Government Shutdown Ends: What the CR Bill Means for Your Medical Practice's Telehealth Operations

Executive Summary for Practice Leaders

The 43-day government shutdown officially ended on November 12, 2025, when President Trump signed a continuing resolution (CR) that retroactively restored critical healthcare programs and provider payment protections through January 30, 2026. For medical practices, this means immediate reinstatement of Medicare telehealth flexibilities, payment safeguards, and safety-net program funding that had lapsed on October 1, 2025.

However, this temporary extension creates a new deadline in just over two months. Practice leaders and clinical staff need to understand both the immediate relief and the longer-term operational challenges ahead.

The Telehealth Relief You've Been Waiting For

What's Been Restored

When the government shutdown began, Medicare telehealth waivers that had been in place since the COVID-19 pandemic expired on October 1, 2025. During the subsequent 43 days of shutdown, Medicare telehealth coverage authority simply didn't exist—creating confusion, billing nightmares, and operational paralysis for practices nationwide.

The CR retroactively restores all pandemic-era Medicare telehealth flexibilities from October 1, 2025, through January 30, 2026. This means:

Patients Can Receive Care From Home: Your patients can access non-behavioral health telehealth services from their homes without geographic restrictions. There are no rural/urban limitations. A patient in Denver can receive the same telehealth-eligible services as a patient in a small mountain town.

Expanded Provider Types: Your occupational therapists, physical therapists, speech-language pathologists, and audiologists can now bill Medicare for telehealth services. This is particularly valuable for practices offering integrated care or partnering with allied health professionals.

Audio-Only Coverage Continues: For patients without video capabilities—a surprisingly large segment of your Medicare population—audio-only telehealth visits remain covered. This eliminates barriers for elderly patients uncomfortable with technology.

Community Health Centers and Rural Clinics Stay Connected: If your practice contracts with or refers to FQHCs or Rural Health Clinics, those organizations can continue serving as distant-site providers for telehealth services, maintaining care coordination networks.

Mental Health Services (With a Caveat): Behavioral health telehealth services continue, but the requirement that patients have had an in-person visit within six months prior to their first telehealth appointment (and annually thereafter) is delayed until January 30, 2026. Your behavioral health staff should prepare for this requirement to potentially resume.

Hospice Recertification By Telehealth: If your practice provides hospice services, physicians and nurse practitioners can continue conducting required face-to-face encounters for patient recertification via telehealth.

The Hospital-at-Home Game Changer

The Acute Hospital Care at Home (HaH) waiver was extended through January 30, 2026. More than 400 approved facilities can now continue providing hospital-level care in patients' homes. If your hospital system or larger practice group hasn't explored this model, this timeline gives you approximately two months to assess whether HaH could:

• Reduce readmission rates for your complex patient populations

• Expand revenue through alternative care delivery models

• Improve patient satisfaction and clinical outcomes

• Create differentiation in a competitive market

The Payment Protection You Didn't Know You Needed

Beyond telehealth, the CR includes critical payment protections that directly affect your practice's revenue and bottom line.

The 4% Sequestration Waiver: What It Saves

Without the CR, Medicare would have imposed an additional 4% across-the-board sequestration cut beginning January 1, 2026, on top of the existing 2% sequestration cut. For a primary care physician billing $400,000 in annual Medicare revenue, that additional 4% cut would mean roughly $16,000 in lost annual revenue. For a practice with ten physicians, that's $160,000 in lost revenue that won't materialize now.

The CR waives this statutory Pay-As-You-Go requirement, protecting your payments from compounding reductions. The existing 2% sequestration cut remains in effect (a separate issue), but you're protected from the additional hit that would have occurred January 1.

The Work Geographic Practice Cost Index Floor: Why Rural Practices Should Care

The CR temporarily restores the 1.0 work geographic practice cost index (GPCI) floor nationwide through January 30, 2026. If you operate in a lower-cost-of-living area—common in many mountain communities and rural regions—this matters significantly.

The work GPCI adjusts Medicare payment rates based on regional wage levels. Without the 1.0 floor, practices in low-cost areas see reduced reimbursement rates compared to urban centers. By restoring the floor, the CR ensures that your practice's reimbursement doesn't get further compressed based on regional economics alone. This is particularly important for practices trying to recruit and retain clinical talent in competitive markets.

