Shutdown Over: Medicare Telehealth Is Back Through January 30. Fix the Claims

On Monday, November 10, 2025, the Senate passed the Continuing Appropriations Act, 2026 by a vote of 60 to 40. The House cleared it on Wednesday and the President signed it that night, November 12, ending a shutdown that ran 43 days, the longest in the country's history. Buried in the bill are the Medicare extenders that lapsed on October 1, including the telehealth flexibilities, restored retroactively to October 1, 2025 and running through January 30, 2026, the same day the new funding expires.

So we are back where we were on September 30, with a new cliff eleven weeks away and six weeks of claims to untangle. CMS has said publicly that telehealth services furnished during the shutdown will be paid the way they were paid before October 1, as if the lapse had not happened. The detailed claims processing instruction to the MACs had not been posted as of this writing, and we expect it within days. This article is about the untangling you can start before it lands. The politics can wait.

Key takeaways

• The law restores, from October 1 through January 30, 2026, the full set of telehealth flexibilities plus the 1.0 work GPCI floor, the ground ambulance add-ons, the Acute Hospital Care at Home waiver and the other Medicare extenders that lapsed.
• Shutdown-period Medicare claims fall into five groups: held, paid at the wrong rate, returned on or after November 6 with CARC 16 and RARC M77, resubmitted with the GY modifier, and never submitted. Each needs a different action.
• Any Medicare patient who paid for a video visit that is now retroactively covered is owed a refund of everything above the applicable cost sharing.
• Do not resubmit claims that are sitting in the MAC hold. Duplicates slow everything down.

What was restored, and until when

The law extends, through January 30, 2026, the same set of flexibilities that lapsed: the patient's home as an originating site and no geographic restriction for non-behavioral telehealth; audio-only where the patient cannot or will not use video; physical therapists, occupational therapists, speech-language pathologists and audiologists as distant-site practitioners; FQHCs and RHCs as distant sites; the delay of the in-person visit requirement for telehealth mental health services; telehealth for the hospice face-to-face recertification; and the Acute Hospital Care at Home waiver. Because the extension is retroactive to October 1, every telehealth visit furnished during the shutdown under the old flexibilities is now payable as if nothing had happened.

The non-telehealth extenders came back too. The 1.0 work GPCI floor is restored through January 30, which matters because the MACs began paying physician fee schedule claims on October 21 using the pricing that was available to them, without the floor. Practices in the affected localities were paid slightly less than they should have been on October dates of service, and those claims will need to be adjusted.

Where the shutdown-period claims stand today

Here is the timeline that produced the mess. On October 1, CMS told the MACs to hold physician fee schedule, ground ambulance and FQHC claims with October dates of service. On October 21, CMS lifted that hold for everything except non-behavioral telehealth and Acute Hospital Care at Home claims, which stayed on hold. On November 6, with no end to the shutdown in sight, CMS instructed the MACs to return a subset of telehealth claims submitted on or before November 10 that were not payable under the law as it stood. Professional claims came back with claim adjustment reason code 16 (claim lacks information or has a submission or billing error) and remittance advice remark code M77 (missing, incomplete or invalid place of service). CMS told practitioners who wanted a formal denial with appeal rights to resubmit those claims with the GY modifier. Then, on November 12, the law changed.

The returns are the confusing group. A returned claim is not a denial; it carries no appeal rights and it never entered the payment history. It is simply a claim the MAC handed back, which means the practice has to send it again. A practice that did not notice the CARC 16 returns in early November, because they look like clearinghouse noise, has claims that will never pay unless someone finds them. Pull every Medicare remittance since November 6 and filter for CARC 16 with M77.

