Yesterday CMS posted QSO-26-01, which describes revised plans for State Surveys in the event of a Federal Government shutdown, as well as updated guidance on Claims Hold and Telehealth.

Survey Activities During a Shutdown:

• Surveys NOT affected by the shutdown: State funded surveys, surveys of Medicaid only facilities, and hospice surveys

• Surveys PROHIBITED during a Federal Government shutdown: Standard surveys, non-emergency re-visit surveys, initial surveys, initial certifications, non-emergency Medicare complaint investigations, IDR’s

• Surveys EXCEPTED and therefore PERMITTED during the shutdown: Complaint investigations and reported incidents alleging harm and their resultant enforcement actions, revisit surveys necessary to prevent termination, immediate threats to life or safety, other tasks that were begun prior to Sep 30, 2025, that requires orderly shutdown

For more information on Survey information, please visit: https://www.cms.gov/files/document/qso-26-01-all-revised-2025-10-21.pdf

Claims Hold:

CMS instructed all MACs to lift the claims hold and process claims with dates of service of October 1, 2025, and later for claims paid under the Medicare Physician Fee Schedule.

Telehealth:

Due to the government shutdown, the extension of Medicare telehealth for PT, OT, and ST services has not been extended. 

It is important to note that as long as your state allows telehealth provision, telehealth may still be provided by therapists for other payers, however, payment by Medicare, specifically Medicare B, cannot be guaranteed. 

CMS has instructed MACs to HOLD any PT,OT, ST Medicare telehealth claims that were provided after Sep 30,2025, and retroactive payment cannot be guaranteed.

CMS strongly recommends that therapists who choose to provide telehealth after October 1, 2025, give their beneficiaries an 

ABN: Advance Beneficiary Notice (CMS R-131 form for Med B) PRIOR to the provision of therapy services, and maintain a copy on file. 

For more information on ABN Forms, please visit:

https://www.cms.gov/medicare/forms-notices/beneficiary-notices-initiative/ffs-abn

If you have questions, or need additional information, please email us at: Medicarequestions@enhancetherapies.com