Federal Government Shutdown Continues

October 24, 2025 / 6 min read

As reported in our recent article, the Federal Government partially shut down as of October 1, 2025, as Congressional leaders and President Trump failed to reach an agreement to keep the government open. As of the time this article was drafted, the shutdown continues and has become the third longest shutdown in modern history.^[1]With the shutdown heading deeper into October, an interesting question is whether this current shutdown could potentially threaten to break the record for the longest government shutdown of approximately 35 days, which occurred in late December 2018 through late January 2019.^[2]

General Update

At the crux of the stalemate, in main part, is a dispute regarding the extension of federal subsidies for health insurance under the Affordable Care Act which are set to expire at the end of the year.^[3]The debate is centered primarily on whether this issue should be addressed as part of a temporary funding extension to keep the government open, or whether the issue should be negotiated separately and outside the context of funding the government.^[4]While the House passed a “stop gap” continuing resolution to keep the government funded in September, the Senate has been unable to reach a similar agreement despite several attempts.^[5]As of October 20^th, eleven separate votes in the Senate to extend government funding had failed.^[6]

While a complete examination into the shutdown’s impact (and potential impact) is beyond the scope of this article, some noted examples include flight delays, and hundreds of thousands of federal employees who have either been furloughed, laid off, or who are working without pay.^[7] In addition, the Trump Administration has attempted to fire approximately 4,100 federal employees as part of what are referred to as “reductions in force (RIFs)” dismissals.”^[8]However, a federal judge has temporarily blocked the administration’s efforts to effectuate these dismissals.^[9]

Medicare/Medicare Secondary Payer

Regarding Medicare, which is likely of interest to many readers of our blog, the shutdown, as noted in our prior article, is not expected to result in the interruption of Medicare benefits as these benefits are part of mandatory spending which is not subject to the appropriations process.^[10]Of note, Medicare’s annual open enrollment period (October 15^th to December 7^th) has started as scheduled despite the shutdown.^[11]

However, staff reductions could result in interruption of some other services.^[12]For example, it is reported that updates to the Medicare.gov site could be delayed, and there may be delays in the processing of applications for those beneficiaries looking to make a change to their Medicare plan as part of the annual enrollment period. ^[13]Further, CMS’s contingency plan, FY 2025 Lapse Plan Center for Medicare and Medicaid Services (CMS), outlines several activities that will not continue during a shutdown.^[14]For example, CMS notes that “policy and rule-making” could be impacted stating “CMS payment rule development and other policy decisions would depend on the funding source and duration of a lapse in appropriation. With limited staff to review and provide operational support, we would expect delays in rule-making and other policy development.”^[15]Other impacted activities noted by CMS include health care facility survey and certification, contract oversight, outreach and education (which would include Medicare card, and other mailings), and beneficiary casework.^[16]

Regarding Medicare secondary payer (MSP) activities conducted by CMS contractors, as we reported in our prior article and per Verisk’s recent outreach to CMS’s contractors, the Commercial Repayment Center (CRC), the Benefits Coordination and Recovery Center (BCRC), and Workers’ Compensation Review Center (WCRC), we have confirmed that these entities are funded through the fiscal year, and the shutdown is not expected to impact MSP contractor operations. In this regard, we have not experienced any interruption in MSP contractor activities.

Of note, one apparent casualty of the shutdown in the MSP area was CMS’s cancellation of its TPOC/WCMSA webinar.^[17]This webinar was scheduled for October 1^st (the same day the government shutdown began). CMS cancelled this webinar shortly before it was scheduled to start and noted that it was postponed “until further notice.” While CMS’s notice canceling this webinar did not specifically cite the shutdown as the reason why the webinar was cancelled, it would seem reasonable to assume that it was related to the shutdown.

For many, CMS’s cancellation of this webinar was likely disappointing, given the many unexpected actions CMS has taken since implementing its new TPOC/WCMSA beginning April 4, 2025. More specifically, as outlined in our recent article, these actions have included premature closing of pending MSA submissions in certain instances, automatic conversion of approved MSAs to non-approved MSAs, conversion of Professional Administration to Self-Administration, and unexpected outreaches by an EDI representative to investigate discrepancies on a case-by-case basis. Each of these CMS actions can significantly impact beneficiaries, and impact claims handling and WCMSA settlement practices going forward. Further, it is noted that none of these actions were announced or discussed by CMS as part of the agency’s extensive roll-out of its new reporting requirements prior to the April go-live date. Thus, many were hoping CMS would provide clarification and further guidance on these points as part of its webinar, which was ultimately postponed as noted above.

As of this time, CMS has not rescheduled its TPOC/WCMSA webinar. Verisk will continue to monitor any additional developments in this area and provide updates as warranted. In the interim, please see Verisk’s TPOC/WCMSA Resource Center to learn more about how Verisk’s services can help you meet the new compliance challenges.