The patient refund problem

Some practices collected from Medicare patients for video visits during the shutdown, either under an Advance Beneficiary Notice or, less carefully, as self-pay. Those services are now covered by Medicare retroactively, and a Medicare beneficiary cannot be charged more than the applicable deductible and coinsurance for a covered service. The practice must submit the claim and refund the patient any amount collected beyond the Medicare cost sharing once the claim adjudicates. This is not optional, and we expect CMS to say so explicitly in its processing instruction. A Medicare beneficiary who paid $110 for a covered service is owed the difference between what they paid and the coinsurance and deductible that apply.

Build the list now: every Medicare patient payment posted against a telehealth visit with a date of service from October 1 to November 12, the amount, and the visit. Submit the claim, wait for the remittance, then refund the excess with a short letter explaining why. Most practices we work with have between zero and a few dozen of these. If you have hundreds, you built a shutdown revenue strategy around patient pay, and this is the bill.

The reconciliation, step by step

1. Pull the tagged list of Medicare telehealth claims with dates of service October 1 to November 12. If you did not tag them, filter by POS 02 and POS 10 and modifier 95 for Medicare Part B.
2. Split the list by current status: paid, held (submitted, no remittance), returned (CARC 16 with M77), resubmitted with GY, or never submitted.
3. Submit the never-submitted group this week. Timely filing is twelve months from the date of service, so there is no deadline pressure, but cash is cash.
4. Hold the returned and GY groups until your MAC posts its instruction, then resubmit them in one batch without GY. Expect that within days.
5. For the held group, watch remittances for the next three to four weeks and clear the tag as each one pays.
6. For the paid group, check the allowed amount against the 2025 fee schedule with the GPCI floor. Anything short is a candidate for the MAC's adjustment; note it and wait rather than appeal.
7. Run the patient refund list and work it after the claims adjudicate.
8. Reset the front desk: video visits from home are payable again for Medicare through January 30. Reopen the video slots you closed in October, and tell the patients you converted that they can choose again.

A practice with 180 shutdown-period Medicare video visits will typically find 100 or so in the held group, 40 to 60 in the returned group, a handful with GY, and a dozen never sent. The held group takes care of itself. The rest is two days of work for one biller, and it is worth about $19,000 to the practice in our example, so do not let it wait until January.

What we think about the January 30 cliff

Honestly, we expect another extension and another scramble. Congress has extended these flexibilities repeatedly since 2022 and has now let them lapse once. The pattern is that they get attached to whatever funding vehicle is moving. What practices should not do is spend the next eleven weeks pretending it will not happen again. Keep the tagging habit. Keep the in-person conversion plan in a drawer. Keep the ABN decision written down. If the flexibilities lapse on January 31, you will have done this before and it will take a morning instead of a month.

Questions we hear

Our MAC has not released the held claims yet. Should we resubmit them?

No. Resubmitting a claim that is already in the MAC's queue creates a duplicate rejection and slows both down. Resubmit only what came back with CARC 16 and M77, what was denied with GY, or what you never sent, and wait for the MAC's instruction on the first two. Give the held claims until early December.

Do Medicare Advantage plans have to pay these visits?

MA plans were given flexibility to keep covering telehealth during the shutdown and most did. Any MA plan that denied a telehealth visit for originating site during October or November should be asked to reprocess, citing the plan's own shutdown guidance and the restored law.

Did anything else change in the funding law?

Several other Medicare extenders that lapsed on October 1 were restored through January 30 as well, and three of the twelve appropriations bills were passed for the full year. For the revenue cycle, telehealth and the GPCI floor are the pieces that matter. Our billing team is building the resubmission lists this week, and our Revelrex EHR training environment includes shutdown-period telehealth scenarios for teams who want to practice the reconciliation before doing it on live claims.

What to do this week

1. Pull the shutdown-period Medicare telehealth list and split it into the five groups in the table.
2. Filter every Medicare remittance since November 6 for CARC 16 with RARC M77 and build the resubmission batch.
3. Submit anything you never sent.
4. Build the patient refund list from payments posted against October and November telehealth visits.
5. Reopen Medicare video slots and put a calendar note on January 20 to check whether Congress has acted on the January 30 date.