Government Shutdown Update

This page will be updated as new information becomes available.

The federal government shut down on October 1 and remains shutdown after several failed attempts by Congress to pass a short-term funding bill. This remains a highly fluid situation as lawmakers continue to negotiate a path forward.

Academy staff and consultants are monitoring this situation and actively engaging with members of Congress to emphasize the critical ramifications this shutdown will have on Academy members and health care systems along with federal nutrition programs.

A government shutdown occurs when Congress fails to pass a budget or a continuing resolution (CR) before the current budget's expiration date. As a result, federal agencies and departments are left without the necessary funding to operate, causing a cascade of consequences.

Essential government functions may continue, but federal employees may be temporarily suspended and many services may be delayed, interrupted or severely impacted.

The Office of Management and Budget has significant latitude on how agencies and personnel are deemed "essential". They have indicated in a memo that there could be significant disruption to agencies not deemed a priority of the administration.

What Expiration/Shutdown Means for Health Agencies and Programs

Telehealth Waivers: Without congressional action, telehealth flexibilities which allow Medicare beneficiaries to receive telehealth services from their home and outside of statutorily defined rural areas expired at midnight on September 30.
Get more information about telehealth

Medicare Work Geographic Index Floor Expiration: Medicare's Geographic Practice Cost Index (GPCI) adjusts the Medicare Physician Fee Schedule for local costs. When the statutory “1.0 floor” is in place, payments for the affected index can’t drop below the national average. As the statutory floor provision has expired, the GPCI for some localities now falls under 1.0.

Community Health Centers and Special Diabetes Program: These programs are vital to public health and face funding lapses without reauthorization by September 30.

Updated Claims Processing Guidance from the CMS: Telehealth and Localities with a Geographic Practice Cost Index of Less Than 1.0

As of October 1, 2025, the Centers for Medicare & Medicaid Services (CMS) issued a special Medicare Learning Network (MLN) Connects update on Medicare telehealth and claims operations during the shutdown. CMS directed Medicare Administrative Contractors (MACs) to place a temporary hold on claims.

On Wednesday, October 15, CMS issued updated guidance stating that "In anticipation of possible Congressional action, CMS has instructed all Medicare Administrative Contractors (MACs) to continue to temporarily hold claims with dates of service of October 1, 2025, and later for services impacted by the expired Medicare legislative payment provisions... Providers may continue to submit these claims, but payment will not be released until the hold is lifted."

On Thursday, October 16, additional guidance was issued instructing MACs to limit the Medicare claims hold for services provided on or after October 1, 2025, that are impacted by the expired Medicare legislative payment provisions, including telehealth services other than for behavioral or mental health care, and services provided in locations with a work GPCI below the 1.0 floor.

For all other services, Medicare claims will continue to be processed and paid in a timely manner. To date, no payments have been delayed as statute already requires all claims to be held for a minimum of 14 days. Providers may continue to file claims accordingly.

As Congress has failed to pass a CR, original (fee-for-service) Medicare has reverted to pre-pandemic telehealth rules. As of October 1, 2025, for MNT furnished via telehealth, beneficiaries must be located in a rural area as defined in statute and receive services at an eligible originating site. MNT telehealth services delivered to a beneficiary in their home, or outside the eligible geographic or originating sites, are not payable under current law.

Consistent with prior CMS statements, providers may wish to consider issuing an Advance Beneficiary Notice of Noncoverage (ABN) for services that are not payable on or after October 1. While we do not know what Congress will ultimately decide, Congress could restore the expired telehealth flexibilities , potentially retroactive to October 1.

As operational responses vary by organization based on a wide variety of factors, the Academy encourages RDNs working in facilities to coordinate with their administration and compliance teams to determine interim policies on scheduling, ABNs and claim filings, and should assess options to route telehealth encounters through eligible originating sites where feasible.

The Academy encourages private practices to assess impacts on patient access, scheduling and revenue cycle; communicate proactively with patients about care options; and identify and reach out to eligible originating sites about partnering with and serving as telehealth hubs.

In practice, organizations are taking different approaches, including holding claims pending legislative action, shifting visits to in-person where possible or deferring telehealth visits later in the month, using ABNs when appropriate or proceeding with telehealth while accepting the risk of nonpayment.

The expired flexibilities discussed here apply only to Traditional Medicare. Medicare Advantage plans, state Medicaid programs and commercial payers may choose to mirror Medicare but are not required to do so. Providers should verify requirements with each plan.

Some states also have statutes governing Medicaid telehealth and coverage or payment parity for commercial plans that may preserve access to telehealth for certain services, including MNT. For state-specific telehealth laws and Medicaid policy details, the Center for Connected Health Policy is a helpful resource.

Medicare Shared Savings Program Accountable Care Organizations Exception

Under the Bipartisan Budget Act of 2018, clinicians in applicable Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs) may continue to furnish and bill covered telehealth services without geographic restrictions and with the beneficiary's home as the originating site during CY 2025; no special application is required.

Providers may subscribe to the MLN Connects Newsletter to receive direct updates from CMS.

What Expiration/Shutdown Means for the U.S. Department of Agriculture and Nutrition Programs

Supplemental Nutrition Assistance Program (SNAP): Critical nutrition programs like SNAP will face operational challenges. While benefits for SNAP may continue temporarily due to state funding draw downs, administrative support and future funding could be disrupted.

Special Supplemental Program for Women, Infants, and Children (WIC) Program: WIC could continue to enroll families and provide services, but only as long as currently funding is available. This would impact access to nutritious food for millions of low-income families, especially those relying on WIC benefits for young children and infants.

Child Nutrition Programs: Programs like the National School Lunch Program (NSLP) and School Breakfast Program (SBP) could face delays in reimbursement funding, creating uncertainties for schools and impacting meal access for children. If a full appropriations bill is not passed, these programs may be unable to operate efficiently, leaving vulnerable children at risk of hunger.

The Academy is focused on ensuring telehealth flexibilities are extended, with ongoing efforts to secure their inclusion in current legislation. The Academy is also committed to advocating for uninterrupted funding and ensuring nutrition security programs remain intact as critical components of nutrition security and access.