Medicare FFS Telehealth Policy During the Federal Government Shutdown (Effective October 1, 2025)

Last Updated: October 8, 2025

Beginning October 1, 2025, the expanded Medicare telehealth flexibilities expired as a result of the federal government shutdown. See below for the changes that are currently in effect.

It’s important to note that this policy change applies only to Medicare FFS. Medicare Advantage, Medicaid, and commercial telehealth rules remain unchanged. View the Medicaid Telehealth Policy Manual here.

Background

The expanded Medicare telehealth flexibilities that began during the COVID-19 Public Health Emergency (PHE) expired on October 1, 2025 because of the federal government shutdown. These are the same restrictive rules that were in effect prior to the COVID PHE.

Once the shutdown ends, CMS is expected to reinstate the telehealth flexibilities, but it is unclear whether those flexibilities will be applied retroactively to services delivered on or after October 1.

In the meantime, Medicare is advising providers to hold claims for telehealth services delivered on or after October 1 to avoid denials that may later become payable once the flexibilities are reinstated.

Health centers can still deliver telehealth during this period, but Medicare FFS will not reimburse most medical telehealth services while the shutdown is active.

Download PDF of chart here.

FAQ

1. Can health centers still provide telehealth to Medicare FFS patients during the shutdown?

Yes. There is no legal prohibition on providing telehealth. The restriction is only on reimbursement. Services delivered outside the allowable conditions (for example, medical telehealth to a patient at home in NYC) will not be reimbursed by Medicare FFS during the shutdown.

2. Does this apply to Medicare Advantage, Medicaid, or commercial plans?

No. This guidance applies only to Medicare Fee-for-Service.
Medicare Advantage plans, Medicaid, and commercial payers each follow their own telehealth policies, which remain unchanged during the shutdown. View the Medicaid Telehealth Policy Manual here.

3. What counts as a “behavioral health telehealth” service?

For FQHCs, Medicare classifies a telehealth visit as behavioral health or medical based on the G-code billed, which is determined by the underlying CPT codes used for the visit.

Behavioral health telehealth visits are billed using G0469 (new patient) or G0470 (established patient). These G-codes are used when the visit is for the diagnosis, evaluation, or treatment of a mental health disorder and correspond to the following CPT codes:

90791 – Psychiatric diagnostic evaluation
90792 – Psychiatric diagnostic evaluation with medical services
90832 – Psychotherapy, 30 minutes
90834 – Psychotherapy, 45 minutes
90837 – Psychotherapy, 60 minutes
90839 – Psychotherapy for crisis, initial 60 minutes
90845 – Psychoanalysis

If a provider bills an E/M code (for example, 99213 for medication management), that CPT code rolls up to a medical G-code (G0467) rather than a behavioral health G-code. In that case, Medicare will treat it as a medical telehealth visit, which does not qualify for behavioral health telehealth flexibilities.

4. What are the rules for the in-person visit requirement for behavioral health?

For patients new to tele-behavioral health (starting Oct 1 or later), Medicare requires an in-person visit with the same provider or a member of the same clinical team within the 6 months prior to the first telehealth appointment.
For patients already receiving tele-behavioral health, the required in-person visit must occur within 12 months.

This applies to all behavioral health telehealth services, including those provided by psychiatrists using E/M codes.

5. What are the rules for audio-only behavioral health?

Audio-only telehealth for behavioral health is still permitted when video is not available or not feasible for the patient, as long as the service otherwise meets Medicare telehealth requirements. This applies in both rural and urban settings.

6. What should we do with claims for telehealth visits after October 1?

Medicare has advised providers to hold claims for telehealth services delivered during the shutdown to avoid denials. Once the shutdown ends, CMS may retroactively reinstate telehealth flexibilities, but this has not been confirmed.

7. Where can I read more official guidance?

Key Takeaways

This applies to Medicare FFS only.
Urban health centers cannot receive reimbursement for medical telehealth during the shutdown.
Behavioral health telehealth remains allowed (home permitted, audio-only allowed, in-person cadence applies).
Certain rural sites may still bill for medical telehealth if the patient is physically on site.
CMS is expected to reinstate telehealth flexibilities after the shutdown, possibly retroactively.

Topics

Medicare

Current:

Medicare FFS Telehealth Policy During the Federal Government Shutdown (Effective October 1, 2025)

Medicare FFS Telehealth Policy During the Federal Government Shutdown (Effective October 1, 2025)