The shutdown that began on October 1 is now in its third week, and the questions from practice owners have changed. In the first week it was "are we getting paid at all". Now it is "how long can we carry the held claims, and what happens to payroll if this runs to Thanksgiving". Those are better questions, because they can be answered with a spreadsheet.
Here is the situation as of today. On October 1, CMS told the MACs to hold claims affected by the Medicare provisions that expired on September 30, for what it described as typically up to ten business days. Those ten days ran out on October 15, and instead of lifting the hold CMS told the MACs to keep it in place for claims with dates of service on or after October 1 that are paid under the physician fee schedule, plus ground ambulance and FQHC claims. No end date was given. Because Medicare cannot pay an electronic claim before the 14-day payment floor, the first October visits would have paid around October 15 in a normal month. That is why the gap is only now showing up in remittances, and why the calls started this week.
Key takeaways
- Every Medicare physician fee schedule claim with a date of service of October 1 or later is in the hold, not just telehealth. Claims for September and earlier dates are paying normally, and so are commercial, Medicaid and Medicare Advantage claims.
- Most of the held money is delayed, not lost. The exception is non-behavioral telehealth furnished to patients at home, which is not payable under current law unless Congress acts retroactively.
- Build a payer-by-payer forecast that separates delayed from at-risk revenue. For most practices the delay is a few weeks of Medicare cash; the at-risk piece is small.
- Keep submitting everything, tag the October Medicare claims, work the commercial receivables you already have, and talk to the bank before you need it.
What CMS has said since October 1
The October 1 MLN Connects newsletter explained the hold and reminded practices that behavioral and mental health telehealth remains payable from the patient's home under permanent law, while the originating site and geographic limits are back for everything else. The October 15 newsletter repeated the telehealth position, confirmed that MACs will continue to hold physician fee schedule, ground ambulance and FQHC claims with October dates of service, suggested an Advance Beneficiary Notice for telehealth services that are no longer payable, and noted that clinicians in applicable Medicare Shared Savings Program ACOs can keep furnishing telehealth without the geographic restriction under their own statutory benefit.
What CMS has not said is when the hold ends. Our reading is that CMS is waiting for Congress, because a retroactive fix (which is what happened after every previous telehealth cliff) would otherwise force the MACs to reprocess hundreds of thousands of claims. Practices should plan for the hold to last as long as the shutdown does, and to lift a week or two after it ends.
Build the forecast in an afternoon
Take the last three full months of payments by payer and by month. That is your baseline. Then split the Medicare Part B line and adjust it:
| Line | Status today | Adjustment | How to size it |
|---|---|---|---|
| Medicare Part B, dates of service before October 1 | Paying normally | None | Baseline |
| Medicare Part B, October dates of service, in-person | Held | Move from October and November into the month you expect the hold to lift; do not remove | Average daily Medicare charges times allowed percentage times days in the hold |
| Medicare behavioral telehealth from home | Held but payable | Delay, same as in-person | Count of visits times average allowed amount |
| Medicare non-behavioral telehealth from home | Held and not payable under current law | Move to zero unless Congress acts retroactively | Count of Medicare video visits from home times average allowed amount |
| Commercial, Medicaid, Medicare Advantage | Paying normally | No change from the shutdown itself | Baseline, adjusted for your normal seasonality |
A three-physician internal medicine practice collecting $350,000 a month, with Medicare Part B at 35 percent of that, has about $122,000 of Medicare cash in a normal month. If the hold runs to mid-November, most of October's Medicare money arrives four to six weeks late. That is a timing problem: the practice needs to cover roughly one month of Medicare receipts from reserves or a line of credit, then gets it back in a lump. The same practice does 180 Medicare video visits a month with patients at home at an average allowed amount of about $105, or about $19,000. That piece is the real risk, and it is a little over five percent of monthly collections. Unpleasant, not fatal. A telehealth-heavy practice where 40 percent of Medicare visits are video from home has a different problem and needs the seven moves below sooner.
One more line to check: the 1.0 work GPCI floor also expired on September 30. If your locality was protected by the floor, the MACs will price October claims slightly lower when the hold lifts, unless Congress restores the floor retroactively. For most localities the effect is well under one percent of Medicare payments, but it belongs in the forecast as a note.
