As of today, Congress is close to finalizing an agreement to continue funding the government; however, the deal is not expected to be completed in time to fully avoid a brief shutdown. As a result, Medicare telehealth flexibilities for home health agencies will expire tonight.

The shutdown is anticipated to be short-lived, with funding expected to resume next week when House members return for a vote. While a retroactive extension of the telehealth flexibilities is likely, it is not guaranteed. Home health agencies should prepare to operate under pre-flexibility rules during this period.

Home Health Face-to-Face Requirement Reminder

To be eligible for Medicare home health services, patients must have a face-to-face encounter with a physician or allowed practitioner (nurse practitioner, physician assistant, clinical nurse specialist, or certified nurse-midwife) within 90 days prior to or 30 days after the start of care.

Agencies should carefully review face-to-face documentation to ensure compliance with the telehealth rules in effect at the time each encounter occurred.

What Is Expected Once the Government Reopens

Congress is expected to extend home health telehealth flexibilities — including removal of geographic restrictions and expanded originating sites — through December 31, 2027, allowing required F2F encounters to continue to be conducted via telehealth.

HCAF will continue to update members as developments occur.