Social Security

With respect to social security, the shutdown is not expected to result in a disruption of social security benefits since these benefits are covered by mandatory spending which has already been approved by Congress without an expiration date.^[18]Thus, Social Security recipients including retirees, disabled Americans and the dependents of deceased workers are not expected to experience any interruption in their monthly payments.^[19]However, it is noted that other social security services could be disrupted, including beneficiary benefit verifications, earnings record corrections and updates, overpayments processing, and replacing Medicare cards.^[20]On this point, there are reports that in-person support for beneficiary benefit verification letters has been suspended, although beneficiaries can still reportedly access these letters online and through the Social Security Administration’s automated phone system.^[21]In this context, “verification letters” refer to letters the Social Security office provides a beneficiary to assist them in obtaining aid like housing assistance, fuel assistance, and help from nonprofits.^[22]

In addition, based on our handling of MSP claims for our customers and observations thus far, we have been advised by certain Social Security Administration offices that they are unable to process third-party social security status verifications due to the shutdown. These requests are typically used to determine the potential applicability of a Medicare set-aside. Based on prior experience, we expect the SSA to resume processing these requests once the government shut down is lifted. In the interim, the claimant may be able to expedite this process by establishing an account at https://www.ssa.gov/myaccount to request a Benefit Verification. Verisk continues to monitor this situation and will provide updates as warranted.

Questions?

Please do not hesitate to contact the authors if you have any questions. In the interim, the Verisk policy team will continue to monitor the situation and provide updates as warranted.

[1] Becket, S., Yilek, C., Quinn, M. Government shutdown becomes the third-longest in history with no end in sight on Day 18. CBS News. https://www.cbsnews.com/live-updates/government-shutdown-2025-latest-senate-day-17/

[2] This prior shutdown occurred between December 21, 2018 and January 25, 2019. Lee, C. (2025, Oct. 10). Charts US government shutdown length and history. CNN. https://edition.cnn.com/politics/longest-government-shutdown-vis and Jalonick, Mary Clare. (2025, September 29). A look at previous government shutdowns and how they ended. Federal News Network. https://federalnewsnetwork.com/government-shutdown/2025/09/a-look-at-previous-government-shutdowns-and-how-they-ended/ Of note, these two resources calculated this shutdown as lasting 35 days. In contrast, other sources have calculated this prior shutdown at 34 days. The Longest Government Shutdowns in U.S. History. TIME. https://time.com/7325137/government-shutdown-longest-history/ and Roberts, G., Iyer, K. (2025, Oct. 2) and Yilek, C. (2025, Oct. 17). What is a government shutdown? Here’s what happens when funding runs out. CBS News. https://www.cbsnews.com/news/government-shutdown-2025-what-happens/

[3] Hussein, F., Cappelletti, J., Bedyan, J., Riddle, S. (2025, Oct. 15). Federal workers endure financial strain and fear layoffs as the government shutdown drags on. AP News. https://apnews.com/article/congress-federal-workers-shutdown-layoffs-5bef57b6c431830a9af84fbfcc59b324 On this point, this resource states: “The shutdown began on Oct. 1 after Democrats rejected a short-term funding fix and demanded that the bill include an extension of federal subsidies for health insurance under the Affordable Care Act. Trump and other Republican leaders have said the government must reopen before they will negotiate with Democrats on the health subsidies.” Id. Expanding on this point, the current logjam has also been described as follows: “Democrats are demanding an extension of tax credits that have helped millions of people afford health insurance since the coronavirus pandemic, while Republicans have refused to negotiate until Congress passes a funding bill to reopen the government.” Cappelletti, J., Sanders, L. (2025, Oct. 16). Who’s winning the blame game over the shutdown? Here’s what a new AP-NORC poll shows. AP News. https://apnews.com/article/poll-government-shutdown-blame-trump-republicans-democrats-12c01432bbb43746b6d8d32390c959f4

[4] Hubbard, K. (2025, Oct. 1). Why did the government shut down? Here’s what behind the funding lapse. CBS News. https://www.cbsnews.com/news/government-shutdown-2025-funding-congress/ On this point, this resource provides further explanation as follows:“This time around, Democrats have refused to help Republicans in the majority extend government funding without addressing health insurance subsidies that are set to expire at the end of the year. Republicans have been steadfast in their belief that health care and other issues should be negotiated outside the context of funding the government, and urged Democrats to agree to a temporary funding extension. On Sept. 19, House Republicans passed what's known as a continuing resolution to keep the government funded at existing levels until Nov. 21. Republicans touted the ‘clean’ continuing resolution that would give lawmakers more time to work out full-year spending bills. But Democrats insisted that Republicans negotiate with them on the funding plan to earn their support. Although Republicans have majorities in the House and Senate, most legislation in the upper chamber is subject to a 60-vote threshold to advance. With 53 Republicans, Democratic support is necessary. Meanwhile, Democrats pushed their own proposal to avert a shutdown with a bill that would keep the government funded until Oct. 31. Their bill also includes a number of their priorities, including a permanent extension of enhanced tax credits for Americans who purchase health insurance through the Affordable Care Act marketplace, which became a red line for their support. Both the House-passed bill and the Democratic proposal fell short in the Senate, as the two parties became locked in a stalemate over the funding plan.” Id. In addition, it is reported that Democrats also want any government funding bill to reverse the Medicaid cuts in President Trump’s mega-bill passed this summer, which do not go into effect immediately but are already driving some states to cut Medicaid payments to health providers. https://apnews.com/article/health-care-subsidies-congress-shutdown-democrats-republicans-bb3464820a347fd2c0399e78e335881e

