Rural Health Clinics and Federally Qualified Health Centers have relied on a single billing code for distant site telehealth services since 2020. Effective October 1, 2026, that convenience disappears. The Centers for Medicare & Medicaid Services (CMS) issued Change Request 14468 on May 27, 2026, instructing Medicare Administrative Contractors to require RHCs and FQHCs to bill the specific CPT or HCPCS code that describes each telehealth service, rather than the catch-all code G2025.[1]
For billing and revenue cycle staff, the shift is far more than a coding footnote. It touches claim scrubbers, EHR charge masters, payer edits, denial workflows, and internal reporting all at once. Facilities that treat this as a minor administrative update risk a wave of denials starting in Q4 2026. Facilities that get ahead of it now can turn the transition into a genuine data and revenue opportunity.
What’s Actually Changing on October 1, 2026
Under the current rules, RHCs and FQHCs bill G2025 for more than 280 eligible services delivered via telehealth, and Medicare reimburses a flat rate set each year by CMS — $97.53 for calendar year 2026.[2] The rate is administratively simple, but it tells CMS nothing about what service was actually performed. A behavioral health check-in and a chronic care management visit generate identical claims data under G2025.
Starting with dates of service on or after October 1, 2026, RHCs and FQHCs must instead report the individual CPT or HCPCS code that matches the telehealth service rendered, along with the appropriate revenue code and one of two modifiers: modifier 93 for audio-only synchronous services, or modifier 95 for real-time audio-visual services.[1] CMS will update the eligible telehealth code list annually alongside the Physician Fee Schedule, so the specific codes in scope can shift from year to year.[1]
Payment methodology is also changing in a subtler way. Rather than a single negotiated flat rate, CMS says it will base the payment amount on the average of all Physician Fee Schedule telehealth services on the approved telehealth list, weighted by volume, and will not adjust that rate for geographic locality.[1] Coinsurance and deductible rules stay largely intact: RHC services carry both coinsurance and deductible, FQHC services carry coinsurance only, and preventive services remain exempt from both.[1]
Importantly, the change affects the billing mechanics, not the underlying policy that allows RHCs and FQHCs to serve as distant-site telehealth providers. Section 6209(c) of the Consolidated Appropriations Act, 2026 extended that authority through January 1, 2028, so the ability to bill Medicare for telehealth is not at risk — only the way those claims get coded.[1]
Why CMS Made the Switch
Advocacy from the rural health community played a direct role in this decision. The flat G2025 rate obscured exactly which services rural patients were receiving via telehealth, making it difficult for CMS, researchers, and rural health advocates to build a case for adequate reimbursement or to track utilization patterns with any precision.[2]
The data gap has been well documented. Federally funded research using Medicare claims from 2019 through 2021 found FQHCs used telehealth far more heavily than RHCs during the pandemic years, with FQHC telehealth use ranging from 18% to 31% of visits compared to 8% to 14% at RHCs, and behavioral health consistently the dominant use case at both settings.[3] More recent figures show rural FQHCs alone logged roughly 3 million telehealth visits in 2023, accounting for about 8% of all patient visits at those sites.[4] None of that granularity was visible in claims data, since nearly all of it flowed through one undifferentiated code.
Service-specific coding should let CMS, state Medicaid programs, and value-based care arrangements finally see what’s being delivered by telehealth at rural facilities. This is a change the National Association of Rural Health Clinics has pushed for specifically because it will let RHCs participating in Accountable Care Organizations properly capture preventive services like Annual Wellness Visits performed virtually.[2]
What Billing Teams Should Do Between Now and October 1
Audit your telehealth code inventory. Pull a full list of the CPT and HCPCS codes your clinicians actually use for telehealth encounters today, cross-referenced against the CMS telehealth services list published with the CY 2026 Physician Fee Schedule. Confirm each one is loaded correctly in your EHR and practice management system before the October cutover, not after the first batch of denials arrives.
Rebuild your charge capture logic. Systems configured to default to G2025 for any telehealth encounter need reprogramming so the staff selects the correct underlying CPT or HCPCS code at the point of service. Coders and providers documenting the encounter need clear guidance on code selection, since accuracy now directly determines reimbursement rather than a flat rate absorbing minor documentation gaps.
Standardize modifier use. Front-desk and coding staff need a simple, consistent rule for choosing between modifiers 93 and 95 based on whether the encounter was audio-only or full audiovisual. Small clinics running mixed telehealth modalities are especially exposed to mismatched modifiers slipping through unnoticed.
