The federal government entered a shutdown at midnight on September 30 after Congress did not pass a funding bill or temporary resolution for 2026. Essential health programs like Medicare and Medicaid continue to operate, but several pandemic-era services and flexibilities have expired, creating uncertainty for physician practices.
One significant change is the rollback of most telehealth waivers under Medicare. As of October 1, Medicare telehealth coverage is again limited mainly to rural areas, as it was before the COVID-19 pandemic. Patients generally cannot receive telehealth services from their homes unless they qualify under specific exceptions, such as treatment for mental health or behavioral health disorders (including substance use disorders), stroke evaluation and management, or monthly visits for home dialysis patients with end-stage renal disease.
Most non-rural Medicare beneficiaries are no longer eligible for telehealth visits, and audio-only services are no longer allowed. The Acute Hospital Care at Home program has also ended.
The Centers for Medicare & Medicaid Services (CMS) advises clinicians who provide telehealth services not currently payable under Medicare to consider giving patients Advance Beneficiary Notices of Noncoverage, which inform them that Medicare may not reimburse those services. The American Medical Association highlights an exception: “Physicians participating in certain Medicare Shared Savings Program Accountable Care Organizations may continue to provide and be paid for telehealth services under their program-specific waivers.”
Although telehealth flexibilities have expired, CMS states that claim processing continues during the shutdown. Physicians can still submit claims for telehealth services, but these will be placed on temporary payment hold while Congress debates whether to extend the waivers. If Congress restores the flexibilities, payments could be made retroactively; if not, there is no guarantee physicians will be paid.
The CMS newsletter recommends: “practitioners who choose to perform telehealth services that are not payable by Medicare on or after Oct. 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage.” Some physicians may choose to switch to in-person visits until further guidance is available.
