CMS Releases Guidance on Telehealth Billing for RHCs


UPDATED 4/21/2020

We have confirmed that for telehealth distant site visits, all RHC claims need both the CG and 95 modifier.

RHCs can perform any telehealth service on the CMS list of approved telehealth services as long the healthcare practitioner is working within the scope of their practice.

The list of approved telehealth services includes 99201 and 99211 (services that would normally not rise to the level of an RHC encounter) meaning that these level 1 E/M codes if furnished by an RN within their scope of practice would be billable as a distant site service.

You would use both modifier CG and modifier 95 on all distant site RHC telehealth visits.

When the G-code, G2025, goes into effect on July 1, then no modifiers will be necessary.


To: RHC Community and Friends
From: Bill Finerfrock
           Executive Director
           National Association of Rural Health Clinics
Re: RHC billing for telehealth

CMS has released the long-awaited guidance on telehealth billing for RHCs. Here is a link to the MLN document:

NARHC will be conducting a FREE Webinar on Monday, April 20 to go over this policy announcement and respond to your questions. More information on how to register for this FREE webinar will be distributed later today (4/17).

Here are key points on what CMS is adopting:

  1. Medicare claims for RHC telehealth visits occurring since January 27th will be paid by Medicare. If you have been holding these telehealth claims, you can submit them and they will be paid.
  2. CMS has established a uniform RHC telehealth payment rate of $92.00 per visit. This rate will apply to telehealth visits performed by independent or provider-based RHCs.
  3. All RHCs will bill for telehealth visits the same as you would bill for an in-person visit and use the 95 modifier on the claim line to signify that the visit was via telehealth rather than in-person.
  4. In order to expedite adoption of this policy, CMS will INITIALLY pay the RHC’s all-inclusive rate for this visit.
  5. Beginning in July, CMS will automatically adjust ALL RHC telehealth claims to reflect the $92 telehealth per visit rate that were submitted between now and July 1, 2020. RHCs with a per-visit rate below $92.00 will receive an additional payment reflecting the difference between their AIR and $92.00. For RHCs with an AIR above $92.00, CMS will RECOUP the difference.
  6. After July 1, 2020, through end of the COVID-19 Emergency RHCs will use G Code G2025 to identify distant site telehealth visit services. This code will reimburse $92.00 and no recoupment will be necessary.
  7. Costs associated with the delivery of a telehealth visit will be reported on the RHC cost report however, they will be included in line 79 of the cost report, non-reimbursable RHC costs. This is so that RHC telehealth costs and telehealth visits will not be counted when determining the RHCs cost-per visit.

Please review the information from CMS and we look forward to talking with you on Monday as we take a closer examination of the CMS RHC telehealth policy.