CLAIMS HOLD UPDATE 10/21/2025_CMS Payment Hold for Certain Claims

CMS instructed all Medicare Administrative Contractors (MACs) to lift the claims hold and process claims with dates of service of October 1, 2025, and later for certain services impacted by select expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025 (Pub. L. 119-4, Mar. 15, 2025). This includes claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and Federally Qualified Health Center (FQHC) claims. This includes telehealth claims that CMS can confirm are definitively for behavioral and mental health services. CMS has directed all MACs to continue to temporarily hold claims for other telehealth services (i.e. those that CMS cannot confirm are definitively for behavioral and mental health services).

What’s happening:
CMS has instructed all Medicare Administrative Contractors (MACs) to temporarily hold claims for services with dates of service on or after October 1, 2025, due to the expiration of temporary legislative payment provisions from the Full-Year Continuing Appropriations and Extensions Act, 2025.

Claims affected:

  • Medicare Physician Fee Schedule (MPFS) claims

  • Ground ambulance transport claims

  • FQHC claims

Action for FQHCs:

  • Continue submitting claims as usual; payments will be delayed until the hold is lifted.

  • Monitor CMS communications for updates on the release of payments.

Resource:


Key Takeaways for FQHCs

  1. Telehealth: Use ABNs for services not covered; watch for legislative updates.

  2. Claims Payment: Submit claims as normal, but expect delayed payment for affected services.

  3. ACOs: Special flexibilities continue for participating providers.