Update from AMA at 10:02 am ET on 10-16-25:
Overnight, CMS issued updated guidance to Medicare Administrative Contractors (MACs) instructing them to limit the Medicare claims hold for services provided on or after October 1, 2025, that are impacted by the expired Medicare legislative payment provisions, including telehealth services other than for behavioral or mental health care, and services provided in locations with a work geographic practice cost index (GPCI) below the 1.0 floor. For all other services, Medicare claims will continue to be processed and paid in a timely manner. To date, no payments have been delayed as statute already requires all claims to be held for a minimum of 14 days.
The AMA continues to monitor the impact of the government shutdown, and any impacted physicians are encouraged to email AMA advocacy staff at [email protected] and include the subject heading “Medicare Payment Delay.”
Please note that CMS has also updated its telehealth FAQs.
Notification from AMA at 4:33 pm ET on 10-15-25:
As the federal government shutdown continues, the Centers for Medicare & Medicaid Services (CMS) has issued updated guidance instructing all Medicare Administrative Contractors to continue to temporarily hold claims with dates of service of October 1, 2025, including all claims paid under the Medicare Physician Fee Schedule. As a reminder, telehealth flexibilities have lapsed for care to all patients except those being treated for mental health or substance use disorders. Additionally, the 1.0 work geographic practice cost index (GPCI) floor also expired. More information from CMS is below. The AMA encourages physicians to continue to check their MAC websites and this CMS website for up-to-date information about Medicare claims processing.
Claims Hold Update
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.
CMS notes that the Bipartisan Budget Act of 2018 allows clinicians in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) to provide and receive payment for covered telehealth services to certain Medicare beneficiaries without geographic restriction and in the beneficiary’s home. There is no special application or approval process for applicable ACOs or their ACO participants or ACO providers/suppliers. Clinicians in applicable ACOs can furnish and receive payment for covered telehealth services under these special telehealth flexibilities. For more information: https://www.cms.gov/files/document/shared-savings-program-telehealth-fact-sheet.pdf (PDF).
Update from AMA on 9-26-25:
The AMA has long called for Congress to enact legislation that would: (1) permanently allow Medicare patients in every geographic area, not just patients in rural areas, to receive telehealth services by waiving the geographic restrictions in current law; and (2) permanently allow Medicare patients to receive telehealth services in their homes instead of having to go to a medical facility to receive telehealth from a distant site. To date, however, Congress has passed legislation that only temporarily waives these requirements. Most recently, in March 2025 Congress extended these telehealth flexibilities for a six-month period that ends Sept. 30, 2025.
Physicians who provide telehealth services to Medicare patients should be aware that if Congress is not able to pass legislation before Oct. 1, 2025, that extends government funding, then the current Medicare telehealth flexibilities will lapse. This means that telehealth services would be limited to rural areas as they were before the COVID public health emergency and that patients would not be able to receive telehealth services in their homes. In addition, the ability to provide audio-only services to Medicare patients would lapse, as would the Acute Hospital Care at Home program.
In past government shutdowns, whenever Congress passed legislation to reopen the government, it made the funding and policies retroactive to the effective date of the shutdown. Physician practices may want to consider adjusting their patient schedules for telehealth services, however, as neither the likelihood nor the duration of a shutdown are known.