As the federal government shutdown continues, the Centers for Medicare & Medicaid Services (CMS) has released guidance regarding Medicare operations. The South Dakota Association of Healthcare Organizations (SDAHO) is sharing the following update to help members navigate potential impacts.
Temporary Claims Hold
When certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice—typically lasting up to 10 business days—ensures Medicare payments remain accurate and consistent with statutory requirements.
- Providers may continue to submit claims during this period.
- Payments will not be released until the hold is lifted.
- Due to the standard 14-day payment floor, the impact on providers should be minimal.
This approach helps avoid reprocessing large volumes of claims should Congress act after the expiration date.
Telehealth Services After October 1, 2025
Absent Congressional action, several statutory limitations for Medicare telehealth services will return on October 1, 2025, including:
- Restrictions on telehealth services for beneficiaries in their homes and outside of rural areas.
- Prohibitions on certain hospice recertifications requiring a face-to-face encounter via telehealth.
- Limitations on which practitioners may be paid for telehealth services.
These changes could affect provider workflows and even beneficiary eligibility for certain Medicare benefits. Practitioners who continue to provide non-covered telehealth services may wish to issue an Advance Beneficiary Notice of Noncoverage (ABN) and monitor Congressional activity closely. Some providers may choose to hold claims for telehealth services that would not be payable if Congress does not act.
For more details on telehealth coverage: CMS Telehealth Coverage
Special Considerations for ACOs
Clinicians participating in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) will continue to have more flexibility. Under the Bipartisan Budget Act of 2018, these providers may furnish and bill for covered telehealth services to eligible beneficiaries:
- Without geographic restrictions
- In the beneficiary’s home
There is no special application or approval process required. These flexibilities will remain in place throughout CY 2025, regardless of further Congressional action.
More information: CMS ACO Telehealth Fact Sheet
Ongoing MAC Operations
Despite the shutdown, Medicare Administrative Contractors will continue to perform all essential functions related to Medicare Fee-for-Service claims processing and payment.
SDAHO Takeaway for Members
- Claims: MACs will place a short hold on payments, but providers can still submit claims. Minimal payment delays are expected.
- Telehealth: Without Congressional action, many COVID-era telehealth flexibilities will end October 1, 2025. Review services impacted and consider ABNs if continuing non-covered care.
- ACOs: Shared Savings Program ACOs retain expanded telehealth flexibilities through 2025.
- Action: Monitor Congressional updates closely, and consider temporarily holding claims for telehealth services that may not be payable.
