Medicare Telehealth Billing Changes for FQHCs and RHCs: What You Need to Know for October 1, 2026
Medicare telehealth billing changes for FQHCs and RHCs are set to take effect on October 1, 2026, following new guidance from the Centers for Medicare & Medicaid Services (CMS). These changes will significantly impact how Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) bill Medicare for distant-site telehealth services.
For coding, billing, and compliance teams, understanding these Medicare telehealth billing changes now will be essential to ensure a smooth transition, maintain compliance, and prevent claim submission issues.
At CodeEMR, we understand that regulatory updates can directly affect coding accuracy, reimbursement, and operational efficiency. As organizations move away from the longstanding G2025 billing methodology, proactive preparation will be critical for maintaining compliance and protecting revenue.
Background
During the COVID-19 Public Health Emergency (PHE), Congress authorized FQHCs and RHCs to serve as distant-site telehealth providers for Medicare beneficiaries. This flexibility has since been extended through federal legislation and is currently authorized through January 1, 2028.
Historically, Medicare telehealth services provided by FQHCs and RHCs have been reported using a single HCPCS code:
G2025 – Payment for a telehealth distant site service furnished by an RHC or FQHC only
While this simplified billing processes, it offered limited visibility into the specific telehealth services being delivered.
What Is Changing?
Beginning October 1, 2026, FQHCs and RHCs will no longer bill telehealth visits using HCPCS code G2025. Instead, organizations will be required to report the actual CPT or HCPCS code that accurately reflects the service performed.
✅ Current Billing Process
Telehealth services are generally billed using:
- G2025
✅ New Billing Process
Organizations will now report the specific service furnished, such as:
- 99213 – Established patient office visit
- 99214 – Established patient office visit
- 99441–99443 – Telephone E/M services (when applicable)
- Other approved telehealth CPT/HCPCS codes
The selected code must accurately align with the documented medical service provided.
For coding teams, this change increases the importance of precise clinical documentation and coding specificity – areas where experienced coding support can significantly reduce reimbursement risk.
Telehealth Modifiers Required
In addition to reporting the appropriate CPT or HCPCS code, providers must append the correct telehealth modifier.
✅ Modifier 93
Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System
Use when the encounter is conducted through audio-only technology.
✅ Modifier 95
Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System
Use when the encounter includes real-time audio and video communication.
Example
✅ Provider Documentation
- Established patient follow-up
- Moderate medical decision making
- Conducted through video
✅ Coding
- 99214-95
Under the previous billing methodology, this same encounter would likely have been billed as G2025.
Payment Methodology Changes
CMS will continue reimbursing telehealth services furnished by FQHCs and RHCs; however, reimbursement calculations will follow a revised payment structure.
According to CMS:
- Payment rates will be updated annually
- Payment will reflect the national average of telehealth services under the Physician Fee Schedule (PFS)
- Geographic locality adjustments will not apply
- FQHC beneficiaries will generally be responsible for coinsurance
- RHC beneficiaries will generally be responsible for coinsurance and deductibles
- Preventive telehealth services remain exempt from coinsurance and deductible requirements
What This Means for Coding and Billing Teams
These changes will require closer collaboration among providers, coders, billing teams, and compliance staff.
✅ For Providers
Clinical documentation must support the specific CPT or HCPCS code billed. General telehealth documentation will no longer be sufficient.
✅ For Coders
Coding teams will need to:
- Assign the correct CPT or HCPCS code based on provider documentation
- Determine whether modifier 93 or 95 applies
- Confirm the service is included on the Medicare telehealth services list
- Ensure coding accuracy, medical necessity, and compliance requirements are met
✅ For Billing Teams
Billing departments should prepare by:
- Updating billing workflows and claim edits
- Eliminating automatic reliance on G2025
- Validating telehealth modifier usage
- Reviewing payer-specific telehealth billing requirements
Healthcare organizations that lack internal coding bandwidth may benefit from specialized coding and billing support to maintain compliance and reduce denial risks during the transition.
Why CMS Is Making This Change
CMS has indicated that reliance on G2025 alone limited insight into the types of telehealth services being delivered.
By requiring service-specific CPT and HCPCS reporting, CMS can better:
- Track telehealth utilization trends
- Measure service delivery across organizations
- Support reporting initiatives, including Accountable Care Organizations (ACOs)
- Improve reimbursement and policy decision-making through better data accuracy
How FQHCs and RHCs Can Prepare Now
Organizations should begin preparing well before the implementation date by:
- Reviewing telehealth coding workflows
- Updating internal SOPs and coding policies
- Training providers, coders, and billing teams
- Testing billing system edits and modifier logic
- Monitoring CMS guidance for future updates
At CodeEMR, we help healthcare organizations strengthen coding accuracy, billing efficiency, and compliance readiness through specialized medical coding and revenue cycle support services.
Final Thoughts
The October 1, 2026 telehealth billing update represents a major operational shift for FQHCs and RHCs.
The transition from G2025 to service-specific CPT and HCPCS coding will improve reporting accuracy but also introduce new documentation, coding, and billing responsibilities.
Organizations that begin preparing early – through workflow updates, staff training, and coding process improvements – will be better positioned to maintain compliance, reduce denials, and protect reimbursement outcomes.
Need support navigating evolving coding requirements?
CodeEMR provides expert medical coding, billing, and RCM support to help healthcare organizations adapt confidently to changing regulations.
Learn more: https://www.codeemr.com/