Value-Based Care

Update on the Government Shutdown: Medicare Claims Hold


On October 15, 2025, the Centers for Medicare and Medicaid Services (CMS) issued a statement on the continued hold of all fee schedule claims. You may have heard that CMS decided to pause reimbursement for all Medicare claims until after the shutdown, but this decision was quickly reversed after much pushback. In this blog, we discuss the latest update and what it means for you.

Certain Medicare Claims Will Remain on Hold

While CMS initially instructed Medicare Administrative Contractors (MACs) to continue to hold all Medicare claims until further notice, this decision was quickly reversed after significant pushback.

Now, only Medicare claims impacted by expired provisions will remain on hold. While this is good news for claims outside of these provisions, there are still many types of claims that remain affected, including claims for telehealth other than behavioral and mental health services and claims for care delivered in low-cost geographic areas. In some cases, Medicare claims reimbursements across entire states are affected, as we discuss in the next section of this blog.

Note that the claims hold does not apply to Medicare Advantage or to Medicaid.

For more information on the types of claims affected by expired provisions and additional details on the shutdown, refer to our previous blog: What You Need to Know about the Government Shutdown.

You can also click on the dropdown below for a reminder on the telehealth flexibilities that expired on September 30, 2025. Claims for these services will not be reimbursed unless Congress acts to renew these flexibilities.

Expiration of Telehealth Flexibilities

The Medicare fee-for-service telehealth flexibilities that were established during the COVID-19 Public Health Emergency (PHE) expired on September 30, 2025. This means that as of October 1, 2025, in order to be reimbursable, telehealth visits must meet the pre-COVID-19 PHE requirements, including the following:

  • Geographic and Originating Site Requirement: As of October 1, 2025, the patient’s home is no longer considered an “originating site.” For non-behavioral or mental health services, patients can only receive care from specific sites, such as a provider’s office or hospital.
  • No More Audio-Only Telehealth: Audio-only telehealth visits are no longer reimbursable unless they are for behavioral or mental health.
  • In-Person Visit Requirement: Patients receiving behavioral health telehealth services must first have an in-person visit and continue to have an in-person visit at least once every 12 months.

For telehealth services that do not meet the criteria to be covered, CMS recommends that providers consider using an Advance Beneficiary Notice of Noncoverage (ABN) before delivering the service to inform patients that Medicare is unlikely to provide coverage.

Medicare Shared Savings Program Accountable Care Organizations (ACOs) will continue to be reimbursed for covered telehealth services.

For Medicare Advantage, many plans, such as Aetna and United Healthcare, are continuing to offer payment for expanded telehealth services.

Medicaid plans may also continue to offer expanded telehealth services.

For both Medicaid and Medicare Advantage, we recommend checking with specific plans to see if they are continuing coverage.

Impact on Medicare Reimbursement in Low-Cost Geographic Areas

On September 30, 2025, the 1.0 floor on the geographic practice cost index (GPCI) adjustment to the physician work component of Medicare reimbursements expired. As it is uncertain whether the floor will be reinstated by Congress when they pass the budget, CMS is holding all claims impacted by the expiration of the 1.0 work GPCI floor. This impacts 51 of the 109 Medicare localities, 30 of which encompass entire states and/or US territories.

What to Expect if Congress Does Not Renew the 1.0 Work GPCI Floor

GPCIs are geographic adjustment factors that Medicare uses to modify physician fee schedule payments based on geographic variations in the cost of providing care. Think of GPCIs as CMS’ way of acknowledging that practicing medicine in Manhattan costs significantly more than practicing in Wisconsin.

There are different GPCIs for different Medicare cost components; the one impacted by this expired policy is the work GPCI (physician labor costs). In areas with a lower cost-of-living than the national average, the work GPCI is less than 1.0, meaning that the reimbursed amounts for the physician work component would be less than the fee schedule amount.

Congress previously passed a temporary policy, followed by numerous subsequent extensions, to create a 1.0 floor for the work GPCI. This floor meant that the reimbursement for physician labor costs could not have a downward geographic adjustment. This floor expired on September 30, 2025.

Click on the dropdown below to see the 51 localities impacted by the expiration of the GPCI work floor. For these localities, payments will be held until the shutdown ends or until further CMS action.

2025 GPCIs by State and Medicare Locality Impacted by 1.0 Floor Expiration

Localities that encompass entire states or US territories are in bold.

