G2025 Retires October 1: New Telehealth Billing for RHCs, FQHCs
Starting October 1, 2026, rural health clinics and FQHCs must bill individual CPT/HCPCS codes for distant-site telehealth instead of G2025. What changes and how to prepare.
The catch-all is going away. For dates of service on or after October 1, 2026, rural health clinics and federally qualified health centers must bill Medicare distant-site telehealth using the individual CPT or HCPCS code for each service — plus the matching modifier — instead of lumping everything under HCPCS G2025. CMS issued the instruction in Change Request 14468 this spring, and the effective date is now about five weeks out.
Since 2020, G2025 has let RHCs and FQHCs bill telehealth with one code regardless of what the visit actually was. Convenient, but opaque: CMS couldn't see what services were being delivered, and clinics couldn't easily compare their telehealth mix against anything. The new requirement trades that convenience for specificity.
What changes on the claim
Three moving parts, all of them mechanical:
- The service code. Report the specific CPT or HCPCS code that describes what was furnished — the same codes on the Medicare telehealth list that other providers use. CMS publishes that list annually with the Physician Fee Schedule.
- The modifier. Append modifier 95 for real-time audio-video visits or modifier 93 for audio-only.
- The revenue code. Pair the service code with the appropriate revenue code on the institutional claim.
Payment, per CMS, continues to be based on the national average Physician Fee Schedule telehealth rates — this is a reporting change, not a new payment methodology. Our telehealth reimbursement guide covers how the RHC/FQHC pathway fits into the broader Medicare picture.
The five-week to-do list
The clinics that will have a smooth October are doing three things now. First, pull the last six months of G2025 claims and map every visit type to its specific code — most clinics discover their telehealth volume concentrates in a handful of E/M and behavioral health codes. Second, confirm the EHR and clearinghouse can carry the modifier and revenue-code pairing on institutional claims; this is exactly the kind of change that works in theory and dies in a claim scrubber. Third, brief whoever audits denials, because early October rejections will look like payer error when they're actually mapping gaps.
Worth remembering the larger context: RHC and FQHC distant-site telehealth authority itself currently runs on the extension Congress passed in February — covered in our report on the Medicare extension through 2027. Verify current billing requirements with your Medicare Administrative Contractor before October.
Frequently asked questions
- What replaces G2025 for RHC and FQHC telehealth billing?
- For dates of service on or after October 1, 2026, RHCs and FQHCs report the individual CPT or HCPCS code that describes the telehealth service furnished, with the appropriate revenue code and modifier 95 for audio-video visits or modifier 93 for audio-only.
- Does the October 2026 change cut RHC or FQHC telehealth payment?
- CMS has indicated payment continues to be based on the national average Physician Fee Schedule telehealth rates. The change is about reporting specificity, not a new payment methodology — but clinics should still verify rates for their highest-volume codes.
- Which codes can RHCs and FQHCs bill for telehealth?
- The eligible services are the ones on the Medicare telehealth list, which CMS posts and updates annually alongside the Physician Fee Schedule. Billing teams should map their current G2025 volume to specific codes from that list before October.