Updated October 16, 2025
Unfortunately, Congress was unable to reach a funding consensus before the end of the federal fiscal year (September 30), and the US federal government shut down as of 12:01 a.m. on October 1. During a shutdown, non-essential federal employees are furloughed, and many government services are paused until funding is restored. The Committee for a Responsible Federal Budget has created a comprehensive FAQ for reference, but APMA has captured the main concerns below. APMA consultant Hart Health Strategies has also compiled an extensive resource document addressing the shutdown impact.
How Will the Shutdown Affect My Practice?
On October 15, 2025, CMS released a Medicare Learning Network (MLN) Connects Newsletter clarifying that Medicare Administrative Contractors (MACs) would continue to process and pay held claims in a timely manner with the exception of select claims for services impacted by the expired provisions with dates of service on or after October 1. As initially indicated, this hold "prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date” to extend certain statutory provisions that have expired, including certain telehealth flexibilities. Providers can continue to submit claims during this hold time, but payment will not be released until the hold is lifted. A previous communication implied that CMS had directed MACs to continue holding all Medicare Physician Fee Schedule (PFS) claims.
CMS will also continue to pay Medicaid reimbursement as long as funds allow without a reauthorization in appropriations. APMA will not know how long CMS Medicaid reimbursement will continue until shutdown contingency instructions are released. Additionally, providers may have delays in responses to billing questions and process enrollment applications because the employees for these functions are paid through annual appropriations and could be affected by the shutdown.
The Department of Veterans Affairs (VA) will require physicians to report to work and deliver clinical care, but there will be a delay in reimbursement and administrative functions. The VA recently released its shutdown contingency instructions.
Telehealth Extension
Medicare telehealth benefits originally established during the COVID-19 Public Health Emergency have expired. This means that absent any additional Congressional action, telehealth services are prohibited for Medicare beneficiaries who do not live in rural areas. Home-based telehealth services are no longer be reimbursed, and patients are required to travel to a medical facility to receive Medicare telehealth. The Acute Hospital Care at Home Program has also expired along with the ability to provide audio-only visits as well. CMS has advised that practitioners choosing to perform telehealth benefits on or after October 1 should consider providing beneficiaries with an Advance Beneficiary Notice of Noncoverage.
Please note, that for DME requiring a face-to-face encounter prior to dispensing, the more restrictive, reinstated telehealth restrictions will again apply:
2) Items Requiring a Face-to-Face Encounter. For PMDs and other DMEPOS items selected for inclusion on the Required Face-to-Face Encounter and Written Order Prior to Delivery List, the treating practitioner must document and communicate to the DMEPOS supplier that the treating practitioner has had a face-to-face encounter with the beneficiary within the 6 months preceding the date of the written order/prescription.
(i) The encounter must be used for the purpose of gathering subjective and objective information associated with diagnosing, treating, or managing a clinical condition for which the DMEPOS is ordered.
(ii) If it is a telehealth encounter, the requirements of §§ 410.78 and 414.65 of this chapter must be met.
410.78 includes requirements for originating site and geographic location requirements for telehealth (among other requirements). This means that any face-to-face encounter via telehealth used to support the ordering of DME will need to comply with the more restrictive reinstated telehealth restrictions. APMA recommends that providers confirm that the face-to-face visit was either in-person or conducted in accordance with the more restrictive telehealth policies that are now in place before dispensing DME after October 1, 2025.
Members can view the full list of DME items that require a face-to-face encounter here: https://www.cms.gov/files/document/required-face-face-encounter-and-written-order-prior-delivery-list.pdf.