Impacts of the Federal Government Shutdown on Home Health and Hospice Providers

The U.S. government is officially shut down as Congress did not reach agreement on a continued funding bill. The Alliance is offering the following guidance:

Telehealth Impacts

Telehealth flexibilities for home health and hospice providers expired on September 30, including those applicable to the face-to-face (F2F) encounter. Hospices and home health agencies must ensure that all F2F encounters on and after October 1, 2025, are in-person encounters in order to comply with Medicare coverage requirements. The Alliance recognizes the adverse impacts the lack of telehealth flexibilities has on patients and providers. Prior to the expiration of these flexibilities, the Alliance requested that CMS proactively provide guidance to home health agencies and hospices that it will exercise enforcement discretion related to the required face-to-face encounter until the telehealth waivers can be extended by Congress. No such guidance was provided. It is possible that Congress will eventually extend the telehealth flexibilities retroactively to October 1, 2025. However, there are specific timing requirements for the encounter in both home health and hospice, and providers must observe the requirements that are in place at the time the encounter is conducted. Telehealth policies for Medicaid are contingent on the state and not addressed in or impacted by the shutdown.

Medicare and Medicaid Reimbursements Continue

Medicare claims are expected to be processed and paid, as Medicare and Medicaid are mandatory programs whose funding isn’t subject to annual appropriations. It is expected that Medicaid will maintain its payments to states. The Centers for Medicare & Medicaid Services (CMS) will continue processing Medicare claims. Although CMS did state in an MLN Connects Special Edition newsletter on October 1, 2025 that when certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact on providers due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted. Since government shutdowns impact federal, and not state, agencies, state Medicaid agencies should remain open and functional, and providers should be able to continue engaging with staff at the administration. Although states should be available for routine business, some delays to other aspects of operations could result from the lack of CMS staff to support state plan amendment and waiver processing or to answer State questions about policy and operational requirements.

Quality Reporting

CMS is instructing providers to continue reporting as they have been, and any changes will be communicated through the Quality Reporting Program channels. The quality program helpdesk responses will be delayed.

Surveys

Medicare certification and recertification surveys for home health and hospice providers could be impacted and some may not occur. Complaint surveys may occur, depending on severity and if the state or CMS determine that a survey is necessary for patient safety.

Other Programs

Programs which are not mandatory spending and subject to annual appropriations, such as the Older Americans Act and the Social Services Block Grant, may see lapses and reduced or paused service provision. Though these programs are substantially smaller in size and scope, they do provide valuable home care support to individuals in the community, and an impact may be felt.

Potential for Administrative Delays

With reduced CMS staffing, providers may face delays in Medicare and Medicaid enrollments, appeals processing, and other administrative functions. A shutdown could also slow down the release of the CY 2026 home health final rule. The rule is normally expected to be posted by November 1 with a January 1 effective date.

Here’s the link: Care at Home Impacts of a Government Shutdown – National Alliance for Care at Home | National Alliance for Care at Home

At MAC Legacy, our team of experts provides education, consulting, and compliance support to help home health and hospice agencies stay aligned with ever changing regulations while continuing to deliver quality patient care.