In response to the current state of affairs in Washington DC, CMS has provided updates over the past two days related to guidance on claim holds. Yesterday, 10/16/25, they posted further clarification to their 10/15/25 MLS Matters on their website:
“Effective October 1, 2025, CMS instructed all Medicare Administrative Contractors (MACs) to hold claims with dates of service of October 1, 2025, and later for services impacted by the expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025. In light of the continuing government shutdown, CMS will continue to process and pay held claims in a timely manner with the exception of select claims for services impacted by the expired provisions. To date, no payments have been delayed as statute already requires all claims to be held for a minimum of fourteen days, and this recent hold is consistent with that statutory requirement. Providers may continue to submit claims accordingly.”
While we are still trying to understand the full impact of this additional guidance, and the meaning of the wording being slightly different from what we shared yesterday, we interpret CMS' communication from today to be a clarification that MACs are instructed to pay Part B claims except for services affected by expired provisions in law; those expired provisions would include care delivered via telehealth and services delivered in areas subject to the expired Work GPCI. Specifically, in the message above, CMS refers to ‘expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025’ and we are interpreting this to mean the telehealth authority and the 1.0 floor for the Work GPCI. We believe this change will allow other Part B claims to be paid, like portable x-ray transportation (because it does not need a GPCI) or Part B services in a locality where the Work GPCI exceeds 1.0 and so is not subject to the 1.0 floor Work GPCI.
Further, we believe that CMS will pay Part A claims (with the exception of Medicare dependent hospitals), and that the expired provisions should not affect Skilled Nursing Facilities on the Part A side.
We are continuing to monitor this situation closely and will provide updates as information becomes available-we appreciate and value your partnership and are committed to supporting you as well as our clinicians during this challenging time.
Please reach out to AskRegulatory@PowerbackRehab.com or your Clinical/Operations leadership with questions.
Resources:
https://www.cms.gov/medicare/payment/fee-for-service-providers
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