On October 21, 2025, the Centers for Medicare and Medicaid Services (CMS) announced that the hold on most Medicare claims will be lifted. In this blog, we discuss the latest update and what it means for you.
Which Claims Will Be Reimbursed?
CMS has instructed Medicare Administrative Contractors (MACs) to begin processing claims with dates of service of October 1, 2025, and later for most Medicare services. This includes certain services that were impacted by the provisions that expired on September 30, 2025.
Claims released from the hold include:
- Claims paid under the Medicare Physician Fee Schedule
- Ground ambulance transport claims
- Federally Qualified Health Center (FQHC) claims
- Claims that CMS can confirm are *definitively *for behavioral and mental health services
Claims that will continue to be held (not be reimbursed) include:
- Claims for all other telehealth services (i.e., telehealth that is not for behavioral or mental health)
- Acute Hospital Care at Home claims
Note that the claims hold does not apply to Medicare Advantage or to Medicaid.
For additional details on the telehealth flexibilities that expired on September 30, 2025, click on the dropdown below. Claims for these services will not be reimbursed unless Congress acts to renew these flexibilities.
Expiration of Telehealth Flexibilities
The Medicare fee-for-service telehealth flexibilities that were established during the COVID-19 Public Health Emergency (PHE) expired on September 30, 2025. This means that as of October 1, 2025, in order to be reimbursable, telehealth visits must meet the pre-COVID-19 PHE requirements, including the following:
- Geographic and Originating Site Requirement: As of October 1, 2025, the patient’s home is no longer considered an “originating site.” For non-behavioral or mental health services, patients can only receive care from specific sites, such as a provider’s office or hospital.
- No More Audio-Only Telehealth: Audio-only telehealth visits are no longer reimbursable unless they are for behavioral or mental health.
- In-Person Visit Requirement: Patients receiving behavioral health telehealth services must first have an in-person visit and continue to have an in-person visit at least once every 12 months.
For telehealth services that do not meet the criteria to be covered, CMS recommends that providers consider using an Advance Beneficiary Notice of Noncoverage (ABN) before delivering the service to inform patients that Medicare is unlikely to provide coverage.
Medicare Shared Savings Program Accountable Care Organizations (ACOs) will continue to be reimbursed for covered telehealth services.
For Medicare Advantage, many plans, such as Aetna and United Healthcare, are continuing to offer payment for expanded telehealth services.
Medicaid plans may also continue to offer expanded telehealth services.
For both Medicaid and Medicare Advantage, we recommend checking with specific plans to see if they are continuing coverage.
Next Steps
- Share this information with your colleagues.
- To learn more about the impact of the government shutdown, refer to our previous blog: What You Need to Know about the Government Shutdown.
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Written By: Jessica Peterson, MD, MPH & Sarrah Hakim, MHSA
About the Authors:
Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.
Sarrah Hakim, MHSA is a Manager of Health Policy at Anatomy IT.