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LUGPA Policy Brief - CMS Confirms Retroactive Restoration of Medicare Telehealth Flexibilities After Government Shutdown

November 2025 

On November 20, 2025, the Centers for Medicare & Medicaid Services (CMS) released an updated Telehealth Frequently Asked Questions (FAQ) document confirming that Medicare telehealth flexibilities lapsed during the recent federal government shutdown (October 1–November 12, 2025) are now applied retroactively as if no lapse occurred.

This follows the continuing resolution enacted on November 12, 2025, that extended these authorities through January 30, 2026, ensuring uninterrupted payment for eligible services furnished since October 1, 2025.

Key CMS Clarification

Q16: What will happen to telehealth services that were provided during the government shutdown?

CMS Response (excerpt): CMS will continue to pay telehealth claims in the same way they had been paid before October 1, 2025. Telehealth flexibilities will apply retroactively as if there hadn’t been a temporary lapse through January 30, 2026.

Preserved flexibilities include:

  • Coverage of telehealth services provided to patients at home (no originating-site restrictions),
  • Removal of geographic limitations,
  • Continued reimbursement for audio-only services when appropriate,
  • No new in-person visit requirements during this period.

Implications for Urology Practices

  • Uninterrupted Reimbursement: Submit claims for services on or after October 1, 2025, with confidence in payment at pre-lapse rates; no new modifiers or widespread resubmissions anticipated.
  • Preserved Patient Access: Seamless telehealth for postoperative follow-up, PSA monitoring, chronic condition management (e.g., BPH, OAB), and consultations without barriers.
  • Elimination of Administrative Burden: Retroactive policy prevents denials, recoupments, or patient billing for good-faith services.
  • Alignment with LUGPA Advocacy: Reinforces LUGPA's push for stable telehealth policy in independent urology.

LUGPA Position

LUGPA applauds CMS’s clarification and the congressional extension restoring flexibilities retroactively through January 30, 2026. This protects patient access, shields practices from disruption, and sustains telehealth gains since 2020.

Temporary fixes, however, breed uncertainty. LUGPA urges permanent reform, including:

  • Permanent removal of geographic and originating-site restrictions,
  • Ongoing coverage of clinically appropriate audio-only services,
  • Equitable reimbursement relative to in-person care,
  • Elimination of arbitrary in-person mandates.

LUGPA will continue advocating with Congress, CMS, and partners for lasting Medicare telehealth access that supports independent urology practices and patients.