Resources & Reports

On October 1, 2025, the Centers for Medicare and Medicaid Services (CMS) issued guidance regarding Medicare telehealth claims during the government shutdown via a special edition of the Medicare Learning Network (MLN) Newsletter. In the update, CMS stated that when legislative payment provisions are scheduled to expire, CMS directs Medicare Administrative Contractors (MACs) to implement a temporary claims hold, typically of up to 10 business days. The hold is meant to prevent a large reprocessing of claims if Congress acts after the statutory expiration date, which was September 30, 2025. As the 10-day hold period had expired on October 14, CMS has now issued an additional claims hold update on October 15, 2025, stating that in anticipation of possible Congressional action, CMS has instructed all MACs to continue to temporarily hold claims with dates of service of October 1, 2025 and later for services impacted by the expired Medicare legislative waivers.

CCHP’s October newsletter is here! This month’s topics include – MEDICARE: Telehealth Policy – Where Do We Stand Post-Waiver Expiration?; NEW(ish):  MONTHLY COLUMN IN THE CCHP NEWSLETTER; Federal Agencies and Congress Turn Their Attention to AI in Health Care; Ethical and Professional Perspectives on Telehealth: Insights from ACOG and AOA; ATA Launches Digital Infrastructure Score to Benchmark Community Readiness for Telehealth; Study Finds Gaps in Same-Day Mental Health Access for Telehealth Patients; Latest Developments in CCHP’s Telehealth Policy Finder.

The expiration of the Medicare telehealth waivers on September 30, 2025, has created significant uncertainty for providers as longstanding flexibilities have been scaled back or altered. While Congress continues to negotiate a government funding package that may reinstate some of these flexibilities, permanent statutory restrictions are now in effect layered with Centers for Medicare and Medicaid Services (CMS)’ guidance that is at times ambiguous or unclear. As a result, providers are facing complex questions regarding in-person visit requirements, billing procedures, and the applicability of policies across different care settings. As a result, CCHP has created two new resource documents in an effort to add some clarity to the currently quite complex landscape.

1. FAQ Document:  outlines common questions CCHP has received in regard to telehealth, including mental health and FQHC/RHC information.
2. Summary Chart:  outlines current permanent telehealth policy as CCHP understands it today, with accompanying source citations and insights.