August 11th, 2026
Emilia Ochoa-Ruiz, MS, PMP
The Centers for Medicare & Medicaid Services (CMS) has announced an important change to how Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) bill Medicare for distant-site telehealth services for dates of service on or after October 1, 2026. CMS released this guidance through Change Request (CR) 14468, with an effective date of October 1, 2026.
What Is Changing?
Beginning October 1, 2026, FQHCs and RHCs will no longer bill Medicare for distant-site non-behavioral health telehealth services using the single HCPCS code G2025. Instead, organizations must bill the specific CPT or HCPCS code that corresponds to the telehealth service provided and is included on CMS’s Medicare telehealth services list.
In addition, providers will be required to report the appropriate telehealth modifier:
- Modifier 93 for synchronous audio-only telehealth and other interactive audio-only telecommunications system services.
- Modifier 95 for synchronous audio-video telehealth and other audio-video telecommunications system services.
CMS also requires FQHCs and RHCs to report the appropriate revenue code along with the applicable telehealth modifier. The new distant-site payment requirements do not apply to service lines reported with behavioral health revenue code 0900.Although FQHCs and RHCs will bill the specific service provided, Medicare payment will be based on the average payment for all services on the Medicare telehealth list, weighted by how often each service is provided. CMS updates this payment rate each year, and it does not vary by geographic location.
Why the Change?
Under the current approach, many telehealth services are reported using a single billing code (G2025), making it difficult to distinguish the specific services being delivered through telehealth. CMS states that organizations to bill the actual CPT or HCPCS code associated with the service furnished, it will have greater visibility into the types of telehealth services being provided.
This change is expected to improve the accuracy of telehealth data collection and reporting while providing better insight into telehealth utilization across Medicare beneficiaries.
What Should FQHCs and RHCs Do Now?
Organizations may want to begin preparing for the transition by:
- Reviewing current telehealth billing workflows.
- Identifying the CPT and HCPCS codes commonly used for telehealth services and confirming that they appear on CMS’s Medicare telehealth services list.
- Updating billing systems, charge masters, and claim submission processes.
- Training coding, billing, compliance, and clinical staff on new documentation and modifier requirements.
- Working with EHR and revenue cycle vendors to ensure system readiness before October 1, 2026.
Key Dates
- May 27, 2026: CMS released Change Request 14468.
- October 1, 2026: New telehealth CMS billing requirements become effective.
- October 5, 2026: CMS implementation date.
Learn More
CMS details the changes in Change Request 14468: Rural Health Clinics & Federally Qualified Health Centers: Billing Distant Site Telehealth Services. Healthcare organizations should review the guidance carefully and consult their billing, compliance, and reimbursement teams to prepare for implementation.
CTRC will continue to monitor federal telehealth policy and reimbursement developments and share updates relevant to California healthcare organizations.
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