Telehealth Policy & Resources

Medicare Telehealth Policy

Medicare telehealth policy shifted dramatically for the entire healthcare industry in response to COVID-19. Telehealth policy unique to RHCs and more broadly within the fee-for-service community evolved rapidly in a matter of months, expanding avenues for patients to see providers, but also creating unique hurdles that NARHC is working to fix.

As of October 1st, 2025, Medicare telehealth flexibilities granted during the COVID-19 pandemic have officially expired for RHCs, meaning they no longer can receive reimbursement for providing medical Medicare telehealth services to patients located in their homes. Please read below for more information.

As of October 1st, Congress was unable to reach an agreement to continue funding the government, leading to an active government shutdown. While not a component of federal appropriations, Congress previously aligned the expiration of Medicare telehealth flexibilities with the end of the fiscal year. Thus, Medicare telehealth flexibilities officially expired for RHCs, meaning they no longer receive reimbursement for providing medical Medicare telehealth services to patients located in their homes. With the expiration of originating and geographic flexibilities, patients will only be eligible to receive telehealth services if they are located in a qualifying medical facility (practitioner’s office, hospital, CAH, RHC, FQHC, SNF, or dialysis facility) that is in a rural area or a health professional shortage area. We anticipate that this will be a temporary lapse in coverage through the end of the government shutdown period. Please check NARHC’s Forum for the most timely updates on this matter.

Prior to the government shutdown, RHCs were granted Medicare telehealth flexibilities shortly after the onset of the pandemic through a "special payment rule." The special payment rule reimbursed RHCs and FQHCs through a composite system based on the weighted average of physician fee schedule codes billable via telehealth. Operationally, this meant that RHCs and FQHCs used one single code, G2025, which paid one single rate, $94.45, for any and all of the over 280 services that are billable via telehealth. While this rule allowed RHCs to serve as distant site providers for telehealth, it ultimately imposed significant barriers on safety-net providers seeking to offer telehealth services to their patients:

1. The payment rate is lower than an RHC’s all-inclusive rate, which disincentivizes investment in telehealth technologies;
2. Limited data can be gathered from G2025 as it obscures and distorts claims data; and
3. It requires RHCs to separate calculate costs associated with telehealth on their cost report which generates significant administrative burden for the RHCs. 

Note: while CMS used their authority to extend G2025 policy through 12/31/2025, the latest from Congress is that originating site flexibilities (where the patient can be located) have expired as of October 1, 2025. NARHC will continue advocating for further extensions of these flexibilities, as well as a fix to the payment policy.

Further complicating the current policy landscape is the fact that in the 2022 Medicare Physician Fee Schedule, CMS changed the definition of an RHC/FQHC mental health encounter to allow mental health services provided via telehealth to be reimbursed through normal payment mechanisms. In other words, for mental health telehealth services, RHCs/FQHCs already have payment parity.

Prior to the government shutdown, this so-called "temporary" special payment rule remained in effect for over 5 years. As a result, RHCs were operating without adequate telehealth reimbursement for an extended period, facing ongoing financial strain. Each short-term punt merely delayed a long-term solution and extended the flawed special payment rule creating persistent uncertainty about the future of RHC telehealth services.

The timeline below illustrates the turbulent journey of telehealth flexibilities since 2020.

Telehealth Resources

Below are some resources to help RHCs navigate the shifting telehealth landscape. With any questions, please email Sarah Hohman at Sarah.Hohman@narhc.org.

• Beginning January 2022 and not connected to the PHE, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.
• In December 2020 CMS announced significant telehealth coinsurance changes.
• Table 1 below breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.
• Table 2 below highlights the various Medicare telehealth waivers and their current status as of October 2025.

NARHC Telehealth Advocacy

NARHC is advocating for:

• Reinstatement of COVID-19 Medicare telehealth flexibilities
• Permanent coverage of medical telehealth encounters
• A revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement when seeing patients via telehealth

Bills introduced in the 119th Congress that achieve telehealth reimbursement parity for RHCs include:

• CONNECT for Health Act of 2025 (S.1261 and H.R. 4206)
• Save America's Rural Hospitals Act (H.R. 3684)
• Telehealth Modernization Act (H.R.5081)
• Helping Ensure Access to Local TeleHealth (HEALTH) Act (H.R.5496)

NARHC is also open to appropriate guardrails to ensure that the integrity of the telehealth benefit is protected in our safety net provider settings.

Table 1

Name of Telehealth Service	Brief Description	How to Bill	Reimbursement Rate	Relevant   Dates
Virtual Check-In or Virtual Care Communications	Remote evaluation - G2010 Brief communication with patient (5 min) - G2012	G0071 Bill on UB-04 No modifier necessary Rev Code 052X	2024: $13.32	Permanent coverage
Digital e-Visits	Online evaluation and management 99421-99423	G0071 Bill on UB-04 No modifier Rev Code 052X	2022: $23.88 2023: $23.72	Only billable during the COVID-19 PHE (ended May 11, 2023).
Telehealth Visits	One to one substitutes or additions to in-person services/visits List of allowable services maintained by CMS (including services allowed via audio-only)	G2025 Bill on UB-04 Audio-only modifier: FQ Rev Code 052X Costs and encounters carved out of cost report	2025: $94.45	Billing details currently set to expire December 31, 2025
Mental Health Telehealth Visits	One to one substitutes or additions to in-person mental health services/visits CPT codes that can be billed with 0900 revenue code	Rev Code 0900 Use proper mental health CPT code Modifier CG always Modifier 95 if audio-video Modifier FQ or 93 if audio-only Count costs and encounters on cost report	All-Inclusive Rates	Permanent coverage beginning January 1, 2022 *Occasional in-person visit requirement begin on January 1, 2026
Chronic Care Management/ Principal Care Management/Remote Physiologic Monitoring/Remote Therapeutic Monitoring Psychiatric Care Management	G0323, 99487, 99490, 99491, 99424, 99426, G3002, G3003, 99453, 99454, 99457, 99458, 99091, 98975, 98976. 98977, 98980, 98981, G0019, G0022, G0023, and G0024 = G0511 99492, 99493 = G0512	G0511- Care Management G0512- Psychiatric Care Management	G0511 2024: $72.90 G0512 2024: $146.47 Individual payment rates for care management codes in  2025.	In 2024, CMS greatly expanded care  management policy for RHCs. RHCs can bill for Remote Physiological Monitoring and  several others (as G0511) and are  eligible to bill for  multiple G0511 codes per patient per month. Details here. Beginning on September 2025, RHCs will no longer use G20511 to bill for care management services. For more details visit NARHC News.
Transitional Care Management	Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions.	99495, 99496 on an RHC claim, either alone or with other payable services	If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid.	Covered since January 1, 2013

 

Table 2

Medicare Policy Area	Current Policy and Duration of Flexibility/Waiver
Originating Site/Geographic Requirements	As of October 1, 2025 patients can no longer receive telehealth services in their home. Patients are only eligible to receive telehealth services if they are located in a qualifying medical facility (practitioner’s office, hospital, CAH, RHC, FQHC, SNF, or dialysis facility) that is in a rural area or a health professional shortage area.
Distant Site Requirements	RHC providers can serve as telehealth distant site providers through December 31, 2025.
Billing/Cost Reporting Requirements	Please see table above. G2025 policy for medical telehealth visits remains in effect  through December 31, 2025.
Modality	The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023

 

Other Telehealth Information of Interest

• The Drug Enforcement Agency extended the flexibilities for prescribing controlled substances via telehealth through December 31, 2025.
• HHS provided resources on educating patients on privacy and security risks when using telehealth.

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