RHC and FQHC Telehealth Billing After G2025

For Medicare dates of service on or after October 1, 2026, rural health clinics (RHCs) and federally qualified health centers (FQHCs) bill non-behavioral health distant-site telehealth with the individual CPT or HCPCS code that describes the service furnished, instead of the single HCPCS code G2025. Each line also carries the appropriate revenue code and either modifier 95 (real-time audio-video) or modifier 93 (audio-only). CMS set this out in Change Request 14468, issued May 27, 2026, with an implementation date of October 5, 2026 for Medicare Administrative Contractors (MACs). The instruction states that, unless otherwise specified, the effective date is the date of service, so a claim is coded according to when the visit happened, not when it was submitted. October 1 decides which visits take the new coding. October 5 is the implementation date, the date by which CMS directed MACs to have their claims systems updated to process them.

Why CMS replaced the single code

Section 3704 of the CARES Act, enacted in March 2020, first let RHCs and FQHCs furnish distant-site telehealth, and those services were reported with G2025. CMS wrote in the change request that it and the clinics had identified "a program need to identify the specific services furnished" under that one code.

That is the practical problem. G2025 told Medicare that a distant-site telehealth service had been furnished. It did not say which one, so a short follow-up visit and a full evaluation looked the same on the claim.

What goes on the claim

• The service code. Report the CPT or HCPCS code for the distant-site telehealth service. These are the services on Medicare's list of telehealth services, which CMS publishes annually with the Physician Fee Schedule (PFS) rule. RHC and FQHC practitioners can furnish services that are within their scope of practice and approved as distant-site telehealth under the PFS, from any location while they are working for the clinic.
• One of two modifiers. Modifier 95 for a real-time audio and video visit, or modifier 93 for a real-time audio-only visit.
• The revenue code. CMS requires "the appropriate revenue code" alongside the modifier but does not name a specific revenue code for these lines in the change request. Confirm the expected revenue code with your MAC.
• Units. The change request tells MACs to bypass edits that block multiple units on lines with modifier 93 or 95, and to take units into account when applying the rate.

The change request also sets a claim edit: when modifier 93 or 95 is billed with a HCPCS code that is not a distant-site telehealth service code, the claim is returned to the provider. The edit is bypassed on types of bill 710 and 770.

How payment is set

By statute, payment for these services must be similar to the national average payment rates for comparable telehealth services under the PFS. Under the change request, the rate:

• is updated annually;
• is based on the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS;
• is not adjusted for geographic locality.

CMS's RHC and FQHC announcements page says the rate "will continue to be based on" that volume-weighted average. The method did not change with the coding. What changed is that the claim shows which service was furnished.

For RHC claims, the beneficiary deductible and coinsurance apply. For FQHC claims, coinsurance applies. Coinsurance is based on the lesser of the payment rate or submitted charges, and coinsurance and deductible are waived for preventive services. Our telehealth reimbursement guide covers where this pathway sits in Medicare billing more broadly.

Mental health visits follow a separate pathway

Since January 1, 2022, mental health visits an RHC or FQHC furnishes through interactive, real-time telecommunications technology count as face-to-face encounters and are paid under the RHC all-inclusive rate or the FQHC prospective payment system. (Change Request 14468 describes these as behavioral health services.) Since then they have not been billed with G2025, and the G2025 change does not move them onto the telehealth rate.

The change request draws that line on the claim itself. It states that the new telehealth rate table does not apply to service lines with revenue code 0900, which is the revenue code CMS shows for these visits in its mental health visit billing guidance (SE22001). That guidance lists modifier 95 for audio-video visits, modifier FQ or 93 for audio-only visits, and modifier CG as required on RHC claims. CMS has said the in-person visit requirements for these mental health visits will not take effect until after January 1, 2028.

How long the authority runs

Section 6209(c) of the Consolidated Appropriations Act, 2026 extended the flexibilities that let RHCs and FQHCs serve as distant-site telehealth providers until January 1, 2028; CMS describes this as running through December 31, 2027. CMS's February 2026 telehealth FAQ still describes G2025 reporting for that period, but for dates of service on or after October 1, 2026, Change Request 14468 governs how those services are coded. Our report on the Medicare telehealth extension through 2027 covers the wider law.

What to check on your own claims

• Keep the code map current. Map the visit types your clinic billed under G2025 to specific codes, and recheck that map each year when CMS updates the telehealth list with the PFS rule.
• Test the institutional claim. Confirm your EHR and clearinghouse carry the service code, modifier 93 or 95, revenue code, and units together on type of bill 71X (RHC) and 77X (FQHC) claims.
• Read returned claims closely. A claim returned for modifier 93 or 95 on a code that is not a distant-site telehealth code usually points to a mapping gap rather than a payer error.
• Keep mental health visits separate. They follow the SE22001 billing described above, so leave them in their own workflow and out of the distant-site telehealth code map.
• Ask your MAC two things: which revenue code it expects on these lines, since the change request does not name one, and whether it has local instructions of its own.