Updated 10/21/25
CMS has directed Medicare Administrative Contractors (MACs) to lift the claims hold and process services dated October 1, 2025, and later under the Medicare Physician Fee Schedule, FQHC, and ground ambulance provisions.

Telehealth claims for behavioral and mental health services will continue to be paid, while other telehealth and Hospital Care at Home claims remain on hold pending further guidance. Practitioners may consider ABNs for non-payable services.
More details: CMS Telehealth Coverage | ACO Telehealth Fact Sheet (PDF)

​Updated 10/16/2025
Overnight, the Centers for Medicare & Medicaid Services (CMS) issued new guidance directing Medicare Administrative Contractors (MACs) to limit the current claims hold to only those services affected by expired Medicare legislative payment provisions.

The hold now applies only to:

  • Telehealth services other than those for behavioral or mental health care
  • Services provided in areas with a work geographic practice cost index (GPCI) below 1.0

For all other services, Medicare claims will continue to be processed and paid in a timely manner. To date, no payments have been delayed, as federal statute already requires a minimum 14-day hold for all claims.

NANS continues to monitor the impact of the federal shutdown. Physicians experiencing payment or processing issues are encouraged to contact ama.advocacy@ama-assn.org with the subject line “Medicare Payment Delay.”

CMS has also released updated telehealth FAQs, available here. 

Background: Initial CMS Claims Hold Guidance

Earlier this week, CMS instructed all MACs to temporarily hold claims with dates of service on or after October 1, 2025, including those under the Medicare Physician Fee Schedule, ground ambulance transport, and Federally Qualified Health Center claims.

The intent was to anticipate potential Congressional action to restore expired payment provisions under the Full-Year Continuing Appropriations and Extensions Act, 2025.
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At that time, physicians were advised to monitor MAC websites and CMS.gov for real-time updates.

Key impacts included:

  • Expiration of most Medicare telehealth flexibilities, except for mental health and substance use disorder care
  • Advance Beneficiary Notice (ABN) requirements for non-covered telehealth services
  • Expiration of the 1.0 work GPCI floor
  • An ACO exception allowing eligible Medicare Shared Savings Program ACOs to continue covered telehealth services without geographic limits