At 12:01 a.m. on Wednesday, October 1, 2025, federal appropriations lapsed and the government shut down. For most practices the first visible effect was not a furloughed federal employee. It was the Medicare telehealth waivers, which had been extended through September 30, 2025 by the March continuing resolution and were not extended again. As of yesterday, Medicare telehealth is back under the pre-pandemic statute, and the MACs have been told to hold a much wider set of claims than most people expected.
A practice manager we spoke with on Wednesday afternoon had 41 Medicare telehealth visits on the schedule for the rest of the week, most of them established patients checking in from home. Her question was the one everyone is asking: do we see them, do we bill them, and who pays if Congress does nothing. This article is our attempt to answer that with what CMS has actually said so far, which is less than we would like but more than nothing.
Key takeaways
- The Medicare telehealth flexibilities expired at midnight on September 30, 2025. Video visits with non-behavioral patients at home are not payable by Medicare for dates of service from October 1 until Congress acts.
- CMS has told every MAC to hold claims affected by the expired provisions, typically for up to ten business days. That hold covers physician fee schedule claims generally, not only telehealth, because the 1.0 work GPCI floor lapsed at the same time.
- Behavioral and mental health telehealth from the patient's home remains payable under permanent law, but the in-person visit requirement is back in force.
- Convert what you can to in-person, tag every October Medicare telehealth claim, and do not build a strategy around billing patients for routine video follow-ups.
What happened and when
The telehealth flexibilities were never permanent. Congress extended them in the Consolidated Appropriations Act, 2023 through December 31, 2024, then in the American Relief Act in December 2024 through March 31, 2025, then in the Full-Year Continuing Appropriations and Extensions Act signed in March 2025 through September 30, 2025. A fiscal year 2026 funding bill would have carried them again. That bill did not pass, so on October 1 the waivers expired and the government closed at the same moment.
The same March law carried a handful of other Medicare extenders with the same September 30 end date: the 1.0 floor on the work geographic practice cost index, the ground ambulance add-on payments, the Acute Hospital Care at Home waiver, and the ability to use telehealth for the hospice face-to-face recertification. All of them lapsed together. The work GPCI floor is the one nobody talks about and the one that reaches every practice, because it changes the price of every physician fee schedule service in the localities that had been protected by it.
In its October 1 MLN Connects newsletter, CMS explained its standard practice when extenders expire: it directs all MACs to implement a temporary claims hold, typically up to ten business days, so that payments match the law as it stands and so that a large volume of claims does not have to be reprocessed if Congress acts retroactively. CMS added that the hold should have minimal impact because of the 14-day payment floor that already applies to electronic claims. Practices can keep submitting claims. Payment on affected claims will not be released until the hold is lifted.
What reverted on October 1
| Flexibility | Status through September 30 | Status from October 1 |
|---|---|---|
| Patient location (originating site) | Any site, including the patient's home | Must be an eligible facility in a rural area for non-behavioral services |
| Geographic restriction | Waived | Applies again for non-behavioral services |
| Behavioral and mental health from home | Allowed | Still allowed (made permanent in 2020), but the in-person visit requirement now applies |
| Audio-only visits | Allowed for many services | Limited to behavioral and mental health in most cases |
| Distant-site practitioners | Included PTs, OTs, SLPs and audiologists | Back to the statutory list of physicians and certain practitioners |
| FQHCs and RHCs as distant sites | Allowed | Not allowed for most services |
| Hospice face-to-face recertification by telehealth | Allowed | Must be in person |
| Acute Hospital Care at Home waiver | Active | Lapsed |
| Work GPCI floor of 1.0 | In effect | Lapsed; affected localities price slightly lower |
The line that catches most office practices is the first one. An established patient with hypertension who joins a video visit from her kitchen in a suburban county is, under current law, not at an eligible originating site. That claim is not payable by Medicare today, regardless of how well the visit is documented or which place of service code is on it.
Who is affected and who is not
Traditional Medicare Part B is affected. Behavioral health visits furnished to patients at home remain payable, with the caveat that the in-person visit rule (a face-to-face visit within six months before the first telehealth mental health service and at least every twelve months after) is now in force because the delay of that rule lapsed as well. Clinicians in Medicare Shared Savings Program ACOs in the applicable tracks keep a separate, permanent statutory telehealth benefit that ignores the geographic and home restrictions; if your practice is in one, ask the ACO today whether it applies to you.
CMS also said it is giving Medicare Advantage plans flexibility to continue covering telehealth during the shutdown, so MA claims depend on the plan. Commercial and Medicaid telehealth policies are governed by state law and payer contracts and did not change on October 1.
