CMS Updates Guidance on Claims Processing and Survey Activities Amid Federal Shutdown
(Oct. 21, 2025) The Centers for Medicare and Medicaid Services (CMS) has released updates to guidance on Medicare claims processing and survey activities during the federal shutdown.
Medicare Claims Hold for Certain Services
In the wake of confusion created by inconsistent notices last week, CMS has issued updated guidance on the Medicare claims hold. In a Special Edition of the Medicare Learning Network (MLN) Connects newsletter issued today, Oct. 21st, CMS directs Medicare Administrative Contractors (MACs) to resume processing claims with dates of service on or after Oct. 1, 2025 for certain services that it had previously announced were being held. The claims that were to be held under the prior notice, but are now being processed, are:
- Claims under the Medicare Physician Fee Schedule
- Ground ambulance transport claims
- Federally Qualified Health Center (FQHC) claims
- Telehealth claims that CMS can confirm as behavioral or mental health services
However, claims for other telehealth services (i.e., those that are not for behavioral health) and for Hospital Care at Home remain on hold. Many COVID-era telehealth flexibilities expired on Oct. 1st, resulting in the resumption of pre-COVID restrictions on Medicare reimbursement for services delivered to beneficiaries in their homes or outside rural areas and requirements for in-person hospice recertifications.
The notice reiterates that clinicians in qualifying Medicare Shared Savings Program Accountable Care Organizations (ACOs) may continue to provide and bill for covered telehealth services without geographic restrictions, including in-home services, under special statutory flexibilities.
The MLN notice encourages practitioners offering non-covered telehealth services to consider issuing Advance Beneficiary Notices of Noncoverage (ABNs). Additional guidance and ABN forms are available here.
Revised Survey and Certification Guidance During Shutdown
CMS also revised its QSO-26-01-ALL memo on Oct. 21st, updating the survey and certification activities that are suspended and those that may continue during the federal shutdown.
Most notably, the updated notice indicates that state survey agencies may request approval to conduct a revisit survey in order to “[p]revent a statutorily-mandated (three-month) denial of payment for new admissions.” This is in addition to the previously authorized revisits when necessary to prevent Medicare termination of a provider. LeadingAge National wrote to CMS last week asking that it suspend denials of payment for new admissions during the shutdown in order to avoid impacts on access to care. This updated guidance responds to the concern expressed by LeadingAge National.
The updated notice clarifies that state-funded survey activities are not impacted by the lapse in appropriations, but that these licensure surveys may not be assumed to count as federal surveys. States that receive funds under the Consolidated Appropriations Act of 2021 to conduct hospice surveys may also continue to conduct those surveys.
CMS further emphasizes in the update that routine Medicare provider certification activities, such as initial certifications, changes of ownership, and changes of location, will not be completed during the shutdown.
LeadingAge NY will continue to update members as the impacts of the shutdown evolve. The LeadingAge National serial post on the shutdown is here.
Contact: Karen Lipson, klipson@leadingageny.org