The Government failed to pass a Continuing Resolution by midnight on September 30th to fund the Government as of The Government failed to pass a Continuing Resolution (CR) by midnight on September 30, resulting in a lapse in funding effective October 1. This impacts our LTC sector in two key areas: Telehealth and a Temporary Claims Hold.
Telehealth Option for Rehab Expired
Effective October 1, CMS will be reverting to pre-COVID-19 Telehealth limitations, meaning current Telehealth authority utilized by rehab therapists for Medicare paid services lapsed as of midnight September 30. It is expected that eventually Congress will pass the CR which will extend the current telehealth authorities.
Temporary Claims Hold
CMS has directed all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.
FAQs: What Happens After September 30, 2025?
Q: What are our options for handling telehealth billing after September 30?
A: Continue as Normal:
Continue billing for Part B telehealth services as usual.
Hold telehealth treatment:
This could have potential clinical and financial implications. Facilities are still required to meet their respective state practice acts and to provide 10th visits to patients covered by Med B. If telehealth is the only option to provide these services, this may be the best option to maintain compliance with all regulatory requirements. If CMS retros the bill to 10/1 this could potentially reduce reimbursement to the facility.
Q: Should we be concerned about Medicare Part A services?
A: No. Medicare Part A services are not reimbursed for telehealth (bundle) and are not impacted by this change. The primary concern is Medicare Part B billing.
Q: If the evaluation is done by telehealth can the rest of the treatment be billed as usual.
A: Yes, since telehealth is still an allowable mode of delivery the entire treatment plan counts as a recognized Plan of Care. Only the treatments delivered by telehealth have the potential to be denied.
Q: If I know that the services won’t be reimbursed, should I still document the treatments?
A: Yes, all treatments should be recorded as they are actual medical services that are provided. The minutes should still be counted on the MDS and recorded on the UB 04.
Q: Does a telehealth visit count towards the necessary 5 days of treatment to meet the skilled criteria for Medicare A?
A: Yes, telehealth is an accepted mode of treatment that meets the Medicare A criteria.
Q: Does a telehealth visit count to meet the state practice act?
A: Yes, as long as telehealth is allowed in your particular state.
The Point Is: The Government Shutdown has impacted our ability to utilize telehealth as a valuable tool to ensure prompt access to therapy when an evaluating therapist onsite is unavailable. QRM will continue to monitor updates on ongoing Continuing Resolution efforts and will share updates as they become available. Please let us know if any questions arise that we can assist with.
