The change has important implications for FQHC and RHC medical coding, Medicare telehealth billing, documentation, claim workflows, and compliance. Coding and billing teams should begin reviewing their processes now to prepare for the October 1 implementation date.
What Is Changing for FQHC and RHC Telehealth Billing?
Historically, FQHCs and RHCs have used HCPCS code G2025 to report many Medicare distant-site telehealth services. G2025 provided a simplified approach to telehealth billing but did not identify the specific service delivered through telehealth.
Beginning October 1, 2026, FQHCs and RHCs will no longer report these telehealth visits using G2025. Instead, the claim must include the actual CPT or HCPCS code that represents the service performed.
For example, depending on the documented service, an AteleHealth encounter may be reported using an appropriate office visit code, such as
- 99213 - Established patient office visit
- 99214 - Established patient office visit
- Other applicable telehealth CPT or HCPCS codes
The selected code must accurately reflect the service documented and provided.
Which Telehealth Modifiers Are Required?
In addition to reporting the appropriate CPT or HCPCS code, FQHCs and RHCs must append the applicable telehealth modifier.
Modifier 93: Audio-Only Telehealth
Modifier 93 is used for a synchronous telemedicine service delivered through a telephone or another real-time interactive audio-only telecommunications system.
Modifier 95: Audio and Video Telehealth
Modifier 95 is used when the encounter is conducted through a real-time interactive audio and video telecommunications system.
For example, if an established patient follow-up includes moderate medical decision-making and is conducted through real-time video, the example in the guidance uses 99214-95. Under the previous methodology, the same service would likely have been reported using G2025.
What Does This Mean for FQHC and RHC Medical Coding?
The transition from G2025 to service-specific coding means documentation and coding will need to be more closely aligned.
Providers must document enough information to support the specific CPT or HCPCS code reported. General telehealth documentation alone will no longer be sufficient.
For coders, the October 1 change means they will need to:
- Assign the appropriate CPT or HCPCS code based on provider documentation.
- Determine whether modifier 93 or 95 applies.
- Verify that the service is included on the Medicare telehealth services list.
- Ensure medical necessity and applicable coding guidelines are met.
This makes communication between providers, medical coders, and billing teams increasingly important.
How Will Medicare Telehealth Payment Change?
CMS will continue to reimburse telehealth services furnished by FQHCs and RHCs, but payment calculations will follow a new structure.
According to the guidance, payment rates will be updated annually, and payment will be based on the national average of telehealth services paid under the Physician Fee Schedule (PFS). Geographic locality adjustments will not apply.
FQHC beneficiaries will generally be responsible for coinsurance, while RHC beneficiaries will generally be responsible for coinsurance and deductible amounts. Preventive telehealth services remain exempt from coinsurance and deductible requirements.
How Should FQHCs and RHCs Prepare for October 1, 2026?
FQHCs and RHCs should begin preparing their Medicare telehealthMedicaretelehealth billing workflows before the new requirements take effect.
Key preparation steps include:
- Review telehealth coding workflows to identify where G2025 is currently used.
- Update internal SOPs and coding guidance to reflect service-specific CPT and HCPCS coding.
- Train providers, coders, and billing staff on the new requirements.
- Test system edits and modifier logic before implementation.
- Monitor CMS communications for additional implementation guidance.
Billing departments should also remove automatic reliance on G2025, validate telehealth modifier usage, and review payer-specific telehealth requirements.
Why Is CMS Changing FQHC and RHC Telehealth Coding?
The change is intended to provide greater visibility into the specific services being delivered through telehealth.
Under the previous approach, using G2025 did not provide CMS with the same level of service-specific information. Requiring the actual CPT or HCPCS code can help CMS track telehealth utilization, measure service delivery across organizations, support reporting initiatives such asAccountable Care Organizations (ACOs), and improve data accuracy for policy and reimbursement decisions.
Frequently Asked Questions
Prepare Your FQHC or RHC for October 2026 Telehealth Billing Changes
The move from G2025 to service-specific CPT and HCPCS coding represents an important operational change for FQHCs and RHCs providing Medicare telehealth services.
Successful implementation will require coordination across providers, medicalproviders,medical coders, billing teams, and compliance staff. By reviewing workflows, strengthening documentation practices, updating system edits, and training staff ahead of October 1, organizations can prepare for the new telehealth billing requirements and support accurate claim submission.
Nivaran helps healthcare organizations navigate documentation, coding, and revenue cycle requirements with solutions designed to support operational efficiency and compliance.
Contact us today - https://www.nivaran.ai/get-started
