Government Shutdown Effect on CMS and MACs

The government shutdown which has been going on since October 1, 2025 has impact to CMS operations and to the Medicare Contractors. Although CMS is working, it is with a reduction in workforce. We are seeing delays at the regional office level. This impacts new certifications, recertifications, and changes to CMS-29 forms. We are also seeing delays with the different MACs on provider enrollment issues and tie-in notices. Telehealth claims are being held and other claims processing seems slow in some regions.

Major Changes to Medicare Medical Distant Site Telehealth Started October 1st

Although RHCs can still perform distant site medical telehealth, the ability for the patient to be at home for telehealth ended September 30, 2025. Congress failed to act prior to the government shutdown to extend the flexibility of the patient being at home. The patient must be in a qualified originating site (CAH, SNF or another RHC) for example) and the RHC provider is either in the clinic or in their home. We cannot bill G2025 when the patient is at home unless Congress extends the flexibility. There is legislature being introduced to make medical telehealth permanent for RHCs but we do not have it yet. Mental health telehealth remains a permanent RHC encounter. Ask your consultant if you have more questions about telehealth billing.

RHC: NEW LIBRARY ITEMS: AUTOCLAVE LOGS 238-D & 238-E

Two new library items have been created for those RHCs using autoclaves. Surveyors are validating that autoclave logs are being kept, especially cleaning logs which align with manufacturers guidelines. Don't receive a deficiency because of a missing log. We have added 238-D which is for monthly autoclave cleaning and spore counts and 238-E which is a log which can be used daily, weekly and monthly according to the manufacturer's guidelines.

NEW EHR CHART REVIEW TOOL IN LIBRARY 510-A2 AVAILABLE

If your physician reviews NP/PA charts electronically, you must still be able to give the surveyor a list of those charts and the review date with signatures. This would be similar to an attestation. EHR PHYSICIAN CAHRT REVIEW 510-A2 is your saving grace! Use this form to document which charts were reviewed and obtain attesting signatures. Don't forget to add closed charts as part of your review process.