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Key Takeaways:
- Flexibility Dramatically Shifts: With no FY 2026 spending bill passed, the government shutdown triggered a rollback to pre-pandemic Medicare telehealth reimbursement policies, limiting patient locations and eligible providers and requiring in-person visits at certain intervals for mental health services; find a summary here.
- Temporary Claims Hold in Effect: CMS has instructed MACs to temporarily hold claims to avoid reprocessing if flexibilities are reinstated. Providers can still submit claims, but payments are paused.
With Congress unable to pass a FY 2026 spending bill, the government officially shut down on October 1, 2025. With it, the Medicare telehealth flexibilities have lapsed.
We are now back to the pre-pandemic restrictions on Medicare reimbursement for telehealth, which means:
- Patients must be located in certain health care facilities (with limited exceptions for certain end-stage renal disease, substance use disorder, and mental health disorder patients)
- Only certain providers are eligible to deliver telehealth services
- For mental health disorder patients, in-person visits are required within six months before the first telehealth visit and every 12 months thereafter
For more on what Medicare telehealth policy looks like post-expiration, read: Medicare Telehealth Flexibilities: Countdown to September 30, 2025.
In an update issued the morning of Oct. 1, the Centers for Medicare & Medicaid Services (CMS) directed all Medicare Administrative Contractors to implement temporary claims hold to avoid having to reprocess large volumes of claims should Congress reinstate the flexibilities.
Providers may continue submitting claims during this period, but payments will not be released until the hold is lifted. During the lapse, CMS reminds providers to consider whether issuing an Advance Beneficiary Notice of Noncoverage would be appropriate when delivering telehealth services that may no longer be covered by Medicare.
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