Impacts of a Government Shutdown

Telehealth Impacts

If a continuing resolution is not passed, telehealth flexibilities will expire on September 30. This may mean reviewing all the F2F encounter due dates within the hospice F2F encounter timeframe which is 30 days prior to the third or subsequent benefit period. If the due date falls within the 30 day period after September 30 (October 30) and the hospice wishes to utilize telehealth for the encounter, organizations may want to have it completed no later than September 30. 

The F2F encounter due date may be more difficult to anticipate in home health, but if agencies are aware of any encounters that are needed prior to the home health encounter timeframe – 90 days before or 30 days after the start of care – where the practitioner would like to utilize telehealth to complete the encounter, the agency may want to make the practitioner and patient aware of the telehealth flexibilities expiration date so they can plan accordingly. 

Telehealth policies for Medicaid are contingent on the state and not addressed in or impacted by the September 30 deadline.

Medicare and Medicaid Reimbursements Continue

Medicare claims are expected to be processed and paid without interruption, as Medicare and Medicaid are mandatory programs whose funding isn’t subject to annual appropriations. Based on previous shutdowns, it’s probably safe to assume that the Centers for Medicare & Medicaid Services (CMS) will continue processing Medicare claims, and Medicaid will maintain its payments to states.

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.

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 supports 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 post by November 1 with a January 1 effective date.