Funding lapse update, Oct. 15, 2025

As the lapse in federal funding continues, the Centers for Medicare & Medicaid Services (CMS) has instructed all Medicare Administrative Contractors (MACs) to continue temporarily holding claims with dates of service on or after Oct. 1, 2025, for services impacted by expiration of provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025. These include the expiration of policies enabling telehealth services to be provided to Medicare beneficiaries in their homes and outside of rural areas. Update guidance from CMS can be found in the latest MLN Connects Newsletter.

In the absence of Congressional action, CMS advises that physicians who choose to perform telehealth services that are not payable by Medicare on or after Oct. 1, 2025, may want to consider providing beneficiaries with an Advance Beneficiary Notice of Noncoverage (ABN).

It is also important to note that the Bipartisan Budget Act of 2018 allows clinicians in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) to provide and receive payment for covered telehealth services to certain Medicare beneficiaries without geographic restriction and in the beneficiary’s home. Physicians in applicable ACOs can provide these covered telehealth services and bill Medicare for the telehealth services that are permissible under Medicare rules during CY 2025, irrespective of further Congressional action.

The AOA continuous to work with Congress to find common ground to fund the government and ensure patient access to care.