CMS recently announced a temporary claims payment hold for services billed under the Medicare Physician Fee Schedule (PFS) — effective for dates of service on or after October 1, 2025. If your clinic submits claims to Medicare, here’s what you need to know and how to prepare.

Why the Hold Is Happening

The payment hold stems from expired legislative provisions that determine how certain Medicare services are paid. Until Congress takes action to extend or renew these provisions, Medicare Administrative Contractors (MACs) have been instructed to hold affected claims.

This impacts:

• Outpatient rehab therapy services billed under the PFS

• Ground ambulance transports

• Federally Qualified Health Centers (FQHCs)

You can still submit claims as usual, but payment will not be released until CMS lifts the hold.

What It Means for Rehab Therapy Practices

For most private outpatient therapy clinics, this means a temporary delay in Medicare payments for October dates of service and beyond. This could impact short-term cash flow — particularly for practices with a high Medicare patient mix.

Telehealth services are also at risk. If Congress doesn’t act soon, pre-COVID telehealth restrictions may return. That means:

• Only rural patients may qualify

• Services may no longer be covered when performed from the patient’s home

• Certain codes could become non-payable

Practices providing telehealth should consider issuing Advance Beneficiary Notices (ABNs) to alert patients when a service may not be covered.

What You Should Do Now

• Continue submitting claims — CMS will process them once the hold is lifted.

• Monitor cash flow closely and adjust projections.

• Watch for legislative updates — CMS will release guidance as soon as payment provisions are renewed.

• Communicate with patients receiving telehealth to prevent coverage surprises.

While the hold is temporary, it highlights how quickly policy changes can affect revenue cycles. Staying proactive and informed will help your practice weather the delay and minimize disruption.

For ongoing updates, follow CMS’s MLN Connects Newsletter