When certain legislative payment provisions (“extenders”) are set to expire, CMS directs Medicare Administrative Contractors (MACs) to place a temporary hold—typically up to 10 business days—on claims. This standard practice helps ensure payments remain accurate with statutory requirements and avoids the need to reprocess large volumes of claims if Congress acts after expiration. Providers may continue submitting claims during this period; payments will be released once the hold is lifted.
Without Congressional action, beginning October 1, 2025, many pre-COVID-19 restrictions on Medicare telehealth services (except for behavioral and mental health) will be reinstated. This includes limitations on services delivered to patients in their homes, outside rural areas, and certain hospice recertifications requiring face-to-face encounters. Practitioners should consider the use of an Advance Beneficiary Notice of Noncoverage (ABN) when providing services not payable by Medicare, and may opt to hold claims for those services until Congressional direction is clear.
Notably, under the Bipartisan Budget Act of 2018, clinicians in eligible Medicare Shared Savings Program ACOs may continue to deliver covered telehealth services without geographic restrictions and bill Medicare accordingly, regardless of further Congressional action.
MACs will continue all core functions related to Medicare Fee-for-Service claims processing and payment throughout this period.
For details:
- Telehealth coverage: CMS Telehealth
- ACO telehealth fact sheet: Shared Savings Program Telehealth