Shutdown FAQs: Impact on Federal Payors, Health Care Practices, and Telehealth

Note: This article has been updated to reflect APTA’s latest analysis of the federal government’s official shutdown and subsequent related guidance as of Oct. 24. For more information on recent CMS claims hold updates, please see section 2 of this article. APTA members should be mindful of how a lapse in federal funding affects major federal health care programs, Medicare, and Medicaid.

Here are a few common questions that you’ll want to know the answers to:

Where can I find resources on what’ll be happening to the staffing and operations at the federal health care agencies and other agencies that provide care services?
Can I still see Medicare patients and bill Medicare for my services?
Can I continue to see Medicare patients via telehealth?
What happens to survey and certification activities?
What happens to federal rulemaking?
What happens to HHS-employed care providers during a shutdown?

1. Where can I find resources on what’ll be happening to the staffing and operations at the federal health care agencies and other agencies that provide care services?

The Department of Health and Human Services, as well as its subagencies, which include the Centers for Medicare & Medicaid Services, maintain staffing contingency plans for a lapse in funding caused by a shutdown, the summaries of which are publicly available at this page (subagencies are separately linked at the bottom). We have also provided an FAQ and contingency page for VA employees. The answers to the questions in this FAQ reflect these summaries.

These documents are the most current, publicly available plan of what is likely to occur in the event of a shutdown. However, some parts of these plans are discretionary (e.g., optional exemptions), and there is no way of knowing exactly how operations may be affected. Still, for any questions not answered in this guidance, we recommend reviewing the staffing plan most relevant to your needs. Otherwise, submit questions to APTA Advocacy.

For ease of access, each agency and subagency’s plan is linked below — CMS, ACL, FDA, HRSA, and NIH are bolded given their direct impact for certain providers:

HHS Contingency Staffing Plan for Operations

Department of Veterans Affairs Contingency Planning

VA Furlough FAQs

2. Can I still see Medicare patients and bill Medicare for my services?

Yes, the expectation is that the Medicare program will continue during a shutdown, and Medicare Administrative Contractors would be expected to continue processing provider claims. On Oct. 1, CMS announced a hold on Medicare claims for dates of service on or after Oct. 1, expected to last 10 business days to help ensure accuracy in payments and prevent reprocessing if Congress had legislated funding shortly after the shutdown.

Update on CMS Claims Holds as of Oct. 24
On Oct. 21, CMS announced it has instructed all MACs to lift a hold and begin processing claims for dates of service Oct. 1 and after for those paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and federally qualified health center claims. While it also included lifting holds on telehealth claims that CMS can confirm are for behavioral health services, a temporary claims hold that began Oct. 1 for other telehealth services, including physical therapy telehealth, continues.

The Oct. 21 CMS Claims Hold Update follows two previous updates on Oct. 15, one that briefly indicated that all payments under the PFS, ground ambulance transport claims, and all federally qualified health center claims would be temporarily held that was promptly reversed.

During the shutdown, providers within a handful of states should also expect a decrease in reimbursement due to the lapse in the extension of the 1.0 floor for work geographic practice cost indices, or GPCIs. GPCIs adjust relative value units in Medicare payments to reflect regional differences in the cost of physician services. Congress has routinely renewed GPCI as part of the formula for Part B reimbursement. The extension is expected to be included in a future funding package, but CMS has not instructed MACs to hold claims affected by the lapse in extension during this period.

Additionally, providers should be aware that during a shutdown, CMS would suspend its oversight activities of its major contractors, including MACs, which include monitoring quality, quantity, and timeliness of contractor performance. While not guaranteed, suspension of these activities could affect a response to provider complaints related to MAC performance. In addition to its contractors continuing operations, CMS anticipates 51% of its own staff will be retained during a shutdown.

3. Can I continue to see Medicare patients via telehealth?

Specifically regarding telehealth, CMS advised that practitioners who choose to perform telehealth services that are not payable by Medicare on or after Oct. 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage, or ABN. They should monitor congressional action and may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of congressional action.

Historically, Congress has extended the Medicare telehealth waivers every time they have approached expiration, most recently through the Full-Year Continuing Appropriations and Extensions Act, 2025, which allows any practitioner who can independently bill Medicare for their professional services, including physical therapists, to furnish telehealth through Sept. 30. Without further action to extend this waiver, physical therapists will not be eligible to be paid for services delivered to Medicare beneficiaries provided via telehealth starting Oct. 1. Therefore, any patients who were seen via telehealth on or before Sept. 30 should be reimbursed by Medicare, but the MACs will not reimburse for services delivered Oct. 1 or later.

4. What happens to survey and certification activities?

These activities would not continue in their full capacity. Many APTA members are familiar with regularly conducted survey and certification activities, either at outpatient practices or any of the facilities PTs are employed in. These include primary site and extension surveys to ensure compliance with Medicare Conditions of Participation. Further, survey and certification are not only regularly scheduled activities but also ad hoc, such as investigations based on provider or beneficiary complaints.

During a shutdown, however, CMS anticipates that its operations would reduce to complaint investigations of the most serious alleged incidents of resident or patient harm. Notably, recertification surveys, initial surveys, less serious complaint investigations, and all surveys by federal staff would be suspended.

5. What happens to federal rulemaking?

Rulemaking is expected to be delayed. APTA members may be familiar with the impact that federal rulemaking has on their practice, dictating policies that directly impact operations and payment.

While staff may be available to work on payment or policy rule development, such as the 2026 Medicare physician fee schedule final rule, there are fewer employees available to meet the statutory timelines for rulemaking. APTA members can expect periodic updates on the status of the PFS final rule and education on the rule as soon as it becomes available.

6. What happens to HHS-employed care providers during a shutdown?

Generally, employees fall into one of three categories: furloughed, exempted, or excepted. Employees who are “exempt” from furlough are not affected by a lapse in appropriations because their activities are funded from sources other than annual appropriation, and funding will continue to be available to pay their salaries. By contrast, “excepted” employees may be retained by HHS to perform activities authorized by law, by implication, or necessary to protect the safety of human life.

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