Telehealth policy changes take effect; shutdown impacts Medicare claims processing

In the Medicare Learning Network (MLN) Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown of Oct. 1, 2025, CMS announced that significant changes to Medicare telehealth services that took effect on Oct. 1, 2025, may impact the processing of Medicare telehealth claims. The changes mark the expiration of temporary flexibilities introduced during the COVID-19 Public Health Emergency, reinstating pre-pandemic statutory limitations for telehealth services.

Dermatologists must be aware of how these changes will affect service delivery and Medicare claims payment, especially during the current government shutdown.

During the government shutdown, CMS has directed all Medicare Administrative Contractors (MACs) to implement a temporary telehealth claims hold. This standard procedure typically lasts up to 10 business days and is designed to ensure payment accuracy while awaiting potential congressional action. Offices may continue submitting claims during this period; however, payments will not be released until the hold is lifted. The impact is expected to be minimal due to Medicare’s 14-day payment floor.

Absent congressional action, many of the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency have taken effect again for services that are not considered behavioral and mental health services, which retain broader telehealth coverage.

Under the reinstated rules, many telehealth services provided to beneficiaries in their homes and outside of rural areas and hospice recertifications that require a face-to-face encounter will no longer be reimbursed by Medicare. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits.

When offering telehealth services during the government shutdown period, dermatologists should consider issuing an Advance Beneficiary Notice of Noncoverage (ABN) to inform patients of potential out-of-pocket costs.

During the government shutdown, MACs will continue to perform all functions related to Medicare Fee-for-Service claims processing and payment. Dermatologists are encouraged to monitor congressional developments closely and consider holding claims for telehealth services that may not be payable under current Medicare rules. For more information, visit the CMS Telehealth Coverage page and the AAD’s teledermatology policy page for the latest updates.