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Telehealth claims submitted during the federal government shutdown that began on October 1, 2025, remain in a prolonged holding pattern. CMS has not yet issued updated processing guidance, leaving Medicare Administrative Contractors uncertain about how to handle telehealth services, especially mental and behavioral health visits. As a result, many practices are experiencing returned claims, delayed processing, and inconsistent instructions across different MAC regions.

> Current Billing Challenges

The primary disruption centers on documentation and coding requirements. Many telehealth claims are being returned for additional details, while others are held without clear direction. Providers are seeing slower remittances and rising AR aging, which is putting pressure on revenue cycle workflows. Behavioral health telehealth services are being scrutinized the most due to evolving flexibility rules and documentation expectations.

> Operational Impact

These delays are increasing the administrative workload, as billing teams must review returned claims, verify coding accuracy, and prepare corrections without knowing when resubmissions will be allowed.
Key operational pressures include:

〉Increased time spent communicating with MACs

〉Heightened QA review load

〉Temporary process changes across billing and clinical teams

> Financial Implications

The extended processing slowdown is directly affecting cash flow, particularly for providers with a high telehealth volume. Aging AR buckets are expanding, and revenue forecasts are becoming more difficult to predict. The longer CMS takes to finalize its guidance, the more pressure practices will feel on liquidity and monthly targets.

> Documentation Hotspots

Several documentation elements are repeatedly triggering returns and delays. Billing teams should pay close attention to:

〉Telehealth modality (video or audio-only)

〉Patient consent requirements

〉Provider credentials and location

〉Start/stop times for time-based visits

Ensuring these details are accurately captured will reduce denials once CMS reopens normal processing.

> What Billing Teams Should Do Now

A practical short-term strategy is to track all telehealth claims submitted during the shutdown period and review them for any documentation gaps or coding inconsistencies. Many MACs have advised holding corrected claims for now. Recommended steps include:

〉Tagging all telehealth claims from the shutdown period

〉Performing documentation and modifier checks

〉Preparing corrected claims for immediate resubmission later

〉Reinforcing telehealth documentation standards with providers

> Looking Ahead

Updated guidance is expected to apply retroactively, which means organizations may need to correct or resubmit claims once CMS clarifies its rules. Maintaining strong documentation practices and organized tracking systems now will minimize the risk of denials and ensure a smoother transition when processing resumes.

> Impact on Patient Experience

While these delays occur behind the scenes, they can still influence the patient experience. Longer billing cycles can create confusion for patients who receive delayed statements or unexpected insurance responses. Clear communication with patients, especially for behavioral health visits, can help maintain trust and reduce callback volume while the industry navigates this temporary uncertainty.

> Expectations for Early 2026

If CMS follows historical patterns, final telehealth processing guidance may arrive early in Q1 of 2026. Organizations prepared with clean documentation and ready-to-submit corrections will be able to move quickly once updates are released.
What to anticipate:

〉Retroactive adjustments to previously submitted claims

〉Clarified rules for audio-only vs. video telehealth

〉Potential modifiers or POS updates tied to behavioral health

> RCM Strategy Considerations

As telehealth policies continue to shift, this is a key moment for RCM leaders to reassess internal processes. Strengthening QA steps for digital-health claims, improving communication loops between billing and clinical teams, and reviewing payer-by-payer telehealth trends will help stabilize performance ahead of CMS updates.

> Preparing Providers for Changes

This is also the right time to brief providers on what to expect. Offering simple reminders and quick-reference documentation guides can reduce errors and confusion.
Helpful provider reminders:

〉Capture telehealth consent consistently

〉Document visit modality clearly

〉Ensure time-based details are complete

〉Maintain accurate patient location verification

Contact us today at info@evocarebillings.com or call (323) 412-5399 to explore how we can help your practice grow with smarter, more efficient billing solutions.