Seven moves, in the order we recommend them
- Convert Medicare video visits to in-person wherever the patient can travel. This is the only move that changes the at-risk number, and it is the single biggest lever. Offer early morning and late afternoon slots for the patients who chose video because of work.
- Keep submitting the held claims and tag them. Do not sit on them. When the hold lifts, the claims already in the MAC's queue are the first to pay. Tag the October Medicare claims in the practice management system so you can reconcile them later, and tag the telehealth ones separately.
- Work the accounts receivable you already have. Every practice has claims over 60 days with commercial payers that nobody has called about. This is the month to call. Pull the no-response report (claims with no 277 or 835 after 30 days) and work it top down by dollar value. A practice with $40,000 in stale commercial receivables can often turn a quarter of it into cash in three weeks of calls.
- Send patient statements on time. Patient balances are the most controllable receivable in the practice. If statements go out monthly in one batch, move to a weekly cycle by alphabet or by account age, and turn on text or email reminders if the system has them.
- Talk to the bank before you need to. A line of credit takes weeks to open and days to draw. If you do not have one, start the conversation now, with your forecast in hand. Lenders respond better to a practice that shows a plan than to one that calls in a panic. If you have one, confirm the available balance and the draw process today.
- Delay discretionary spending, not payroll or payer follow-up. Equipment, marketing and the office refresh can wait. Cutting billing staff hours during a cash squeeze is how a practice turns a two-month problem into a six-month one, because the claims that lift the squeeze are the ones those staff would have worked.
- Decide the patient-pay question once. If you will furnish Medicare video visits from home under an Advance Beneficiary Notice, write the script, train the front desk and set the price. If you will not, say so and stop debating it at every visit.
Things that are not affected, so stop worrying about them
Federal employees who are furloughed still have their Federal Employees Health Benefits coverage; premiums accrue and coverage continues, so their claims pay. TRICARE, Medicaid and the state marketplaces are operating. Marketplace open enrollment for 2026 is still scheduled to start November 1. Medicare provider enrollment through PECOS continues, though we have seen slower responses on some applications. The Medicare Physician Fee Schedule final rule for 2026 is normally published around November 1, and a delay there would not change January rates in a way you can plan for now.
Medicare Advantage plans are paying on their normal cycles, and CMS has given them flexibility to keep covering telehealth during the shutdown. Most of the plans we bill have said they will. Confirm yours in writing rather than assuming.
What we think practices are getting wrong
Three things. First, some practices stopped furnishing all Medicare telehealth, including behavioral health from home, which is still payable. That is leaving money and patient access on the table for no reason; those claims are delayed like everything else, not lost. Second, some practices have decided to bill patients directly for every video visit without an ABN, on the theory that Medicare does not cover it anyway. Billing a Medicare beneficiary for a covered-when-furnished-properly service without the proper notice is a compliance problem, and if the flexibilities come back retroactively the practice will owe refunds. Do it properly or do not do it. Third, some owners are treating the whole Medicare line as lost and making staffing decisions on that basis. It is not lost. Read the table again.
Questions we hear
Will the held claims hit timely filing?
Medicare allows twelve months from the date of service, so October claims are safe until October 2026. Submit them now anyway; a claim in the hold is better than a claim on your desk, and the MACs adjudicate in the order received once the hold lifts.
Should we stop scheduling Medicare video visits for November?
Schedule them as in-person by default and offer video only for behavioral health or for patients who genuinely cannot travel and accept the ABN. If the rules change you can convert back in a day. Schedulers need one sentence: "Medicare changed its video visit rules on October 1, so we are booking you in the office for now."
Can our billing company do anything to speed up the hold?
No. The hold is at the MAC on CMS instruction. What a billing team can do is keep the tagged list clean, work the rest of the AR harder and make sure the moment the hold lifts, nothing is missing from the queue. That is what our billing team is doing this month, and it is what an RCM audit would tell you to do if you were doing it yourself.
What to do this week
- Build the five-line forecast above from the last three months of payments and put a date on when you expect the hold to lift.
- Tag every Medicare claim with an October date of service, with a separate tag for telehealth from home.
- Pull the commercial no-response and over-60-day reports and assign them by dollar value.
- Move patient statements to a weekly cycle.
- Call the bank with the forecast in hand, and write down the ABN decision so the front desk stops asking.
