As the federal government shutdown continues, the Centers for Medicare & Medicaid Services (CMS) has issued updated guidance to Medicare Administrative Contractors (MACs) regarding payment processing and telehealth coverage.
Editor’s Note (October 22, 2025)
Since this post was originally published during the federal government shutdown, the Centers for Medicare & Medicaid Services (CMS) has released new guidance clarifying how Medicare Administrative Contractors (MACs) should handle claims beginning October 1, 2025. The update includes key instructions related to telehealth, behavioral health, and ACO claims, as well as the expiration of certain COVID-era flexibilities. The details below summarize what’s changed and what clinicians need to know moving forward.
Update: CMS Guidance Effective October 1, 2025
(Posted October 22, 2025)
The Centers for Medicare & Medicaid Services (CMS) has issued new instructions to Medicare Administrative Contractors (MACs) regarding claims processing for services affected by expired legislative payment provisions under the Full-Year Continuing Appropriations and Extensions Act, 2025 (Pub. L. 119-4).
Key updates include:
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Claims hold lifted: MACs have been instructed to resume processing for claims with dates of service (DOS) October 1, 2025, and later for:
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Services paid under the Medicare Physician Fee Schedule
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Ground ambulance transport claims
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Federally Qualified Health Center (FQHC) claims
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Telehealth claims confirmed to be for behavioral and mental health services
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Claims still on hold: MACs will continue to temporarily hold claims for:
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Telehealth services that cannot be confirmed as behavioral or mental health
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Acute Hospital Care at Home services
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Telehealth coverage changes: With the expiration of several COVID-era flexibilities, many statutory restrictions on Medicare telehealth services have returned.
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Certain telehealth visits are no longer payable when provided to beneficiaries at home or outside rural areas.
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Hospice recertifications again require an in-person (face-to-face) encounter.
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Providers offering non-covered services should consider issuing an Advance Beneficiary Notice of Noncoverage (ABN).
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CMS ABN Forms and Instructions: cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn
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ACO telehealth flexibility remains:
Clinicians in Medicare Shared Savings Program Accountable Care Organizations (ACOs) retain special telehealth flexibilities under the Bipartisan Budget Act of 2018, allowing:-
Telehealth services without geographic restrictions
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Coverage for services delivered in patients’ homes
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Continued payment for behavioral and mental health telehealth claims
However, some telehealth claims in ACOs remain temporarily on hold pending further CMS confirmation.
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CMS Fact Sheet: Shared Savings Program Telehealth Flexibility (PDF)
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Next steps for clinicians:
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Monitor any Congressional action on telehealth legislation that could restore or extend these flexibilities.
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Consider holding claims for non-behavioral telehealth services until additional CMS clarification is issued.
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Review the full CMS guidance on telehealth coverage: cms.gov/medicare/coverage/telehealth
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CMS Confirms Payments Continue: Most Medicare claims are being processed and paid on schedule despite the federal shutdown.
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Limited Hold Applies: Only claims affected by expired legislative provisions are temporarily held.
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Telehealth Flexibilities Reduced: As of October 1, 2025, most pandemic-era telehealth waivers have expired, except those for mental health and substance use disorder care.
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Stay Informed: Monitor your MAC’s website, CMS payment updates, and PAMED’s Government Shutdown Resource Page for the latest guidance.
Medicare Claims Processing
On October 15, CMS announced that most Medicare claims will continue to be processed and paid on schedule, despite the shutdown. Only claims tied to expired Medicare legislative provisions—including certain telehealth services and services in areas affected by the expired 1.0 work geographic practice cost index (GPCI) floor—are temporarily impacted.
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Physicians may continue to submit all claims as usual.
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CMS emphasized that, to date, no payments have been delayed beyond the standard 14-day statutory hold period required for all claims.
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Claims unrelated to the expired provisions will be processed and paid in a timely manner.
Telehealth Flexibilities
As of October 1, 2025, many COVID-19-era telehealth flexibilities expired for services other than those related to mental health and substance use disorders.
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Most telehealth services provided to beneficiaries in their homes or outside of rural areas are no longer reimbursable under Medicare.
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Physicians providing non-covered telehealth services should consider issuing an Advance Beneficiary Notice of Noncoverage (ABN) to patients.
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Clinicians participating in Accountable Care Organizations (ACOs) under the Medicare Shared Savings Program may continue to bill for covered telehealth services without geographic restrictions.
Next Steps for Physicians
CMS and the American Medical Association (AMA) continue to monitor the situation closely. Physicians are encouraged to:
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Check the CMS Medicare Claims Processing page and their MAC websites for updates.
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Review the CMS Telehealth Coverage page and updated Telehealth FAQs.
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Report any payment delays to AMA Advocacy at [email protected] with the subject line “Medicare Payment Delay.”
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For the latest information, physicians should monitor their MAC’s website and this CMS webpage.
ACMS will continue to share updates as new information becomes available.
PAMED has also created a Government Shutdown Resource Page (member login required).
Last updated: October 22, 2025 9:00 AM EST