RHC and FQHC Distant Site Telehealth Billing
HCPCS G2025 Is Retired: Bill the Individual Code With Modifier 93 or 95
Summary of the Rule or Edit Change
CMS changed how rural health clinics (RHCs) and federally qualified health centers (FQHCs) bill Medicare for distant site telehealth. The change was announced in Change Request 14468 on May 27, 2026, and CMS wrote it into the Claims Processing Manual on September 29, 2026 through Transmittal 13975 (Change Request 14625). It's effective for dates of service on or after October 1, 2026, and contractors implemented it October 5, 2026.
Here's the core of it. Since 2021, RHCs and FQHCs billed non-behavioral telehealth services under a single code, HCPCS G2025, which includes audio-only visits. That code is now out for these claims. Starting October 1, you bill the individual CPT or HCPCS code that describes the telehealth service you furnished, plus the revenue code and one of two modifiers: 95 for real-time audio and video, or 93 for audio-only. CMS publishes the eligible codes each year with the Physician Fee Schedule rule, on its list of Medicare telehealth services.
A few related rules came along with the update. The CS modifier you used to flag cost-sharing waivers with G2025 isn't needed anymore, because coinsurance and the deductible are waived for preventive services under the standard rules. FQHCs don't have to report an FQHC PPS payment code, or a qualifying visit code, when telehealth is the only service on the claim. Telehealth is also the only FQHC service subject to the Part B deductible. The originating site facility fee still goes on a clinic claim with revenue code 0780 and HCPCS Q3014.
Mental health visits don't change. Since January 2022, those have been billed like in-person visits with the right revenue code and modifier 95 or 93, never with G2025. And CR 14625 itself says it contains no new policy: it brings the manual in line with the May change. The weighted average payment method set up during the public health emergency continues for non-behavioral distant site services through December 31, 2027, or a later date if Congress extends it.
Action Required for Billing Teams
Do the math on your telehealth volume. If a clinic furnishes 300 distant site telehealth visits a month and the average claim line is worth $95, that's about $28,500 a month sitting on lines that need the new coding. Even a 10% rejection rate means roughly $2,850 a month in claims waiting on rework, and the one-year Medicare filing limit keeps running while they wait.
- Remove G2025 from telehealth charge lines. Replace it with the individual CPT or HCPCS code from CMS's telehealth services list for dates of service on or after October 1, 2026.
- Map modifier 95 and modifier 93. Use 95 for real-time audio and video visits and 93 for audio-only visits, and attach the right revenue code on every line.
- Retire the CS modifier on these claims. You no longer need it to flag preventive services.
- Keep mental health visits separate. They keep following the in-person billing pattern with modifier 95 or 93.
- Check the originating site fee. Confirm Q3014 with revenue code 0780 is set up for patients who are at your clinic.
- Review FQHC telehealth-only claims. Make sure no PPS payment code or qualifying visit code is forced onto them.
- Test a batch before you release it. Send a small group of October claims and read the first remits before you bill the rest.
For how RHC payment works overall, our guide to rural health clinic billing in 2026 covers the visit definition, the all-inclusive rate and the claim structure. Our FQHC billing guide and telehealth billing guide cover the rest.
Verifiable References
- CMS. Transmittal 13975, Change Request 14625: Updates to Medicare Claims Processing Manual, Chapter 9, Rural Health Clinics/Federally Qualified Health Centers. cms.gov/files/document/r13975cp.pdf
- CMS. List of Telehealth Services for Medicare. cms.gov/medicare/coverage/telehealth/list-services
- CMS. Medicare Claims Processing Manual, Chapter 9: Rural Health Clinics and Federally Qualified Health Centers. cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c09.pdf
Related Resources
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