Medicare Administrative Contractor (MAC)StateLocality NumberLocality Name2025 PW GPCI (Without 1.0 Floor)
10112AL00Alabama0.978
03102AZ00Arizona0.981
07102AR13Arkansas0.955
09102FL03Fort Lauderdale0.979
09102FL04Miami0.984
09102FL99Rest of Florida0.969
10212GA01Atlanta0.997
10212GA99Rest of Georgia0.968
01212HI01Hawaii, Guam, Northern Mariana Islands, American Samoa0.996
02202ID00Idaho0.957
06102IL12East St. Louis0.980
06102IL99Rest of Illinois0.972
08102IN00Indiana0.973
05102IA00Iowa0.968
05202KS00Kansas0.965
15102KY00Kentucky0.961
07202LA01New Orleans0.977
07202LA99Rest of Louisiana0.966
14112ME03Southern Maine0.979
14112ME99Rest of Maine0.963
08202MI99Rest of Michigan0.975
06202MN00Minnesota0.996
07302MS00Mississippi0.950
05302MO02Metropolitan Kansas City0.983
05302MO01Metropolitan St. Louis0.982
05302MO99Rest of Missouri0.956
03202MT01Montana0.963
05402NE00Nebraska0.971
01312NV00Nevada0.988
14312NH40New Hampshire0.993
04212NM05New Mexico0.975
13282NY99Rest of New York0.991
11502NC00North Carolina0.983
03302ND01North Dakota0.979
15202OH00Ohio0.983
04312OK00Oklahoma0.965
02302OR99Rest of Oregon0.978
12502PA99Rest of Pennsylvania0.988
09202PR20Puerto Rico0.998
11202SC01South Carolina0.972
03402SD02South Dakota0.974
10312TN35Tennessee0.964
04412TX31Austin0.998
04412TX20Beaumont0.985
04412TX99Rest of Texas0.986
03502UT09Utah0.962
14512VT50Vermont0.973
09202VI50Virgin Islands0.998
11402WV16West Virginia0.961
06302WI00Wisconsin0.985
03602WY21Wyoming0.974

To see the localities that were not impacted by the expiration of the GPCI work floor, click on the dropdown below. For these localities, payments will be processed normally.

2025 GPCIs by State and Medicare Locality Not Impacted by 1.0 Floor Expiration

Localities that encompass entire states or districts (i.e., Washington, DC), are in bold.

Medicare Administrative Contractor (MAC)StateLocality NumberLocality Name2025 PW GPCI (Without 1.0 Floor)
02102AK01Alaska1.500
01112CA54Bakersfield1.017
01112CA55Chico1.014
01182CA71El Centro1.014
01112CA56Fresno1.014
01112CA57Hanford-Corcoran1.014
01182CA18Los Angeles-Long Beach-Anaheim (Los Angeles/Orange County)1.042
01112CA58Madera1.014
01112CA59Merced1.014
01112CA60Modesto1.014
01112CA51Napa1.058
01182CA17Oxnard-Thousand Oaks-Ventura1.026
01112CA61Redding1.014
01112CA62Riverside-San Bernardino-Ontario1.014
01112CA63Sacramento-Roseville-Folsom1.034
01112CA64Salinas1.035
01182CA72San Diego-Chula Vista-Carlsbad1.028
01112CA05San Francisco-Oakland-Berkeley (San Francisco/San Mateo/Alameda/Contra Costa County)1.088
01112CA52San Francisco-Oakland-Berkeley (Marin County)1.088
01112CA65San Jose-Sunnyvale-Santa Clara (San Benito County)1.100
01182CA73San Luis Obispo-Paso Robles1.014
01112CA09San Jose-Sunnyvale-Santa Clara (Santa Clara County)1.100
01112CA66Santa Cruz-Watsonville1.017
01182CA74Santa Maria-Santa Barbara1.022
01112CA67Santa Rosa-Petaluma1.027
01112CA68Stockton1.014
01112CA53Vallejo1.058
01112CA69Visalia1.014
01112CA70Yuba City1.014
01112CA75Rest of California1.014
04112CO01Colorado1.008
13102CT00Connecticut1.022
12202DC01DC + MD/VA Suburbs1.057
12102DE01Delaware1.009
06102IL16Chicago1.007
06102IL15Suburban Chicago1.007
12302MD01Baltimore/Surr. Counties1.020
12302MD99Rest of Maryland1.012
14212MA01Metropolitan Boston1.042
14212MA99Rest of Massachusetts1.017
08202MI01Detroit1.003
12402NJ01Northern NJ1.064
12402NJ99Rest of New Jersey1.042
13202NY01Manhattan1.065
13202NY02NYC Suburbs/Long Island1.065
13202NY03Poughkeepsie/N. NYC suburbs1.046
13292NY04Queens1.065
02302OR01Portland1.013
12502PA01Metropolitan Philadelphia1.024
14412RI01Rhode Island1.025
04412TX09Brazoria1.014
04412TX11Dallas1.011
04412TX28Fort Worth1.011
04412TX15Galveston1.014
04412TX18Houston1.014
11302VA00Virginia1.002
02402WA02Seattle (King County)1.043
02402WA99Rest of Washington1.007

Next Steps

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Written By: Jessica Peterson, MD, MPH & Sarrah Hakim, MHSA

About the Authors:

Jessica Peterson, MD, MPH

Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.

Sarrah Hakim, MHSA

Sarrah Hakim, MHSA is a Manager of Health Policy at Anatomy IT.

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