The Safety-Net Programs That Support Your Patients

While not directly affecting your practice's billing, several safety-net programs were extended through January 30, 2026. These programs support your patients and the communities you serve:

Community Health Centers: $1.4 Billion in Continuity

Community Health Centers account for over 70% of CHC operational funding. The CR provides $1.4 billion from October 1, 2025, through January 30, 2026. If your practice refers to or coordinates care with CHCs, this funding stability means continued access for your uninsured and underinsured patients. You can rely on these partners to maintain staffing and service levels through the first month of 2026.

The National Health Service Corps: Supporting Your Workforce

The NHSC funds scholarships and loan repayments for health care workers serving high-need areas. If you're trying to recruit primary care physicians, nurse practitioners, or physician assistants to underserved regions, NHSC-supported recruitment continues through January 30, 2026.

Teaching Health Center Graduate Medical Education: Building Your Future Pipeline

The THCGME program funds primary care residency training in community-based settings. If you're part of an academic practice or considering involvement in graduate medical education, this program's extension preserves funding for developing tomorrow's physicians.

Special Diabetes Program: Chronic Disease Management Continuity

Both Type 1 diabetes research through the NIH and diabetes prevention programs for Native American communities received funding extensions. If your practice serves communities disproportionately affected by diabetes, this funding stability supports the public health infrastructure that complements your clinical care.

Critical Action Items for Your Practice NOW

1. Establish Your Retroactive Claims Process

During the shutdown, telehealth claims from October 1–November 12 couldn't be processed. Now they can. However, Medicare Administrative Contractors (MACs) have varying timelines for reopening and reprocessing these claims.

Action: Contact your MAC this week to understand:

• Their reprocessing timeline for shutdown-period telehealth claims

• Whether you need to resubmit or if claims will be automatically reprocessed

• Any special documentation requirements for shutdown-period services

• The expected timeline for payment of retroactive claims

Your revenue cycle manager should create a tracking spreadsheet of all telehealth claims submitted during October 1–November 12 to ensure they're successfully reprocessed.

2. Audit Your Telehealth Billing Compliance

Many practices made operational changes during the shutdown, assuming telehealth coverage had lapsed. Now that it's been restored retroactively, you need to ensure your billing is compliant with Medicare telehealth rules.

Action: Review:

• Are you properly documenting originating site (patient location) for each telehealth visit?

• Are you using the correct Place of Service (POS) codes (02 for telehealth)?

• Are you excluding services that were never telehealth-eligible?

• Are your modifiers accurate (GT or 95 for Medicare telehealth)?

Consider requesting a compliance audit from your revenue cycle management consultant or your MAC's Beneficiary and Family Centered Care (BFCC) office.

3. Communicate with Clinical Staff About Behavioral Health Changes

The in-person visit requirement for behavioral health telehealth (six months prior to first telehealth visit, then annually) is delayed until January 30, 2026. Your behavioral health and primary care teams need to understand this timing because:

• Patients on established behavioral telehealth will need in-person encounters scheduled by late January

• New behavioral health telehealth patients will need baseline in-person evaluations scheduled now if they're to receive telehealth follow-up through January 30

Action: Hold a staff meeting with your behavioral health, primary care, and scheduling teams to:

• Review the current telehealth rules for behavioral health

• Develop a patient communication strategy about upcoming requirement changes

• Create a scheduling protocol to ensure compliance before the deadline

4. Prepare for January 30, 2026: The Next Cliff

This is critical: January 30, 2026, is approximately two months away. Congress will need to address these temporary extensions again during what will likely be contentious negotiations over broader government funding.

Action: Begin scenario planning now:

• What is your operational plan if telehealth waivers expire again?

• Which patients rely most heavily on telehealth services?

• What alternative care delivery models can you implement if telehealth coverage lapses?

• Should you adjust staffing plans for late January?

Don't wait until mid-January to start this conversation.

The Bigger Picture: What Wasn't Included (And What You Should Watch)

Enhanced ACA Premium Tax Credits: Expiring December 31, 2025

The CR does NOT extend the enhanced Affordable Care Act premium tax credits that currently help approximately 22 million Americans afford health insurance. These credits expire on December 31, 2025—just over six weeks away.

Without extension, premiums for individual market insurance will increase dramatically for millions of patients. Your practice will likely see:

• More uninsured patients as coverage lapses

• Increased requests for cash payment plans or charity care

• Higher no-show rates from patients struggling with healthcare affordability

• Greater complexity in patient eligibility verification

What to Watch: Senate Republicans have committed to a vote on extending ACA credits by mid-December. Monitor Congressional actions closely. If credits aren't extended, your practice should prepare financial assistance and charity care protocols.

