Starting October 1, 2026, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) can no longer bill G2025 for non behavioral distant site telehealth. CMS has changed telehealth billing so that these clinics report the individual Current Procedural Terminology (CPT) or Healthcare Common Procedure Coding System (HCPCS) code that describes the service, plus a revenue code and a telehealth modifier. The change applies to dates of service on or after October 1, and CMS set October 5, 2026 as the contractor implementation date.
This article summarizes what changed, how to choose between modifier 93 and modifier 95, what stays the same for payment and cost sharing, and what each team in a health center may want to review. It also explains what the change does not touch, including Remote Patient Monitoring (RPM) billing, and where DrKumo’s technology may fit.
About this article This article summarizes CMS Change Request 14468 and the MLN Matters summary, and links to both. It reports what CMS instructs and is not billing or coding advice. Health centers should confirm claim level details with their Medicare Administrative Contractor (MAC). |
At a glance
Stop Reporting G2025 for non behavioral distant site telehealth. | Bill The individual CPT or HCPCS code that describes the service furnished. | Add The appropriate revenue code and modifier 93 or 95. |
Behavioral health lines reported with revenue code 0900 are excluded from the new distant site payment table. Source: CMS Change Request 14468.
Key Dates for the G2025 Change
| May 27, 2026 | CMS issues Change Request 14468 with the new billing instructions. |
| October 1, 2026 | The new instruction applies to dates of service on or after this date. |
| October 5, 2026 | The contractor implementation date CMS set for Medicare Administrative Contractors (MACs). |
| January 1, 2028 | The distant site flexibility for RHCs and FQHCs runs until this date under the Consolidated Appropriations Act, 2026. |
What Replaces G2025 on October 1, 2026
Since the COVID 19 public health emergency, RHCs and FQHCs have reported most non behavioral distant site telehealth services with one code, G2025. CMS says there is a “program need to identify the specific services furnished.” One example is showing an Accountable Care Organization (ACO) which services a health center delivered.
From October 1, each distant site telehealth line needs the four parts below. CMS publishes the eligible codes each year on its Medicare telehealth services list, which currently covers calendar year 2026. The list is updated with each Physician Fee Schedule rule, so it is worth rechecking when the CY 2027 final rule is released.
| Revenue code | CPT or HCPCS code | Modifier | Units |
|---|---|---|---|
| The appropriate revenue code. | The code for the service furnished, from the CMS telehealth list. Not G2025. | 93 for audio only or 95 for audio and video. | Multiple units can be reported. CMS considers units when applying the payment rate. |
Which Telehealth Modifier to Use: 93 or 95
Every distant site telehealth line needs one of two modifiers. The choice depends on how the visit was delivered.
93 Audio only A synchronous visit delivered by telephone or another real time audio only system. | 95 Audio and video A synchronous visit delivered through a real time audio and video system. |
The visit note should show how the visit was delivered, so the modifier on the claim matches what happened. Billing practitioners should confirm modifier and revenue code details with their MAC.
What Stays the Same for RHC and FQHC Telehealth
CMS changed how the service is reported, not who can furnish it or how patients share cost. The MLN Matters summary lists what continues, including that practitioners can furnish telehealth “from any location during the time they’re working for the RHC or FQHC.”
| Topic | What CMS says |
|---|---|
| Who can furnish | RHC and FQHC practitioners can furnish distant site telehealth within their scope of practice, for services approved as distant site telehealth under the Physician Fee Schedule (PFS). |
| Payment rate | Updated annually, based on the average amount for all PFS telehealth services on the telehealth list, weighted by volume, and not adjusted for geographic locality. Through CY 2027, the law requires payment similar to national average rates for comparable services. |
| Cost sharing | RHC patients owe a deductible and coinsurance. FQHC patients owe coinsurance. Coinsurance is based on the lesser of the payment rate or submitted charges. |
| Preventive services | Coinsurance and deductibles are waived for preventive services. |
| Behavioral health | Lines reported with revenue code 0900 are excluded from the new distant site payment table. Behavioral health services furnished by telecommunication technology are face to face encounters paid under the RHC all inclusive rate and the FQHC prospective payment system. |
Claim Edits and Details Billing Teams Should Know
Key insight CMS told its claims system to flag bill types 71X and 77X when modifier 93 or 95 is billed with a code that is not a distant site telehealth service code. Contractors then return the claim to the provider. The edit is bypassed for bill types 710 and 770. |
Because the October 5 implementation date has passed, reviewing early October remittances may help catch code and modifier problems.
What Each Team May Need to Review
The change touches three groups in a health center. These are items to review with your billing team and MAC, and they do not replace CMS’s instructions.
Billing team
| Clinical staff
| Systems and vendors
|
What the Change Does Not Touch: RPM at Health Centers
Change Request 14468 addresses distant site telehealth services and does not address RPM. RPM follows a separate pathway. CMS instructions effective January 1, 2025 direct RHCs and FQHCs to bill the four RPM codes below individually as care coordination services, with a transition period that ran until at least July 1, 2025. The CMS instructions list them.
| CPT code | RPM component |
|---|---|
| 99453 | Patient education and device setup. |
| 99454 | Device supply. |
| 99457 | Treatment management. |
| 99458 | Treatment management, additional time. |
CMS updates RPM coding periodically, so confirm the current codes and how they apply to health centers with your MAC. Telehealth visits and RPM are separate services, and they can serve the same patients.
