As the January 30 funding deadline for Fiscal Year 2026 appropriations nears, LeadingAge is monitoring federal agency activities and potential impact on providers by care settings and community types, as well as funding for certain programs impacting aging services, to help members navigate a government shutdown, should one come to pass.

AGENCIES: HUD, HHS, CMS

For members who engage with the Department of Housing and Urban Development (HUD), as of January 27, 2026 the agency had not released any changes to the Contingency Plan released in September 2025, though changes are not necessarily expected.

For members who engage with the Department of Health & Human Services (HHS), as of January 27, 2026 the agency had not released any changes to the Contingency Plan released in September 2025, though changes are not necessarily expected.  Also unchanged: the Centers for Medicare & Medicaid Services (CMS) Lapse Plan.

It’s important to note that agency staffing will be significantly reduced during a lapse in appropriations, impacting operations across settings. During the first FY 26 lapse in appropriations, claims processing was significantly impacted, with an initial hold placed on all Medicare claims and additional holds placed on telehealth claims. It is likely that claims will once again be impacted by a shutdown, particularly given the limbo-state of telehealth extenders, though actual funding for the Medicare program is not impacted.

In addition, during a lapse in appropriations, while claims processing is likely to be a prioritized activity for the Medicare Administrative Contractors (MACs), CMS is unable to provide oversight of contractors.

NURSING HOMES

Nursing home providers should be aware that activities performed by CMS contractors such as nursing home revalidations, Minimum Data Set (MDS) audits, and payroll-based journal (PBJ) audits may be interrupted. Providers should continue to prepare for and comply with stated deadlines regardless.

Nursing home survey activity will once again be significantly reduced in the event of a lapse in appropriations. Standard recertification surveys and initial certification surveys will be suspended, as well as complaint surveys that are triaged at non-harm levels. State licensure surveys may continue, but these should not be expected to be accepted as federal certification (standard recertification) surveys. During the most recent lapse in appropriations, several states continued licensure surveys and CMS maintained that these surveys would not be accepted for federal certification requirements.

The quarterly refresh of Nursing Home Care Compare will take place on Wednesday, January 28 and will not be impacted by a potential shutdown.

However, CMS had previously announced intent to remove complaint totals from Nursing Home Care Compare in February due to errors in how this data is generated. Should a lapse in appropriations occur, this change will be delayed if the shutdown is still in effect when the February monthly update of Nursing Home Care Compare is scheduled to occur on February 25.

Home Health and Hospital at Home Providers 

Home health survey activity, either certification or recertification, is not authorized. Home health survey activity will include investigations at the immediate jeopardy or alleging actual harm levels. Home health face to face telehealth flexibilities will expire. The face-to-face encounter must occur within 90 days prior to the Start of Care (SOC) or 30 days after the SOC. This visit will need to be in person as of January 31, 2026. Home health G Codes reported on claims for telehealth will not be impacted. Regarding Care Compare updates, home health updates were posted earlier in January. Hospital at home programs be required to discharge patients or readmit patients as of January 31, 2026. Prescribing of controlled substances via telehealth will not be impacted as it was extended in a separate final rule issued by the Drug Enforcement Agency in late December until December 31, 2026.

Part B Telehealth Services

The expiration of appropriations on January 30, 2026, means that telehealth will be inaccessible for millions of Medicare beneficiaries. Providers using these flexiblities as well as members supporting Medicare patients in their communities should be aware of the changes which may limit access to care for patients. If you are providing Part B services, such as palliative care through telehealth, LeadingAge is recommending providers prepare Advance Beneficiary Notice regarding their possible responsibility for telehealth services which may not be covered in the event of a government shutdown.

Part B billing of telehealth services:

• The home can no longer be an originating site and must instead be a facility location like a hospital, skilled nursing facility, physician office, etc.
• Geographic restrictions will go back into place, meaning the originating site must be located in a certain geographic location: in a rural health professional shortage area (HPSA); located in a county that is not included in a Metropolitan Statistical Area (MSA); or within a federal telehealth demonstration project.
• Two-way, interactive, audio-video technology will be required for telehealth.
• The scope of practitioners who can provide telehealth services are limited. Occupational therapists (OT); physical therapists (PT); speech language therapists (SLP), and audiologists are excluded.

HOSPICE PROVIDERS

Should Congress fail to reach agreement on a spending package by January 30, hospice providers should be prepared for the potential expiration of the telehealth face-to-face visits. LeadingAge encourages members to review upcoming face-to-face visits in the next 30 days and prioritize their completion either through in person or telehealth visits.

If Congress does come to an agreement on the current spending package proposal, the hospice face-to-face recertification via telehealth would be extended until December 31, 2027. For more information see this article, Telehealth Flexibilities: Possible Lapse, Potential New Guardrails.

AFFORDABLE HOUSING

Similar to the first FY26 lapse in appropriations, HUD will continue to pay monthly rental assistance payments to housing providers, but will not be able to obligate new funds. This means that ongoing Housing Assistance Payments (HAPs) will continue to be paid during a lapse in appropriations for as long as HUD has funding available.

HUD told LeadingAge that it has the funding it needs to pay rental assistance through March. However, agency staffing is significantly reduced during a lapse in appropriations, significantly impacting HUD operations and transactions. More information on HUD’s contingency plan and the impacts of a lapse in appropriations are available here.

PROGRAMS: Supplemental Nutrition Assistance and Low Income Home Energy Assistance

During the previous government shutdown in October 2025 had significant impacts on the distribution of Supplemental Nutrition Assistance Program (SNAP) and Low-Income Home Energy Assistance Program (LIHEAP) benefits to many older adults who qualified for the programs. The impact was larger because the shutdown occurred at the end of the federal fiscal year with no approved contingency funding for the programs. In the Continuing Resolution signed into law November 15, 2025, both programs were fully funded through the 2026 fiscal year ending September 30, 2026.

LeadingAge will continue to monitor Congressional activity and provide additional updates should a lapse in appropriations occur.