Telehealth Policy |

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.

After a 43-day government shutdown period (October 1, 2025 - November 12, 2025), Medicare telehealth flexibilities granted during the COVID-19 pandemic have been reinstated through January 30, 2026. Any claims that were put on hold will be paid retroactively from October 1st onward.

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 means that RHCs and FQHCs use one single code, G2025, which pays one single rate, $94.45, for any and all of the over 280 services that are billable via telehealth. While this rule allows RHCs to serve as distant site providers for telehealth, it ultimately imposes significant barriers on safety-net providers seeking to offer telehealth services to their patients:

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

Note: CMS used their authority to extend G2025 policy and originating site flexibilities (where the patient can be located) through 12/31/2026. However, the latest from Congress is that originating site flexibilities will expire as of January 30, 2026. 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.

This so-called "temporary" special payment rule remains in effect for over five years. As a result, RHCs have been operating without adequate telehealth reimbursement for an extended period, facing ongoing financial strain. Each short-term punt merely delays a long-term solution and extends 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 December 2025.

NARHC Telehealth Advocacy

NARHC is advocating for:

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 January 30, 2026
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 would begin on January 31, 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	Patients can receive telehealth services in their home through January 30, 2026. For any claims that were put on hold during the government shutdown period (October 1, 2025 - November 12, 2025), they will be paid retroactively from October 1st onward.
Distant Site Requirements	RHC providers can serve as telehealth distant site providers through January 30, 2026.
Billing/Cost Reporting Requirements	Please see table above. G2025 policy for medical telehealth visits remains in effect through January 30, 2026.
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. This is expected to be extended further.
HHS provided resources on educating patients on privacy and security risks when using telehealth.

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