Update payer contracts and internal reporting templates. Finance teams tracking telehealth revenue under a single G2025 line item will need new reporting logic to aggregate the new service-specific codes back into a usable telehealth revenue category, or historical trend comparisons will break the moment the transition hits.
Train staff well before the deadline. Coding accuracy problems tend to surface in the first 60 to 90 days after any major billing transition. Running a mock billing cycle with the new codes in September, before real claims are on the line, gives billing staff a chance to catch documentation and workflow gaps early.
The Revenue Cycle Risk Hiding in a “Coding-Only” Change
CMS and industry commentary have both framed this as a change to billing mechanics rather than to underlying telehealth policy.[1] That framing is accurate, but it undersells the operational lift required. Moving from one code to 280-plus means the margin for error in code selection, documentation specificity, and modifier accuracy expands considerably. Claims submitted after October 1, 2026, using the old G2025 code are very likely to be denied outright, since MACs will be instructed to process claims according to the new requirement.
Facilities that historically treated telehealth billing as a low-touch, “set it and forget it” workflow are the ones most likely to feel this. Clinics with strong quarterly claims audits and coding education programs already built into their revenue cycle operations will absorb the change with far less disruption than those relying on legacy defaults configured years ago and never revisited.
Where GeBBS/CPa Medical Billing Fits In
Coding transitions like this one are exactly where a dedicated RCM partner earns its keep. It does this not by replacing internal billing staff, but by stress-testing code mappings, modifier logic, and payer edits ahead of a hard compliance deadline. CPa Medical Billing, part of GeBBS Healthcare Solutions, works with rural and safety-net facilities to audit telehealth billing workflows against CMS transmittals like CR 14468 well before the effective date, so clinics aren’t discovering coding gaps through denied claims.
Frequently Asked Questions
Does this change affect behavioral health telehealth billing at RHCs and FQHCs? No. The CR 14468 transition applies specifically to non-behavioral-health distant-site telehealth services billed under G2025. Behavioral health telehealth visits already use service-specific codes and are unaffected by this change.[1]
What happens if a clinic accidentally bills G2025 after October 1, 2026? CMS instructs Medicare Administrative Contractors to process claims according to the new requirement, so claims that still use G2025 for dates of service on or after October 1, 2026, are likely to be rejected or denied and will need to be corrected and resubmitted with the appropriate code.
Will the new payment methodology pay more or less than the flat G2025 rate? It depends on the service. CMS bases payment on the volume-weighted average of all PFS telehealth services on the approved list, so higher-value services may be reimbursed above the old flat rate, while lower-value services may be reimbursed below it, without geographic locality adjustment.[1]
Is the underlying ability of RHCs and FQHCs to bill for telehealth changing? No. The Consolidated Appropriations Act, 2026 extended that authority through January 1, 2028; only the billing and coding mechanics are changing.[1]
How can a clinic find the exact list of eligible telehealth codes? CMS publishes the telehealth services list annually, alongside the Calendar Year Physician Fee Schedule final rule, which is available through the CMS FQHC Information Center and the annual PFS rule documentation.[5] The list of eligible telehealth services can be found in this zip file on the CMS site.
Sources
- Centers for Medicare & Medicaid Services, “MM14468: Rural Health Clinics & Federally Qualified Health Centers: Billing Distant Site Telehealth Services,” May 27, 2026. https://www.cms.gov/files/document/mm14468-rural-health-clinics-federally-qualified-health-centers-billing-distant-site-telehealth.pdf
- National Association of Rural Health Clinics, “CMS Plans to Replace G2025 with HCPCS Billing for Medicare Telehealth in October 2026,” June 2026. https://www.narhc.org/News/33111/CMS-Plans-to-Replace-G2025-with-HCPCS-Billing-for-Medicare-Telehealth-in-October-2026
- Jonk, Y., O’Connor, H., Gale, J., & Thayer, D., “Medicare telehealth utilization by Rural Health Clinics and Federally Qualified Health Centers prior to and during the COVID-19 pandemic,” The Journal of Rural Health, January 2025. https://onlinelibrary.wiley.com/doi/10.1111/jrh.12920
- Rural Health Information Hub, “Federally Qualified Health Centers (FQHCs) and the Health Center Program Overview,” 2026. https://www.ruralhealthinfo.org/topics/federally-qualified-health-centers
- Centers for Medicare & Medicaid Services, “FQHC Information Center.” https://www.cms.gov/fqhc-information-center