The federal government shutdown that began on October 1 will impact payments to radiology practices in several ways, and it is unknown how long the shutdown will last. Medicare payments will be placed on a 10-day hold, as the agency copes with staffing at about 53% of the normal level. According to a U.S. Department of Health and Human Services (HHS) contingency staffing plan, HHS will maintain such staff as is necessary to support mandatory funded activities such as Medicare and Medicaid.
Rebecca Farrington.
The American College of Radiology (ACR) is urging practices to continue to submit claims as usual. This ACR resource is available for updates on the shutdown and how it will affect radiology practices. They highlight the following points:
Federal No Surprises Act Independent Resolution Process is unaffected by the shutdown.
Medicare payments will be put on a 10-day hold (submit claims as usual); 53% of CMS staff retained.
Medicaid is funded through Q1 FY 2026.
CMS rulemaking and policy development may be delayed.
COVID-era telehealth flexibilities have expired; pre-COVID rules apply.
The telehealth flexibilities that were granted in the Medicare program amid the COVID-19 pandemic expired by law as of October 1, 2025, independent of the government shutdown. This could impact interventional radiologists, radiation oncologists, and nuclear medicine specialists, who typically bill for E&M services. It is recommended that practices obtain an Advanced Beneficiary Notice (ABN) from patients before providing telehealth services.
On a broader scale, the GPCI Work Floor minimum threshold of 1.0 also expired on October 1. This could impact more practices over a longer term. We reported in our article earlier this year, “The Geographic Adjustment Factor is explained in more detail in our recent article What Else is in the Medicare Proposed Rule for 2025?. Without the CR (Continuing Resolution of March 15, 2025), some parts of the country would have seen their Medicare reimbursement reduced on April 1 by up to 2.7% on top of the 2.83% across-the-board cut.
If Congress does not again pull back the GPCI adjustment, 51 payment localities across the country will see a reimbursement reduction from 1.0 to 2.7% as of October 1. In Mississippi, the hardest-hit locality with a 2.7% reduction, the reimbursement for some common procedures could change as follows:
Code | Description | With 1.0 Floor | Without 1.0 Floor |
71046 | 2-view chest x-ray | $9.57 | $9.31 |
77067 | Screening mammogram | $33.29 | $32.39 |
74177 | CT abdomen/pelvis with contrast | $79.54 | $77.39 |
70551 | MR brain, no contrast | $64.22 | $62.49 |
70450 | CT head, no contrast | $37.03 | $36.03 |
76856 | Complete pelvic ultrasound | $29.95 | $29.14 |
Other areas that would see at least a 2% reduction are Arkansas, part of Missouri (99), Idaho, West Virginia, Kentucky, Maine, and Utah. We don’t know at this point if Medicare will process October claims at the old rates or at the reduced rates once the 10-day claims hold expires. In either case, the ultimate Congressional action or inaction could cause a future reconciliation payment or recoupment.
We are aware this will impact your practice, but at this time, there are many unknowns. While current guidance suggests that Medicare and Medicaid will remain unaffected, the broader implications -- both upstream and downstream -- are still unclear. Additionally, we do not yet have clarity on how other payers, including VA, CHAMPUS, TRICARE, and others, may be impacted by the shutdown.
Rebecca Farrington is chief revenue officer at Healthcare Administrative Partners.
The comments and observations expressed are those of the author and do not necessarily reflect the opinions of AuntMinnie.com.
