What You Need to Know about the Government Shutdown

On October 1, 2025, we entered a federal government shutdown, and all signs currently point to this shutdown being prolonged.

During a shutdown, discretionary spending is halted, which disrupts several government functions. While funding for Medicare is non-discretionary, and therefore continues during the shutdown, there are significant impacts on staffing levels, affecting many Medicare operations. Combined with this shutdown, several important Medicare policies have expired and require Congressional action to reinstate.

In this blog, we will walk you through what the shutdown and the expired policies mean for your reimbursement and how they impact Medicare value-based care programs.

Impact on Quality Programs

This section covers direct impacts on the Medicare Quality programs. There are also indirect impacts from changes to reimbursement and a lapse in funding for several other CMS programs.

Medicare 2026 Quality Rules Will Likely Be Delayed

In order for the rules that inform us of the 2026 quality program requirements to be published, we need review staff from the Office of Management and Budget (OMB) and policy staff from CMS. Although most of OMB seems to be working, 47% of CMS staff are furloughed, which includes many CMS policy staff. CMS states that "with limited staff to review and provide operational support, we would expect delays in rule-making and other policy development.” As a result, the release of the 2026 QPP and ASCQR Final Rules will likely be delayed. 

Although it is unclear when the rules will be published, we anticipate that they will still go into effect on January 1, 2026. This gives us limited time to prepare for and implement the 2026 requirements. The last time the QPP Final Rule was delayed was in 2020, during the COVID-19 Public Health Emergency. The 2021 QPP Final Rule was issued by CMS on December 1, 2020, and published to the Federal Register on December 28, 2020. Although the rules are required to be issued 60 days before the start of the next calendar year, the effective date of the 2021 QPP Final Rule was still January 1, 2021.

Slowdowns in Support Services and MIPS Targeted Reviews

Both providers and patients can expect slowdowns in support services, such as call centers and help desks due to furloughed staff. CMS has confirmed that QPP help desk responses will be delayed.

We can also expect an impact on MIPS targeted reviews for the 2024 performance year. These will likely be delayed due to the limited professional staff available to review them.

ASTP/ONC Website Down 

The Assistant Secretary for Technology Policy/Office of the National Coordinator (ASTP/ONC) website, HealthIT.gov, is currently unavailable due to the shutdown. This means that anything that would normally be accessed through this website is unavailable. Some pages and features on the ASTP/ONC website are particularly important for the MIPS Promoting Interoperability (PI) category requirements, including the following:

• Checking EHR certification status through the Certified Health IT Product List (CHPL)
• Reviewing information blocking FAQ
• Submitting information blocking claims
• Accessing the High Priority Practices SAFER Guide
• Viewing USCDI data element lists
• Accessing the free ASTP/ONC Security Risk Assessment Tool

Funding for Medicare Quality Measures

Congress provides funding to CMS to support the selection and endorsement of quality measures for Medicare. Previously, this was accomplished through the Consolidated Appropriations Act, which provided $9 million through December 31, 2024, and the American Relief Act, which provided $2 million through March 31, 2025. If additional funding is not secured, quality measures in Medicare programs like MIPS could be affected.

Impacts on Physician Reimbursement

Medicaid and Children’s Health Insurance Program (CHIP) Funding

CMS has stated that it will be able to fund Medicaid through the first quarter of 2026. Additionally, CMS will maintain the staff needed to provide payments to eligible states for CHIP.

Impact on Medicare Advantage

We don’t anticipate that the shutdown will affect Medicare Advantage payments, as these plans receive a mandatory risk-adjusted capitated payment each month directly from the U.S. Department of the Treasury.

Reimbursement for Medicare Claims

On October 1, 2025, CMS issued a newsletter stating that they have directed all Medicare Administrative Contractors (MACs) to put a temporary hold for 10 business days on all Medicare claims. Providers can continue submitting claims during this time; however, they will not receive payment until the hold is lifted. Given that MACs, by law, cannot pay electronic claims until 14 days after receiving the claim, this should not pose a significant burden on physicians.

Although there are concerns that a prolonged shutdown of greater than 30 days would increase the likelihood of MACs running out of funding, we note that Medicare reimbursements are supported by mandatory funding, not annual appropriations. As such, CMS anticipates that “Medicare claims will continue to be paid, but Medicare will not be providing oversight of the Medicare Administrative Contractors (MACs) who pay these claims.” We do anticipate, however, that claims processing will experience delays in the case of a prolonged shutdown.

Expiration of Telehealth Flexibilities

The Medicare fee-for-service telehealth flexibilities that were established during the COVID-19 Public Health Emergency (PHE) expired on September 30, 2025. This means that as of October 1, 2025, in order to be reimbursable, telehealth visits must meet the pre-COVID-19 PHE requirements, including the following:

• Geographic and Originating Site Requirement: As of October 1, 2025, the patient’s home is no longer considered an “originating site.” For non-behavioral or mental health services, patients can only receive care from specific sites, such as a provider’s office or hospital.
• No More Audio-Only Telehealth: Audio-only telehealth visits are no longer reimbursable unless they are for behavioral or mental health.
• In-Person Visit Requirement: Patients receiving behavioral health telehealth services must first have an in-person visit and continue to have an in-person visit at least once every 12 months.

For telehealth services that do not meet the criteria to be covered, CMS recommends that providers consider using an Advance Beneficiary Notice of Noncoverage (ABN) before delivering the service to inform patients that Medicare is unlikely to provide coverage.

Medicare Shared Savings Program Accountable Care Organizations (ACOs) will continue to be reimbursed for covered telehealth services. Additionally, many Medicare Advantage plans, such as Aetna and United Healthcare, are continuing to offer payment for expanded telehealth services. Medicaid plans may also continue to offer expanded telehealth services. We recommend checking with specific plans to see if they are continuing coverage.

Impact on MIPS

Because the impacts on telehealth visits are related to reimbursement and not coding, we do not anticipate that MIPS measures will be affected.

However, if these telehealth services do not end up being retroactively covered and are therefore not “covered professional services,” there is a chance that providers who deliver a large amount of telehealth and are already close to the low-volume threshold may no longer be eligible for MIPS.

Impact on Medicare Reimbursement in Low-Cost and Rural Areas

Medicare payments to physicians are adjusted using work geographic practice cost indices (GPCIs). These are geographic adjustment factors that Medicare uses to modify physician fee schedule payments based on geographic variations in the cost of providing care.

Think of GPCIs as CMS’ way of acknowledging that practicing medicine in Manhattan costs significantly more than practicing in Wisconsin.

There are different GPCIs for different Medicare cost components; the one impacted by an expired policy on September 30, 2025, is the Work GPCI (physician labor costs). The policy that expired was a 1.0 floor for the GPCI work component, meaning that no one would have a downward geographic adjustment on their work reimbursements.

Congress has previously passed numerous extensions to the 1.0 floor, but they never made the floor permanent. Thus, with its expiration, clinicians in low-cost and rural settings will be impacted by lower Medicare payments. Specifically, this impacts 51 of the 109 Medicare localities.

Click on the dropdown below to see the 51 localities impacted by the expiration of the GPCI work floor.