October 17, 2025
CMS Releases Updated Medicare Telehealth Guidance
On October 1, 2025, the Centers for Medicare and Medicaid Services (CMS) issued guidance regarding Medicare telehealth claims during the government shutdown via a special edition of the Medicare Learning Network (MLN) Newsletter. In the update, CMS stated that when legislative payment provisions are scheduled to expire, CMS directs Medicare Administrative Contractors (MACs) to implement a temporary claims hold, typically of up to 10 business days. The hold is meant to prevent a large reprocessing of claims if Congress acts after the statutory expiration date, which was September 30, 2025.
As the 10-day hold period had expired on October 14, CMS has now issued an additional claims hold update on October 15, 2025, stating that in anticipation of possible Congressional action, CMS has instructed all MACs to continue to temporarily hold claims with dates of service of October 1, 2025 and later for services impacted by the expired Medicare legislative waivers. This includes all claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center (FQHC) claims. While providers may continue to submit these claims, CMS states that payment will not be released until the claims hold is lifted.
Also noted in the update, CMS again suggests that without further Congressional action, providers that continue to deliver telehealth services that are now not eligible for Medicare payment as of October 1, 2025, may want to provide patients with an Advance Beneficiary Notice of Noncoverage.
Meanwhile, stakeholders including the American Telemedicine Association (ATA) are advocating that Congress include a retroactive statement in any future funding fix, to help reassure providers that reimbursement of telehealth services delivered during the waiver gap period will eventually be provided.