[5] H.R. 5371. Continuing Appropriations and Extensions Act, 2026 (119^th Congress, 2025-2026). See also, Walsh, D. (2025, Oct. 17). With some shutdown pain points delayed, talks in Congress are ‘nowhere.’ NPR. https://www.npr.org/2025/10/17/nx-s1-5577136/government-shutdown-congress-trump and Kapur, S., Wong, S. (2025, Oct. 14). Both parties brace for a ‘long conflict’ as government shutdown hits two-week mark. NBC News. https://www.nbcnews.com/politics/congress/both-parties-brace-long-conflict-government-shutdown-two-week-mark-rcna236970

[6] Benson, C., Walsh, S. (2025, Oct. 20), Shutdown Day 20: Senate Dems reject bill to end government shutdown for the 11^th time. UPI. https://www.msn.com/en-us/news/politics/shutdown-day-20-senate-dems-reject-bill-to-end-government-shutdown-for-11th-time/ar-AA1OPD7a?ocid=BingNewsSerp

[7] Cappelletti, J., Sanders, L. (2025, Oct. 16). Who’s winning the blame game over the shutdown? Here’s what a new AP-NORC poll shows. AP News. https://apnews.com/article/poll-government-shutdown-blame-trump-republicans-democrats-12c01432bbb43746b6d8d32390c959f4 and Hussein, F., Cappelletti, J., Bedyan, J., Riddle, S. (2025, Oct. 15). Federal workers endure financial strain and fear layoffs as the government shutdown drags on. AP News https://apnews.com/article/congress-federal-workers-shutdown-layoffs-5bef57b6c431830a9af84fbfcc59b324

[8] Svirnovskiy, G. (2025, Oct. 14). White House to continue reductions in force as shutdown drags on. Politico. https://www.politico.com/live-updates/2025/10/14/congress/more-rifs-00607296

[9] Judge Temporarily Blocks the Trump Administration From Firing Workers During the Government Shutdown. (2025, Oct. 10). U.S. News by Associated Press. https://www.usnews.com/news/politics/articles/2025-10-15/judge-says-shes-inclined-to-block-the-trump-administration-from-firing-workers-during-the-shutdown This article notes that the Judge who issued this order is U.S. District Judge Susan Illston from the United States District Court for the Northern District of California. Id.

[10] Government Shutdowns Q&A: Everything You Should Know. Committee for a Responsible Federal Budget. https://www.crfb.org/papers/government-shutdowns-qa-everything-you-should-know#whatisashutdown

[11] Blake, S. (2025, Oct. 14). Medicare update: Open enrollment starts this week amid government shutdown. Newsweek. https://www.msn.com/en-us/health/other/medicare-update-open-enrollment-starts-this-week-amid-government-shutdown/ar-AA1OoDUS?ocid=BingNewsSerp

[12] D’Amico, Esther. (n.d.) How Medicare Would Be Affected By A Government Shutdown. Kiplinger. https://www.kiplinger.com/retirement/medicare/medicare-affected-government-shutdown

[13] Blake, S. (2025, Oct. 14). Medicare update: Open enrollment starts this week amid government shutdown. Newsweek. https://www.msn.com/en-us/health/other/medicare-update-open-enrollment-starts-this-week-amid-government-shutdown/ar-AA1OoDUS?ocid=BingNewsSerp

[14] Centers for Medicare and Medicaid Services. (2025, September 25). FY 2026 Lapse Plan Center for Medicare and Medicaid Services (CMS). HHS.gov. https://www.hhs.gov/about/budget/fy-2026-cms-contingency-staffing-plan/index.html

[15] Id.

[16] Id.

[17] In terms of the focus of this webinar (which was since cancelled as noted above), CMS’s notice stated as follows: “CMS will be hosting a WCMSA Reporting Webinar. The intent of this webinar is to review the WCMSA reporting process that was implemented this past April, as well as to discuss, from CMS’s perspective, some of the issues encountered as well as WCMSA reporting best practices. As parties impacted by the WCMSA reporting, we also welcome anyone else involved in the submission and administration of WCMSAs, including attorneys and Medicare beneficiaries, to join. Please bear in mind that this Webinar is intended to broadly address the WCMSA reporting process, so questions regarding specific cases are not appropriate for this setting.” See, https://www.verisk.com/4a5d50/siteassets/iso-claims-partners/blog-material/wcmsa-reporting-webinar-annoucement.pdf.

[18] Hubbard, Kaia, et al. (2025, September 29). Government shutdown looms as leaders make little progress at White House meeting with Trump. CBS News. https://www.cbsnews.com/live-updates/government-shutdown-latest-trump-congress-white-house/

[19] Id.

[20] Id.

[21] Lopez, L. (2025, April 10). Shutdown limits Social Security benefit verification letters. NPR. https://www.npr.org/2025/10/10/nx-s1-5566395/social-security-shutdown-benefit-verification-letters

[22] Id.