For years, HCPCS code G2025 has served as a one-size-fits-all code for non-behavioral health, distant-site telehealth services furnished by Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs). That all changes for RHCs and FQHCs billing Medicare starting October 1, 2026[1]. G2025 may continue to be reported for services furnished through September 30, 2026—even when the claim is submitted or adjusted after that date.
What to Look For
For dates of service on or after October 1, 2026, RHCs and FQHCs must report the individual CPT or HCPCS code that describes the telehealth service provided. Moving away from one generic code should give payers significantly better visibility into RHC and FQHC telehealth utilization.
Claims must also include the appropriate revenue code and modifier (93 for synchronous audio-only services or 95 for synchronous audio and video services). RHCs and FQHCs remain authorized to serve as distant-site telehealth providers through the end of 2027, so telehealth access is not disappearing—the claim will simply have to identify what service was provided – and ensure that code is included on the applicable CMS telehealth services list. CMS instructs its claims systems to return applicable claims to the provide for correction when modifier 93 or 95 is reported with a code that is not an approved distant-site telehealth service. The eligible code list is updated annually[2], making ongoing policy maintenance especially important.
CMS is also directing contractors to allow multiple units on qualifying RHC and FQHC telehealth service lines and to consider those units when applying the payment rate. This makes excessive units, overlapping time-based services, repeated identical services, and impossible day scenarios important areas for analysis. Same-member, same-day telehealth and in-person services should also be reviewed for potential duplication, with attention to whether the services were distinct and supported by documentation. Unusual patterns and clinically unlikely scenarios should prompt further review.
Beginning in the fourth quarter of 2026, payers will be able to compare service-code distributions, units, modality, preventive-service utilization, and member-level patterns across peer RHCs and FQHCs.
HCFS Has You Covered
The transition from one generic code to individual service-level billing will create a richer—but considerably more complex—telehealth data set. The HCFSPlatform™ can combine date-sensitive coding logic, targeted analytics, AI-powered anomaly detection, and peer comparisons to help payers identify potentially unsupported services, unusual units, and emerging provider patterns before and after payment. This layered approach helps focus investigative resources on claims and providers that warrant closer review.
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References:
[1] https://www.cms.gov/files/document/mm14468-rural-health-clinics-federally-qualified-health-centers-billing-distant-site-telehealth.pdf
[2] https://www.cms.gov/medicare/coverage/telehealth/list-services
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