GOVERNMENT SHUTDOWN

Immediate impact pronounced in operational support and oversight

The 2025 government shutdown is significantly affecting the senior living industry, but the immediate impact has been more pronounced in operational support and oversight, rather than direct care or reimbursement. While Medicare and Medicaid payments are largely continuing without disruption due to their mandatory funding status, many support functions and critical regulatory activities have been paused or scaled back.

Oversight and Survey Disruptions

• State and federal survey and certification activities are limited to only the most serious complaints, such as those involving immediate jeopardy to resident health or safety. Routine inspections, recertification surveys, and less serious complaint investigations are suspended, causing a backlog and increasing risk to residents in facilities with known quality problems.
• Nearly half of the CMS staff are furloughed, further hampering oversight and timely investigation of problems in senior living and skilled nursing environments.

Program and Services Uncertainties
Programs dependent on discretionary federal funding, such as services under the Older Americans Act (e.g., Meals on Wheels, falls prevention), are at risk of delay or interruption. Staffing shortages at HHS, after terminations and further furloughs due to the shutdown, are compounding these delays.

Financial Pressures and Medicaid Funding
The shutdown continues alongside ongoing Medicaid funding cuts, which are causing broader financial challenges for senior living operators. While Medicaid and CHIP payments are still being made, the industry faces uncertainty regarding potential additional funding reductions from continuing Congressional debates and the growing shift toward value-based care and private payer models.

Steps Providers Can Take to Maintain Care During the Shutdown
Focus on contingency planning, communication, preserving essential services, and being proactive about regulatory and operational changes. Medicare and Medicaid claims continue to be processed, so direct care should not be interrupted, but vigilance is needed on oversight, support programs, and reimbursement delays.

• Ensure Timely Claims Submission: Continue submitting Medicare and Medicaid claims as usual, even if payments are temporarily held due to shutdown protocols. Most claims will be paid retroactively when the shutdown ends.
• Prioritize Resident Safety: Focus resources on areas affecting immediate safety and quality of care. Maintain strong internal monitoring and rapid response systems since external survey and certification activities are limited to immediate jeopardy and actual harm cases.
• Enhance Communication: Communicate regularly with residents, families, and staff about ongoing changes, contingency plans, and reassurance that core services are being maintained.

Contingency Planning and Risk Management

• Monitor Compliance: Internally audit compliance with state and federal requirements since routine oversight is paused. Prepare documentation and improvement plans for when standard inspections resume. 
• Staff Management: Keep staff informed about regulatory updates and any changes in reimbursement or billing practices. Encourage staff to report potential quality-of-care issues promptly, as complaint investigations will still be conducted for serious allegations.
• Telehealth Adjustments: For telehealth, operate strictly within the reinstated pre-pandemic regulations. Warn patients that some services are no longer reimbursed and help identify in-person alternatives, especially for therapies and home-based care.

Preserving Program Access

• Maintain Documentation: Keep detailed records of care processes and financial transactions to ensure transparency and readiness for any post-shutdown audits or enforcement actions.

Providers should combine vigilance, supportive communication, and strategic resource management to maintain quality care and operational continuity throughout the shutdown period.

Excelas helps uncover and organize documentation that can defend against retroactive claims, even when the original paperwork is flawed or fragmented.

MEET THE TEAM

Carrie Bencic

Manager of Client Relationships

Carrie began her career at Excelas right after graduation from Vanderbilt University. As the Manager of Client Relationships, Carrie is the main point of contact for clients.

Outside of work, you can find Carrie sailing, walking her dog Rigatoni, spending time with family and friends, traveling, or volunteering at Cuyahoga County Animal Shelter.

As we enter the fourth quarter, to ensure everything is finalized well before year-end, now is the ideal time to submit your work for review. Contact Excelas today!

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