Where RPM May Fit Alongside Telehealth
Telehealth visits support real time care, and RPM supplies readings between visits. These questions can help a health center decide where RPM may fit.
Your patients
| Their connectivity
| Your team
|
Fit depends on a center’s patients, connectivity, and staffing. The next section explains how DrKumo’s technology works, and the RPM guide covers program setup.
How DrKumo Supports RHC and FQHC Programs
DrKumo provides secure, HIPAA compliant digital health technology that supports RPM programs operated by healthcare providers. For FQHCs and RHCs, rural health organizations, and community providers, the platform moves physiologic data from patients’ homes to care teams over cellular connectivity, with no WiFi or smartphone app required, using medical devices as defined by the FDA. Readings can reach the clinic between telehealth and in person visits.
DrKumo also supports provider led Disease Management Protocols and applies healthcare cybersecurity practices to patient data. This article covers telehealth billing under CMS Change Request 14468, which is separate from RPM. Billing and coding decisions remain with the billing practitioner and the health center. Practices can review DrKumo’s comprehensive guide to RPM. DrKumo is a technology provider and is not a clinical entity. Providers retain full clinical responsibility for patient care decisions, and RPM supports monitoring between visits rather than replacing emergency care.
Key Takeaways
G2025 is retired for RHC and FQHC non behavioral distant site telehealth. For dates of service on or after October 1, 2026, clinics report the individual CPT or HCPCS code for the service, the appropriate revenue code, and modifier 93 or 95.
Who can furnish telehealth, how long the flexibility lasts, and how patients share cost have not changed. The flexibility runs until January 1, 2028. Behavioral health lines reported with revenue code 0900 are excluded from the new distant site payment table.
Codes, modifiers, and returned claims are worth checking now. The change does not address RPM. Health centers that use or are considering RPM can use the questions above to see where it may fit.
Data driven care starts here Considering RPM alongside telehealth at your health center? To learn how DrKumo can help your organization deliver secure, HIPAA compliant RPM, contact us today. Our team is ready to support your journey toward better patient care.
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Frequently Asked Questions About the G2025 Change
Questions RHC and FQHC billing teams are asking about telehealth claims after October 1, 2026.
Is G2025 still valid for RHC and FQHC telehealth?
CMS’s instruction applies to dates of service on or after October 1, 2026. From that date, RHCs and FQHCs must bill the individual CPT or HCPCS code for the service instead of G2025. For earlier dates of service, G2025 was the reporting code for non behavioral distant site telehealth.
What do RHCs and FQHCs bill for telehealth after October 1, 2026?
The individual CPT or HCPCS code that describes the distant site telehealth service, which must be on the CMS Medicare telehealth services list, along with the appropriate revenue code and modifier 93 or 95.
Which modifier should RHCs and FQHCs use, 93 or 95?
Modifier 93 is for a synchronous visit by telephone or another real time audio only system. Modifier 95 is for a synchronous visit through a real time audio and video system. Choose the one that matches how the visit was delivered.
Does the G2025 change apply to behavioral health telehealth?
The new distant site payment table does not apply to service lines reported with behavioral health revenue code 0900. Behavioral health services furnished by telecommunication technology are face to face encounters paid under the RHC all inclusive rate and the FQHC prospective payment system.
Does the G2025 change affect RPM billing at RHCs and FQHCs?
CMS Change Request 14468 addresses distant site telehealth services and does not address RPM. Under CMS instructions effective January 1, 2025, RHCs and FQHCs bill RPM codes 99453, 99454, 99457, and 99458 individually as care coordination services, after a transition period that ran until at least July 1, 2025. Confirm details with your MAC.
References
Centers for Medicare & Medicaid Services. (2026). Billing of Distant Site Telehealth Services in Rural Health Clinics and Federally Qualified Health Centers (Change Request 14468, Transmittal 13776). CMS.gov.
Centers for Medicare & Medicaid Services. (2026). Rural Health Clinics & Federally Qualified Health Centers: Billing Distant Site Telehealth Services (MLN Matters MM14468). CMS.gov.
Centers for Medicare & Medicaid Services. List of Telehealth Services. CMS.gov.
Centers for Medicare & Medicaid Services. (2024). Updates to Billing for Care Coordination Services for Rural Health Clinics and Federally Qualified Health Centers (Transmittal 12958). HHS.gov.
Disclaimer: This article is intended for informational purposes only and does not constitute medical, legal, billing, coding, or financial advice. It summarizes CMS Change Request 14468 as released on May 27, 2026, and the MLN Matters document history lists no revisions. Medicare coverage, coding, and payment requirements are subject to change. Always consult official CMS sources and your Medicare Administrative Contractor for current requirements. DrKumo is a technology provider and is not a clinical entity. It does not provide clinical services or replace a licensed provider’s clinical judgment. Always consult with a licensed healthcare provider for guidance on diagnosis, treatment, or medical decisions. References to CMS and HHS do not constitute or imply an endorsement by those agencies or the U.S. Government. |
