Jun 17, 2026
A New Way to Bill for Medical Services: CMS Changes the Process for FQHCs/RHCs, Not the Policy
CCHP
On May 27, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a Change Request (CR) that impacts how federally qualified health centers (FQHCs) and rural health clinics (RHCs) will bill as distant sites for telehealth services provided on October 1, 2026 and after. Currently, FQHCs and RHCs may bill medical services delivered via telehealth using code G2025. Billing with G2025 provides FQHCs and RHCs with a rate calculated by CMS, which currently is equal to a little under $100. Additionally, with the passage of HR 7148, this ability for FQHCs/RHCs to provide medical services via telehealth and be reimbursed by CMS was extended through December 31, 2027. It is important to highlight that the CR recently issued by CMS will not impact the overall allowance (currently through 2027) for FQHCs and RHCs to provide medical services via telehealth and be reimbursed. It only changes the billing instructions required to receive reimbursement for such services.
In the CR, CMS directs that medical services provided by an FQHC or RHC via telehealth, effective October 1, 2026, shall be billed using the appropriate Current Procedural Terminology (CPT) or Healthcare Common Procedure Coding System (HCPCS) code instead of G2025. This is a change from how FQHCs/RHCs have been billing for non-behavioral telehealth since the beginning of the pandemic. The eligible services and codes will continue to be those that are included on the Medicare List of Telehealth Services. Additionally, the CR instructs FQHCs and RHCs to use the appropriate modifier:
- 93: Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System OR
- 95: Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System
The payment rate will still be an amount calculated by CMS. The CR notes:
- The payment rate is updated annually.
- The payment rate 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.
- The payment rate is not adjusted for geographic locality.
- For RHCs, beneficiary deductible and coinsurance apply. For FQHCs, beneficiary coinsurance applies.
- Coinsurance is based on the lesser of the payment rate or submitted charges.
- Coinsurance and deductible are waived for preventive services.
Therefore, while the process for billing for medical services delivered via telehealth may change, the FQHC/RHC will still continue to receive a calculated flat rate.
The reason behind this change in billing process is related to CMS’ desire to know exactly what services have been provided via telehealth – which they have indicated is something FQHC/RHCs would also like to track. This new change is also in line with the expressed wish of the current Administration to have more detailed data on health care spending to assist with future decision making.
It should be noted that this billing change for FQHCs/RHCs applies only to medical services delivered via telehealth specifically. In 2022, CMS adopted a rule that added the provision of services through telecommunications technology to the definition of a mental health visit for an FQHC/RHC. For Medicare, telehealth is statutorily defined as a service provided via a telecommunications system, which allows CMS to differentiate mental health services provided via technology by an FQHC/RHC from traditional telehealth services. Since the 2022 rule was adopted, FQHC/RHCs have billed mental health services delivered through technology as mental health visits rather than telehealth visits, which results in these services being reimbursed under the all-inclusive rate or Prospective Payment System (PPS). Therefore, the current Change Request, which is limited to medical services provided via telehealth, does not affect the billing of mental health services delivered through telecommunications technology for FQHC/RHCs.
It should also be stressed again that this change will not go into effect until October 1, 2026. Therefore, FQHCs and RHCs should continue to bill for telehealth services the same way they have been until the policy goes into effect on October 1, 2026.
Access the CMS Change Request and Medicare Learning Network (MLN) article for more information regarding this upcoming change in FQHC/RHC telehealth medical services billing. |
|
See original resource at : How we work - CCHP