… and other questions you might have about telehealth during the 2025 government shutdown
As ACG members are likely aware, the popular COVID-era Medicare telehealth flexibilities expired on September 30th.
ACG is dismayed that Congress did not act to avoid this scenario, where our patients may struggle to access critical GI services. In September, the House approved a bill that would have averted the ongoing government shutdown and extended telehealth flexibilities into November – we hope that whichever shutdown solution Congress adopts retains this extension, although it is not guaranteed.
Here are some answers to other common questions you may have about telehealth for your Medicare patients.
Are my telehealth claims being processed during the shutdown?
On October 15, CMS announced that they lifted the 10-day hold on most claims which was enacted at the beginning of the shutdown. They are still holding claims for dates of services provided on October 1 or later that are impacted by expired payment policies, such as telehealth claims.
Which patients are impacted by this change?
The end of the COVID-era telehealth flexibilities primarily affects your patients on traditional, fee-for-service Medicare. For your patients on Medicare Advantage plans, telehealth coverage may differ on a payor-to-payor basis.
Since policies have reverted to their pre-COVID status for traditional Medicare beneficiaries receiving non-mental health services, geographic restrictions have also returned. The practical implication of this is that Medicare will only reimburse telehealth claims for rural Medicare beneficiaries (as identified by CMS), and they must travel to a facility rather than remaining at home.
Although providers are technically permitted to offer telehealth services under traditional Medicare, claims will not be reimbursed unless Congress authorizes retroactive reimbursement. This creates significant uncertainty whether you will be reimbursed for any telehealth services provided during the shutdown. For example:
SCENARIO 1: A non-rural patient who is at home receives a telehealth visit, and Congress does not approve retroactive reimbursement for telehealth services provided during the government shutdown. This visit will not be reimbursed.
SCENARIO 2: However, if Congress extends telehealth flexibilities and authorizes retroactive reimbursement for Scenario 1 claims provided during the government shutdown, the visit will be reimbursed, potentially at the non-facility (physician office) rate, given previous CMS guidance.
SCENARIO 3: A rural patient goes to a designated telehealth facility to receive their service. This visit will be reimbursed.
The following chart may help you understand what has changed since September and now, in terms of where you and the patient are located and what types of services are still covered. ACG encourages you to refer to CMS for more guidance and information.
What are my options if a Medicare patient specifically requests a telehealth visit?
ACG recognizes some Medicare patients may still ask for their upcoming visit to take place virtually.
First and foremost, remember that telehealth visits after September 30th, 2025,may not be reimbursed by the government. Congress would need to authorize retroactive reimbursement for these claims, and that is not guaranteed.
Telehealth services may or may not present a significant financial barrier for your patients; however, if they insist on proceeding with telehealth from home, CMS recommends issuing an Advanced Beneficiary Notice of Noncoverage (ABN), a written notice for your patient, issued before you provide a service that may not be covered.
The ABN can help your patients better understand the risks and financial responsibilities and you can download the form on CMS’ website. ACG has also created a step-by-step process for the ABN, available for download and at the bottom of this blog.
Is there any other risk to me as the physician if I continue to offer telehealth to my Medicare patients?
Before continuing to offer telehealth services that may not be reimbursed by Medicare, ACG recommends you confirm with your local Medicare Administrative Contractor.
Step-By-Step Process for Medicare Telehealth ABN
Effective October 1, 2025
- Identify At-Risk Services
- Audio-only telehealth
- Patient’s home as originating site
- Provider’s home, office as distant site
- Verify Coverage Status
- Check CMS updates and MAC guidance
- Confirm if service is no longer reimbursable as of October 1, 2025
- Prepare ABN (CMS Form CMS-R-131)
- Clearly describe the service
- State why Medicare may not pay (e.g., “Medicare no longer covers audio-only telehealth for this service after October 1, 2025”)
- Discuss With Patient
- Explain financial responsibility
- Answer questions and confirm understanding
- Obtain Signature Before Service
- Patient must sign ABN prior to receiving the service
- Keep a copy in the medical record
- Use Modifier -GA When Billing
- Indicates ABN was issued and patient accepted responsibility