Government Shutdown Impact on Telehealth Services for Medicare & Other Payers

Updated: November 3, 2025

We understand there’s concern about the government shutdown and the expiration of certain federal telehealth waivers. Below is a summary of how this affects different government-sponsored payers, including Medicare, TRICARE, VA, and Medicaid.

The Bottom Line (for Reassurance):

Support for telehealth is exceptionally high, and a legislative solution to extend these flexibilities is highly anticipated. Claims payments for VA and Medicaid are expected to continue uninterrupted because they are mandatory spending programs or rely on existing contractor funds. TRICARE claims processing, however, may face temporary delays due to the lapse in government funding. Only Medicare requires an immediate change to compliance protocol.

1. Medicare

Medicare is the only government payer where the in-person visit requirement for mental health telehealth has legally returned. Our hope is that this requirement will be legislatively delayed again, in which case the change will be retroactively applied.

New Patients (Starting 10/1/25):

• Current Compliance Rule: Before initiating telemental health on/after Oct 1, 2025, the patient must have had an in-person visit within the prior 6 months; after that, an in-person at least every 12 months is required (unless a documented exception applies).

• Should I take a new Medicare client even if I cannot do an initial in-person visit?

  • If you choose to see a new client via telehealth before the mandatory in-person visit, you do so at the risk of non-payment. However, know that we highly anticipate Congress will pass a retroactive extension of the waiver; if this occurs, you will be paid for all visits conducted during the lapse.

Established Patients:

• Annual Requirement: Starting Oct 1, 2025, an in-person visit is required at least once every 12 months while a patient is receiving Telehealth mental health services, unless an exception is documented.

• Waiver Exception: CMS allows limited exceptions to the 12-month in-person requirement when the patient and practitioner agree that the risks or burdens of an in-person visit outweigh the clinical benefits, and the clinician documents the rationale in the medical record. (Note: this exception does not waive the initial in-person visit required within six months prior to starting telehealth services.) If a provider cannot complete the required in-person visit and a waiver cannot be justified, other options may be available to maintain compliance, such as having another practitioner within the same group conduct the in-person visit.

• Claims Status: CMS has placed claims affected by the expired flexibilities under a temporary hold (typically 10 business days). This is standard procedure when legislative extenders lapse, done to prevent the need for reprocessing if Congress passes a retroactive extension.

2. Other Government Plans (Status: Unaffected)

• VA Community Care Network (VA CCN): The VA operates on advance appropriations, so its medical care and critical services continue uninterrupted during a shutdown. There is no in-person visit requirement for telehealth under VA policy.

• TRICARE: Civilian health care under TRICARE is not affected by the shutdown, and telehealth coverage remains available without an in-person visit requirement. However, due to the prolonged lapse in government funding, TRICARE claims for services received on or after October 1, 2025, are currently facing delays or a payment hold until funding is restored. Providers should budget for sustained payment delays throughout the shutdown.

• Note: Patients with TRICARE For Life (TFL) must follow Medicare’s telehealth rules, since Medicare is the primary payer for TFL beneficiaries.

• Medicaid: Medicaid is mandatory spending, so claims payments continue during a shutdown. Federal changes to Medicare telehealth do not override state Medicaid telehealth policies — continue following your state’s specific rules.

Note: The information in this article reflects the status of telehealth policies and government payer updates at the time of publication. Circumstances may change as new legislation or guidance is issued. While we stand by the accuracy of this information, we encourage readers to verify the most current updates with official sources or reach out to us with specific questions.

About Help Therapy

Help Therapy has been providing trusted mental health care since 1993, with a network of over 150 licensed providers across California. We offer psychotherapy, psychological evaluations, and psychiatry/medication management through both in-person and telehealth visits. Our team is dedicated to making care accessible for patients covered by Medicare, Tricare, PPO insurance plans, and private pay.