Effective October 1, 2025

CMS has instructed all Medicare Administrative Contractors (MACs) to temporarily hold claims with dates of service October 1, 2025, and later for services affected by the expired Medicare payment provisions under the Full-Year Continuing Appropriations and Extensions Act, 2025.

This hold applies to:

• All services paid under the Medicare Physician Fee Schedule
• Ground ambulance transport claims
• Federally Qualified Health Center (FQHC) claims

Providers may continue submitting claims, but payments will not be released until the hold is lifted.

Telehealth Impact

Unless Congress takes action, pre-pandemic restrictions on Medicare telehealth coverage have resumed for non-behavioral health services.

This includes:

• Geographic restrictions (coverage limited to rural and underserved areas)
• Originating site limitations (no longer payable from the patient’s home)
• In-person requirements for hospice recertifications

Practitioners who continue providing non-payable telehealth services after Oct. 1, 2025, should consider issuing an Advance Beneficiary Notice of Noncoverage (ABN) to protect against payment denials.

 ABN Forms & Instructions 

ACO Exception

Clinicians participating in approved Medicare Shared Savings Program ACOs may continue telehealth services without geographic restriction or in-person limitations.

More information: CMS Telehealth Fact Sheet

What Practices Should Do Now

• Continue submitting claims but expect payment delays.
• Monitor Congressional updates closely.
• Review your telehealth policies and ABN procedures.
• Communicate with your billing team or Peregrine representative to ensure proper handling of held claims.

We’ll continue to monitor CMS updates and share guidance as new details are released.

Schedule your year-end strategy review with your Peregrine representative today.