September 30, 2025
Dear Member,
A Sept. 29 White House meeting between the President and congressional leadership from both parties appears to have yielded no significant breakthrough. A shutdown appears increasingly likely. If Congress is unable to pass a funding bill before midnight tonight, the federal government will experience a shutdown.
Should that occur, the U.S. Department of Health and Human Services (HHS) will furlough a large percentage of their staff. HHS staff who administer mandatory programs, including Medicare and Medicaid, will continue to work, and emergency surveillance operations will continue. As such, we anticipate Medicaid and Medicare reimbursements should continue uninterrupted during a shutdown. With staff furloughs, certain Medicaid operations will slow down, and Medicaid-related rulemaking, along with activity related to approval of Medicaid waivers, will be suspended for the length of the shutdown.
SAMHSA Contingency Staffing Plan:
The Substance Abuse and Mental Health Services Administration (SAMHSA) will retain 98 staff (13% of its workforce). This includes:
- 5 exempt staff
- 93 excepted staff
- 39 civil service staff
- 54 Commissioned Corps Officers (CCOs)
SAMHSA Activities That Will Continue:
Core behavioral health programs will remain active, including:
- The Disaster Behavioral Health response teams
- The Disaster Distress Helpline (24/7/365 crisis counseling)
- The 988 Suicide & Crisis Lifeline
Previously funded operations will continue, using available balances. This includes, among others:
- The Treatment Services Locator
- The Treatment Referral Line
Staff will remain available to:
- Route letters indicating suicidal ideation to local crisis services
- Respond to Opioid Treatment Program (OTP) regulation exception requests and emergencies
Most SAMHSA Grants from the prior year (e.g., 988 Crisis Services, State Opioid Response, Mental Health/Substance Use Block Grants) still have funds available to be spent by the grantee, and in such cases recipients should still be able to access these funds; CCOs will be retained to help manage administration of these grant programs. States may be able to continue drawing down funds for state programs that rely on federal funding that was awarded prior to the start of the shutdown.
Activities That Will Not Continue:
Many of SAMHSA’s grants have periods of performance that begin on Sept. 30, so a shutdown lasting less than one month would have less impact than a longer shutdown. However, a shutdown would leave new grantees without support in carrying out activities of the program, because many Government Publishing Office (GPO) staff would be furloughed. GPO staff furloughs will delay:
- Responses to grant recipient requests (e.g., prior approvals)
- Summary statements for unfunded applications
- Release of new Notices of Funding Opportunity (NOFOs), reducing turnaround time for FY26 applicants
HHS’s webpage on telehealth policy updates confirms that current Medicare telehealth flexibilities, including the in-person requirements for mental health—are authorized only through Sept. 30, absent congressional action. There is no indication of discretionary leniency or automatic extension beyond Sept. 30.
Should the telehealth waivers expire on Sept. 30, the Centers for Medicare and Medicaid Services has stated “the statutory limitations that were in place for Medicare telehealth services before the COVID-19 [public health emergency] will retake effect for most telehealth services” starting Oct. 1.
CMS has not provided updated guidance on how the agency plans to address any lapse in authorization of existing telehealth flexibilities. Both parties’ continuing resolution proposals included an extension for telehealth flexibilities.
The National Council will continue to provide updates on shutdown-related news as events continue to unfold. If you have any questions related to the potential shutdown or any other policy issues, contact the National Council Policy team at Policy@TheNationalCouncil.org.
Thank you so much!