Medicare Telehealth Coverage Changes, MACs, and Claims Processing During the 2025 Shutdown: Key Takeaways for Providers and Healthcare Organizations

Medicare claims processing will be temporarily halted during the government shutdown, with MACs implementing a hold lasting up to 10 business days. Telehealth coverage changes, including geographic restrictions, site of service limitations, and provider responsibilities, are set to take effect on October 1, 2025. ACO clinicians participating in Medicare Shared Savings Program Accountable Care Organizations will retain flexibility in providing telehealth services.

September 12, 2025

In response to the ongoing government shutdown, the Centers for Medicare and Medicaid Services (CMS) has implemented a temporary halt on Medicare claims processing, affecting telehealth services. The move, announced on the first day of the shutdown, is part of a broader set of changes aimed at managing the impact of the funding lapse.

Temporary Claims Hold

CMS has directed Medicare Administrative Contractors (MACs) to implement a temporary claims hold for telehealth services, effective October 1, 2025. This hold is expected to last up to 10 business days. During this period, providers can submit telehealth claims, but they will not receive payment until the hold is lifted How the shutdown impacts healthcare: CMS pauses some telehealth claims as pandemic-era flexibilities lapse^[1].

Telehealth Coverage Changes

Several key changes to telehealth coverage are set to take effect on October 1, 2025:

- Geographic Restrictions: Medicare beneficiaries must be located in a rural health clinic or rural hospital to conduct a telehealth visit with a provider in another geographic location, excluding mental health services.
- Site of Service Limitations: Audio-only visits are no longer allowed.
- Provider Responsibilities: Certain practitioners, including occupational therapists, physical therapists, speech-language pathologists, and audiologists, can no longer render telehealth services.
- ACO Flexibility: Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program can still perform telehealth services regardless of the beneficiary’s geographic location, allowing beneficiaries to conduct visits in their homes.

Advance Beneficiary Notice of Noncoverage

Providers who continue to offer telehealth services not covered by Medicare should consider sending an Advance Beneficiary Notice of Noncoverage to patients. This notice informs beneficiaries that Medicare will not cover the services How the shutdown impacts healthcare: CMS pauses some telehealth claims as pandemic-era flexibilities lapse^[1].

Impact on HHS and NIH

The Department of Health and Human Services (HHS) is expected to furlough approximately 32,460 employees, or 41%, during the shutdown. However, Medicare, Medicaid, and other mandatory health program payments will continue. The National Institutes of Health (NIH) will halt research activities, while the FDA will not accept new applications for drug and device reviews during the shutdown How the shutdown impacts healthcare: CMS pauses some telehealth claims as pandemic-era flexibilities lapse^[1].

Market Response

Healthcare stocks, including UnitedHealth Group, Humana, and CVS Health, have been impacted by the changes. UnitedHealth Group announced plans to cancel its Medicare Advantage offerings in 109 U.S. counties in 2026, affecting approximately 180,000 members UnitedHealth Stock Slips Premarket Amid Medicare Advantage Pullback; Humana, CVS Also Tighten Coverage^[2].

References

How the shutdown impacts healthcare: CMS pauses some telehealth claims as pandemic-era flexibilities lapse^[1] FierceHealthcare. "Shutdown Tracker: CMS issues billing guidance, HHS furloughs 32,000 employees." [https://www.fiercehealthcare.com/regulatory/shutdown-tracker-cms-issues-billing-guidance-hhs-furloughs-32000-employees](https://www.fiercehealthcare.com/regulatory/shutdown-tracker-cms-issues-billing-guidance-hhs-furloughs-32000-employees)

UnitedHealth Stock Slips Premarket Amid Medicare Advantage Pullback; Humana, CVS Also Tighten Coverage^[2] Asianet Newsable. "UnitedHealth stock slips premarket amid Medicare Advantage pullback." [https://newsable.asianetnews.com/markets/unitedhealth-stock-slips-premarket-amid-medicare-advantage-pullback-humana-cvs-also-tighten-coverage-articleshow-5ppo69u](https://newsable.asianetnews.com/markets/unitedhealth-stock-slips-premarket-amid-medicare-advantage-pullback-humana-cvs-also-tighten-coverage-articleshow-5ppo69u)