Important Provisions for Radiology in the Bill to Re-Open the Government

Important Provisions for Radiology in the Bill to Re-Open the Government In our early-October article What Radiology Practices Need to Know About the Government Shutdown we expressed concern about several Medicare policies that were unresolved during the federal government shutdown that began on October 1, 2025. The Continuing Appropriations and Extensions Act, 2026 (H.R. 5371) that was signed into law on November 12, 2025, addressed those concerns and resolved them in a positive way for radiology practices. The two provisions that expired on September 30 were the telehealth flexibilities and the GPCI 1.0 work floor threshold. The telehealth flexibilities were extended until January 30, and the GPCI work floor was extended until January 31, 2026.

During the shutdown, claims for certain telehealth services were placed on hold by Medicare. In the November 7 MLN Connects newsletter CMS reported that, “For the subset of telehealth claims that are currently being held, and that were submitted on or before November 10, 2025, with dates of service on or after October 1, 2025, CMS will be returning those claims to providers” and indicated that providers would later have to resubmit those returned claims.

Claims for services performed in geographic localities that would have been affected by expiration of the work GPCI floor were put on hold as well. In their October 21 guidance, CMS indicated that the claims would be paid. Now that the shutdown has ended, some of those paid claims might have to be reprocessed.

Another important provision in H.R. 5371 is that it permanently exempted any adjustment of the Medicare fee schedule that would have been necessitated by passage of the OBBBA budget bill in July. The Pay-As-You-Go (PAYGO) law enacted in 2010 requires cuts of up to 4% to programs such as Medicare when spending bills increase the federal deficit. Although Congress has never allowed PAYGO to be implemented as a reduction to the Medicare fee schedule, it has been an annual uncertainty. This Act removes that uncertainty as far as the OBBBA spending increases are concerned.

While most claims other than those for telehealth or those in the affected work GPCI areas should have been paid under the normal 14-day claims processing time frame, practices would do well to review all claims for services in October and early November to be sure they were actually processed and properly paid. Telehealth claims may have to be resubmitted for payment, and claims in the work GPCI affected areas might have to be reprocessed, presumably by Medicare without the necessity for provider action. We will continue to monitor this area and update our blog readers with any news. Subscribe to this blog for all the latest information that affects your practice’s reimbursement.

Rebecca Farrington is the Chief Revenue Officer at Healthcare Administrative Partners.

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