Navigating the shutdown: a guide for rehab therapists 

The recent government shutdown has introduced new uncertainties for therapy professionals. If you’re a physical, occupational, or speech language pathologist, you may have questions about how this impacts your day-to-day practice, your clients, and your billing for telehealth services. Today, my goal is to help explain what’s happening, what it means for your work, and offer some practical guidance as things evolve. 

This is a confusing time, but clear information makes it easier to navigate. Here’s a breakdown of the expiration of pandemic-era telehealth rules, the latest Medicare guidance, and steps you can take to support both your practice and your clients during this period. 

What has changed for telehealth and Medicare? 

During the pandemic, special legislation allowed PT, OT, and SLP therapists to provide more services via telehealth and bill Medicare for them. These changes made therapy more accessible for clients who are homebound or live far from in-person care. 

However, those expanded provisions ended on September 30, 2025, as Congress did not pass a bill to extend them further. As a result, Medicare telehealth rules have reverted to their pre-pandemic state for many therapy services. 

This means Medicare may no longer cover telehealth sessions for clients in their homes unless they reside in a designated rural area. There are also tighter restrictions around which clinicians can be paid for telehealth and requirements around hospice recertifications that now require face-to-face visits. 

Current Medicare guidance 

What does this mean for the claims you’re sending now? The Centers for Medicare & Medicaid Services (CMS) is aware of the uncertainty and anticipates that Congress could still act to restore the provisions retroactively. 

To prepare for this, CMS has told its Medicare Administrative Contractors (MACs) to temporarily hold telehealth claims related to these services. While it may seem inconvenient, this approach avoids claim denials and the need for extensive reprocessing if Congress makes changes after the fact. 

Therapists are being advised to keep submitting claims as usual, even though payment for certain telehealth services will be temporarily delayed. The expectation is that these holds will be short-term, and the standard 14-day payment processing window may help ease immediate financial pressure. 

What can you do right now? 

Uncertainty can be challenging, so it helps to focus on a few practical steps you can take right now to manage your practice and support your clients. 

Keep submitting your claims 

Continue following Medicare’s guidance and submit telehealth claims for services delivered. If the rules are extended, your claims will already be in the pipeline, ready for prompt processing. 

Consider using an ABN 

It may be a good idea to use an Advance Beneficiary Notice of Noncoverage (ABN) for any service you believe Medicare might not pay for. Giving your client an ABN means they’re aware they could be responsible for the cost if coverage is denied. This promotes transparency and helps protect your practice financially. 

Prepare for payment delays or denials 

With the hold on payments for these claims, consider how a delay or denial might affect your cash flow. Taking some time to review your finances and plan for possible short-term disruptions can help smooth things over until the situation is resolved. 

Communicate with your clients 

Clients may also feel unsure or anxious. Keeping them informed about the status of telehealth rules and what it could mean for their services or costs is essential. Open, honest communication helps build trust, and together you can decide whether to continue with telehealth or explore alternatives if coverage remains uncertain. 

Exception for clinicians in an ACO 

There’s an important exception to note. If you’re part of a Medicare Shared Savings Program Accountable Care Organization (ACO), these restrictions don’t apply in the same way. Clinicians in qualifying ACOs can continue to provide and get paid for telehealth services without geographic limitations or home-based restrictions. No separate application or approval is required for this benefit. 

Looking at the bigger picture 

While the focus right now is on billing and logistics, this situation brings up broader questions about access to care. Telehealth has helped many clients overcome barriers to consistent therapy. The loss of these provisions could limit access and increase out-of-pocket expenses for some, especially more vulnerable clients. Staying aware and advocating for meaningful policies will remain important moving forward. 

Rules are shifting, and the future of telehealth coverage for therapists is unsettled. By keeping informed, planning ahead, and communicating with your clients, you can manage this period effectively. 

Monitor updates from Congress and CMS for the latest developments. Staying proactive helps you stay prepared for whatever comes next so you can continue to support your clients and run your practice with confidence.  

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