Practices that bill only commercial payers can skip the telehealth sections of this article, though not the cash flow paragraph below. Practices with a meaningful Medicare telehealth volume, especially primary care, endocrinology, nephrology and any group that built chronic disease follow-up around video visits, need a decision this week.
The four options for this week's Medicare video visits
- Convert to in-person. The safest option for anything that can wait a few days or that the patient can reach the office for. Most practices we work with are doing this for the visits that were scheduled as video for convenience rather than necessity, and opening early and late slots for the patients who chose video because of work.
- Furnish the visit and submit the claim into the hold. If Congress restores the flexibilities retroactively to October 1, held claims should pay. If Congress does not, the claim is not payable and the practice cannot bill the patient without a valid ABN. This is a bet on Congress, and the practice carries the risk.
- Furnish the visit with an Advance Beneficiary Notice. CMS itself pointed to the ABN in its October 1 guidance. Because the service is statutorily not covered from the patient's home, a properly executed ABN lets the practice bill the patient if Medicare denies. This works only if the patient agrees before the visit and the notice is completed correctly, with the specific service and a good-faith cost estimate. Collecting from a Medicare patient for a routine video check-in is not a conversation most front desks want to have, and if Congress acts retroactively you will be refunding it.
- Reschedule behavioral health visits with the in-person rule in mind. Check whether the patient has had a face-to-face visit in the last six months (for new telehealth mental health patients) or twelve months (for established ones). If not, that visit is the one to book in the office.
Our opinion: convert what you can, hold what you cannot, and do not build a billing strategy around the ABN for routine follow-ups. The paperwork burden and the patient conversations cost more than the visits are worth, and history says Congress eventually acts.
What changes in the billing workflow today
Tag every Medicare telehealth claim with a date of service on or after October 1 so you can find them later. A simple claim note or a custom hold status in the practice management system works. If the flexibilities come back, you will want to confirm those claims paid. If they do not, you will need the list for write-offs or patient billing decisions. Keep POS 10 and modifier 95 conventions unchanged for now; CMS has not asked for anything different on the claim itself.
Then look past telehealth. Because the hold reaches physician fee schedule claims with dates of service from October 1, your Medicare remittances for October visits of every kind will pause, not just the video ones. September dates of service are unaffected and will keep paying on the normal cycle, which is why you will not see the gap until the second half of October. A practice that collects $120,000 a month from Medicare Part B should expect the October remittances to arrive late and in a lump rather than in the usual weekly rhythm. Tell the owner now, before the bank balance tells them.
Front desk scripts matter this week. Patients who booked video visits need to hear that Medicare rules changed on October 1, that the office is offering in-person slots, and that the practice will call when the rules change again. Blaming Congress is accurate but not useful; give patients a plan and a date you will check back.
Questions we hear
Should we stop submitting Medicare claims until the hold lifts?
No. Submit everything on the normal schedule. A claim sitting in the MAC's queue is adjudicated the day the hold lifts; a claim sitting on your desk adds your own delay to CMS's. The only thing you gain by holding claims yourself is the option to decide later whether to bill a video visit at all, and tagging gives you that without stopping the flow.
Our patient will pay cash for the video visit. Can we skip the ABN?
Not for a service that Medicare covers when furnished properly. Billing a Medicare beneficiary for a service without the required notice is a compliance problem regardless of what the patient says they are willing to do. If you want the option to collect from the patient, use the ABN, keep the signed copy, and expect to refund if Congress acts retroactively.
Does anything change for the visits we already did in September?
Nothing. September dates of service fall under the old rules and pay normally. If a September telehealth claim rejects for an originating site reason, that is a clearinghouse or MAC edit error, not a rule change, and it should be resubmitted.
What to do this week
- Pull the list of Medicare telehealth visits scheduled through October 31 and sort by whether the patient will be at home. Decide visit by visit: convert, hold or ABN.
- Run a report of Medicare telehealth claims with dates of service from October 1 forward every Friday, and a second report of all Medicare Part B claims with October dates of service so you can watch the hold lift.
- Confirm your MA plans' shutdown telehealth positions in writing or through the portal. Do not assume all plans followed CMS's flexibility.
- For behavioral health, add the last in-person visit date to the schedule view so schedulers can see who is due.
- Model the cash effect. A practice with 150 Medicare video visits a month at roughly $90 to $130 per visit has $13,000 to $20,000 of October revenue at risk on the telehealth rule alone, and all of its October Medicare Part B revenue delayed by the hold. That is uncomfortable but survivable for most practices; it is worth knowing the number.
Practices that outsource medical billing to us are seeing the tagged claims in their dashboard and will get a note when the hold changes. If you want help sorting the October schedule, book a call.
