Medicare operations updates provide limited update on telehealth flexibilities
       
    Jan Hailey, MHL, CMC, CMCO,
CMIS,CMOM, CMCA-E/M
     
     
By Jan Hailey, MHL, CMC, CMCO, CMIS, CMOM, CMCA-E/M

The Centers for Medicare & Medicaid Services (CMS) addressed related changes in its updated MLN006764 - Evaluation and Management Services, particularly on pages 29-30. As of October 1, 2025, no further legislative extensions to telehealth flexibilities have been enacted. 

In addition, the MLN Connects newsletter from October 1, 2025, provides a Medicare operations update that includes telehealth, claims processing, and MAC (Medicare Administrative Contractor) status during the government funding hiatus.

Key points from Oct 1, 2025, MLN Connects:
  • Because certain “extender” provisions expired, CMS has instructed MACs to place a temporary claims hold (typically up to 10 business days) to minimize the need for large-scale reprocessing should Congress later act. Providers may still submit claims during this hold period, but payment release is delayed.
  • Absent Congressional intervention, many pre-PHE (public health emergency) telehealth limitations will resume for non–behavioral health services. For example, restrictions on home as a telehealth site, service types permitted, and geographic constraints may take effect again.
  • Hospice recertification in some cases will revert to requiring face-to-face encounters.
  • Providers might consider issuing Advance Beneficiary Notices of Noncoverage (ABNs) for telehealth services rendered under circumstances that may not be reimbursable under reinstated rules.
  • Clinicians participating in applicable Medicare Shared Savings ACOs retain the ability to furnish and bill certain telehealth services without geographic restriction, per the Bipartisan Budget Act of 2018, even if broader telehealth flexibilities lapse.
The uncertainty this period brings for providers relying on telehealth is why ISMA continues to pay careful attention to evolving policy developments.  In the meantime, physicians are encouraged to:
  • Review current practices and telehealth workflows in light of potential reinstated restrictions.
  • Consider issuing ABNs proactively for high-risk telehealth services.
  • Stay in touch with MAC and coding resources to track implementation of any rolling claims holds.
Please reach out to ISMA with questions or need assistance as this situation develops.