The federal government shut down at midnight on September 30, 2025, after Congress was unable to approve a funding bill or a short-term continuing resolution for fiscal year 2026. While Medicare and Medicaid remain classified as essential services and continue to process physician payments, several critical health programs and pandemic-era flexibilities have expired, leading to uncertainty for physician practices across the country.
As of October 1, most of Medicare’s telehealth waivers that were implemented during the COVID-19 pandemic have expired. This means that Medicare telehealth coverage is now largely restricted to rural areas, reverting to the rules that were in place before the public health emergency. Patients are generally no longer able to receive telehealth services from their homes unless they meet certain exceptions.
Exceptions include treatment for mental or behavioral health disorders (including substance use disorders), stroke evaluation and management, and monthly visits for home dialysis patients with end-stage renal disease. Other non-rural Medicare beneficiaries are no longer eligible for telehealth visits, and the option to provide audio-only services has ended. The Acute Hospital Care at Home program has also concluded.
The Centers for Medicare & Medicaid Services (CMS) advises clinicians who continue providing telehealth services that are not currently reimbursed by Medicare to consider issuing Advance Beneficiary Notices of Noncoverage, informing patients that these services may not be covered. According to the American Medical Association, physicians participating in some Medicare Shared Savings Program Accountable Care Organizations may still offer and be paid for telehealth under specific waivers.
Although telehealth flexibilities have expired, Medicare is still processing claims during the government shutdown. CMS clarified that physicians can submit telehealth claims, but payments will be temporarily held while Congress decides whether to reinstate the waivers. If Congress restores these flexibilities, payments could be made retroactively, but there is no assurance if legislative action is not taken. CMS recommends that practitioners assess whether to issue Advance Beneficiary Notices or consider shifting patients back to in-person visits until further guidance is available.
