On October 1, the federal government entered a partial shutdown following Congress’s failure to advance critical funding legislation. In addition to halting many government operations and slowing down payment, Congress did not extend the temporary waivers that allow Medicare patients to continue accessing telehealth services from any location in the country.
Medicare Payments Continue with Temporary 10-Day Hold
According to the Centers for Medicare and Medicaid Services (CMS), Medicare claims processing has been temporarily adjusted in response to the shutdown, but the impact on physicians should be limited. Medicare Administrative Contractors (MACs) were instructed to implement a 10-business-day claims hold. However, because Medicare already operates under a 14-day payment floor for electronic claims, the hold is expected to have minimal effect on physician reimbursements. Physicians may continue to submit claims during this period, but payment will not be released until the hold is lifted. For the latest information, physicians should monitor their MAC’s website and this CMS webpage.
Medicaid Funding
CMS has sufficient funding for Medicaid to fund the first quarter of FY 2026. The agency is also maintaining the staff necessary to make payments to eligible states for the Children's Health Insurance Program (“CHIP”).
Telehealth Waivers Not Extended, Thereby Reinstating Pre-Covid Restrictions
The lapse of these waivers creates a serious disruption in care for patients who depend on telehealth, particularly individuals with disabilities, chronic illnesses and mobility limitations. For these populations, telehealth is not a convenience but a lifeline, ensuring timely, equitable access to necessary medical services. Safeguarding telehealth access remains a key advocacy priority for your Academy, and the current shutdown underscores the urgent need for congressional action.
With the expiration of telehealth flexibilities, Medicare has reverted to pre-pandemic requirements that restrict access. Patients are again subject to originating site requirements, which generally prevent telehealth from being delivered at home except in certain limited cases. Geographic limits also apply, with coverage confined to beneficiaries in designated rural areas. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits (e.g., face-to-face visits to support the ordering of certain durable medical equipment must meet Medicare telehealth requirements if they are furnished via telehealth). And while CMS has authorized the continuing use of audio-only telehealth, it can only be used when patients receive telehealth services from their homes and other criteria are met, thereby significantly limiting its availability. Physicians in certain Medicare Shared Savings Program accountable care organizations (ACOs) may continue to provide and be reimbursed for telehealth services, but other pandemic-era programs, including the Acute Hospital Care at Home initiative, have lapsed. Physician practices considering performing telehealth services may want to evaluate providing an Advanced Beneficiary Notice of Noncoverage (ABN).
Fighting for You
In spite of this setback, your Academy remains committed to pursuing fair reimbursement for physician-led care, particularly in light of threats to annual decreases to Medicare payment. At the same time, we are strongly advocating for Congress to reinstate broad access to telehealth services for your patients as soon as possible. We are monitoring for additional impacts including the potential impact of a long-term shutdown on research funding considering the list of NIH activities that will not continue.
AAPM&R is particularly concerned about the lack of annual inflationary adjustments to Medicare physician payment, which jeopardizes the sustainability of physician practices, and continues to prioritize fair reimbursement for physician-led care. Your Academy has also consistently advocated for Congress to pass permanent, or long-term, policies guaranteeing continued access to telehealth services. This advocacy, frequently in partnership with the Alliance for Connected Care and other stakeholders, has focused on providing certainty for Medicare providers and patients who rely on telehealth services.
Take Action Now!
We remain committed to advocating for fair, stable Medicare reimbursement and for continued access to telehealth services for all. We encourage all PM&R physicians to:
Contact Academy staff at healthpolicy@aapmr.org with any questions.