Telehealth's Permanent Status Remains Uncertain

All telehealth flexibilities remain temporary, requiring Congressional action again before January 30, 2026. This creates ongoing operational uncertainty:

• Your strategic plans for telehealth expansion have an artificial deadline

• Staff planning assumes potential service disruptions

• Technology investments may need rapid adjustment

• Patient communications become more complex

Clinical Laboratory Fee Schedule: The PAMA Moratorium Question

The CR extends the moratorium on Clinical Laboratory Fee Schedule (CLFS) payment cuts. Without action, up to 15% payment reductions affecting approximately 820 test codes would take effect in 2026. If you operate an in-house laboratory or send significant volumes to affiliated labs, monitor this closely.

Revenue Cycle Implications for Your Team

Your RCM team should focus on these specific operational adjustments:

Claim Submission: Ensure all telehealth claims from October 1–November 12 are submitted or resubmitted with proper documentation and Place of Service codes.

Payer Follow-Up: Develop a tracking system for denied claims during the shutdown period. Insurance companies may have coding issues or documentation deficiencies that prevented initial processing.

Documentation Review: Implement spot-checks on telehealth visit documentation to ensure compliance with Medicare's originating site, provider type, and service type requirements.

Denials Management: Create a specific queue for shutdown-period claim denials to understand patterns (payer issues vs. billing errors).

Revenue Recognition: Work with accounting to properly recognize retroactive telehealth revenue in the appropriate accounting period while maintaining accurate aging of accounts receivable.

Payer Contracting: Review your commercial payer contracts for telehealth payment terms. If commercial payers have aligned their telehealth policies with Medicare's temporary waivers, you need to understand the implications of those policies potentially changing after January 30.

Strategic Considerations for Practice Leadership

Short-Term (Through January 30, 2026): Focus on maximizing telehealth revenue while it's available, ensuring billing compliance, and recovering any shutdown-period claim denials.

Medium-Term (Late January 2026): Prepare contingency plans for potential telehealth lapse or modification. Develop patient communications and operational workflows that can adapt quickly.

Long-Term (2026 and Beyond): Advocate for permanent telehealth authorization through professional associations and direct Congressional engagement. The back-and-forth uncertainty is operationally expensive and creates clinical discontinuity.

Key Takeaways

1. Telehealth flexibilities are restored retroactively from October 1, 2025, through January 30, 2026, giving your practice immediate operational clarity.

2. Payment protections prevent an additional 4% sequestration cut and maintain the work GPCI floor, protecting your revenue.

3. Retroactive claims processing is beginning immediately, but your practice must actively manage resubmission and follow-up.

4. January 30, 2026, creates the next deadline, requiring scenario planning and contingency development now.

5. Safety-net programs remain funded, preserving community health infrastructure that supports your patient populations.

6. Enhanced ACA credits expire December 31, 2025, creating potential patient affordability challenges for your practice.

7. Operational readiness requires immediate action on compliance audits, staff communication, and contingency planning.

Questions Your Team Should Be Asking

• Has our MAC clarified the reprocessing timeline for shutdown-period telehealth claims?

• Are our Place of Service codes and modifiers correct for all telehealth billing?

• What is our plan if telehealth waivers expire again on January 30, 2026?

• How will the December 31 ACA credit expiration affect our patient population and collections?

• Are we maximizing telehealth for appropriate patients while the authority is available?

• Do our clinical staff understand the behavioral health in-person requirement timeline?

Next Steps

This Week:

• Contact your MAC about the shutdown-period claim reprocessing

• Schedule a compliance audit for telehealth billing

• Review behavioral health patient rosters

This Month:

• Hold a staff meeting on telehealth requirements

• Develop contingency plans for the January 30 deadline

• Begin scenario planning for ACA credit expiration

Ongoing:

• Monitor CMS updates on telehealth guidance

• Track Congressional actions on permanent telehealth authorization

• Prepare for potential changes in payment policy

About Revelmed

Revelmed specializes in revenue cycle management and workflow optimization for medical practices. We help practice management and clinical leadership navigate complex healthcare policy changes, optimize billing operations, and ensure compliance with evolving Medicare and payer regulations. If your practice needs specialized guidance on maximizing telehealth revenue, managing retroactive claims, or preparing contingency plans for future policy changes, our team can help.