, and later for services impacted by the expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025. This includes all claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center claims. Providers may continue to submit these claims, 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 took effect again for services that are not behavioral 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 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 (ABN). Further information on use of the ABN, including ABN forms and form instructions: https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn. 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. For further information: https://www.cms.gov/medicare/coverage/telehealth. 

Key Takeaways

This hold includes all claims paid under the Medicare Physician Fee Schedule (MPFS), ground ambulance transport claims, and all Federally Qualified Health Center claims. Physicians may continue to submit these claims, but payment will not be released for the held claims until the hold is lifted.

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.