NARHC Policy and Advocacy

NARHC’s policy and advocacy efforts advance the NARHC mission, enhancing the ability of RHCs to deliver cost-effective, quality health care to patients in rural, underserved communities. NARHC’s government affairs team, based in Washington, D.C. serves as the primary resource to Congress, federal agencies, and the Administration on federal Rural Health Clinic issues.

Together with the NARHC Policy Committee, we focus on both regulatory and legislative options to increase access to care, remove unnecessary regulatory burdens, protect the integrity of the RHC program, and enhance reimbursement policies that incentivize and support rural, outpatient health care services. Advocacy and comment letters sent to CMS, HHS, and Members of Congress can be found here.

Our team develops policy priorities and strategies to accomplish these priorities. Additionally, we develop materials intended to engage RHCs in federal advocacy efforts. For more details on how to make your voice heard or with any questions, please email Sarah Hohman, NARHC Director of Government Affairs, at Sarah.Hohman@narhc.org.


NARHC 2025/2026 Policy Priorities

1. Fix and Extend Medicare Telehealth

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 beginning 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.

Simply extending the previous temporary policy will perpetuate the “special payment rule” that significantly disadvantages RHCs hoping to invest in telehealth. NARHC continues to advocate for permanent coverage of all telehealth services but with a revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement as compared to their fee-for-service counterparts who receive payment parity.

NARHC also advocates for updated billing codes that would grant access to data on telehealth services utilized by RHCs. Currently, all 280+ services are billed under a single code, preventing any collection of data about which services are used most by the RHC community.

NARHC supports bills that achieve telehealth reimbursement parity for RHCs, including the CONNECT for Health Act of 2025 (S.1261 and H.R. 4206), the Save America's Rural Hospitals Act (H.R.3684), the Telehealth Modernization Act (H.R.5081), and the Helping Ensure Access to Local TeleHealth (HEALTH) Act (H.R.5496). For details on billing for telehealth and related services, as well as to help us advocate on this issue, please visit NARHC’s Telehealth Policy page.

2. Protect Medicaid

RHCs rely on enhanced Medicaid reimbursements to provide care for their community. They do not receive any funding to provide care for uninsured patients and are not eligible for any 330 grants.

On July 4th, President Trump signed a large reconciliation bill into law, H.R.1. This bill includes major reforms to Medicaid policy, which will disproportionately harm rural communities. 26.5% of RHC patients are insured by Medicaid, and cuts to the program could take away their access to healthcare entirely. NARHC remains engaged in Medicaid advocacy through participation with the Partnership for Medicaid and the Modern Medicaid Alliance. For more information, please visit NARHC News.

3. Strengthen Medicare Advantage

RHC patients choose Medicare Advantage for a variety of reasons, and maintaining access to that choice is important. However, Medicare Advantage plans continue to pay RHCs less and significantly less than RHCs would receive from traditional Medicare, threatening access to care for these beneficiaries in their communities.

Medicare Advantage enrollment has surpassed traditional Medicare enrollment amongst eligible beneficiaries. While RHCs receive enhanced traditional Medicare payments in comparison with their fee-for-service counterparts, there is no statutory requirement around RHC Medicare Advantage reimbursement and RHCs will be paid the contracted amount they have negotiated with each individual MA plan. Comparatively, FQHCs are eligible for “wrap payments”, through which Medicare will pay the difference if Medicare Advantage plans reimburse less than the Medicare PPS rate. NARHC supports RHC “wrap payments” similar to the FQHC model, or a reimbursement floor for MA plans similar to traditional Medicare reimbursements.

NARHC supports the Prompt and Fair Pay Act (H.R.4559), which requires MA plans to provide reimbursement that is comparable to Traditional Medicare.

4.  Reduce Regulatory Burdens

RHCs are subject to certain outdated and erroneous regulations – some of which have not been updated since the RHC program was created in 1977. In September of 2025, 3 RHC regulatory burden bills were introduced in the House by Representative Tracey Mann (KS-01) and Representative Jill Tokuda (HI-02). The legislation aims to fix outdated language related to RHC location requirements, remove a statutory barrier limiting provision of behavioral health services, and align Nurse Practitioner and Physician Assistant/Associate regulations with state law.

  • Modernizing Rural Physician Assistant (PA) and Nurse Practitioner (NP) Utilization Act (H.R.5199)
    • Summary: Modernizes RHC physician supervision requirements by aligning them to state scope of practice laws governing PA and NP practice. All states have Practice Acts governing PA and NP scope of practice, making federal standards unnecessary. This would allow PAs and NPs to practice to the top of their license without unnecessary federal supervision requirements that apply only because the PA or NP is practicing in an RHC. 27 states have granted NPs full practice authority, yet NPs practicing in RHCs in those states still have separate, federal supervision requirements.
  • RHC Location Modernization Act (H.R.5198)
    • Summary: Maintains status quo policy as to where an RHC can be located, ensures that RHCs can continue to be located in an area that is less than 50,000. Requires a statutory update due to the Census Bureau no longer defining terminology used in current eligibility definition.
  • Rural Behavioral Health Improvement Act (H.R.5217)
    • Summary: Removes statutory barrier that limits the amount of behavioral health services an RHC can provide, allowing clinics to fully treat their patients and better integrate services.

5. Maintain Rural Appropriations

RHCs and their affiliated hospitals and systems are supported by various rural health appropriations, including technical assistance by State Offices of Rural Health (SORHs). Cuts to these rural health programs as proposed in the FY26 President’s budget request threaten the rural safety-net.

Other Policy Priorities

Good Faith Estimate

Good Faith Estimate (GFE) requirements, enacted through the No Surprises Act, requires that RHCs, and all providers, issue a GFE to all uninsured or self-pay patients upon request, and when they schedule an appointment 3+ days in advance. Please visit our Good Faith Estimate Resources for more information and details regarding compliance.

While NARHC is supportive of efforts to increase price transparency for patients, we have requested that CMS engage further with providers and other stakeholders on price transparency policies that achieve these goals without adding so much complexity and cost to the scheduling process. In response to stakeholder feedback, CMS did delay Phase II of the policy, pending future rulemaking. NARHC will remain engaged on this issue.

Value-Based/Quality Reporting for RHCs

NARHC supports the establishment of a quality reporting program designed for RHCs. It is imperative that such a program be made available to all RHCs. RHC participation in quality programs could be greatly increased and improved if a quality payment program specifically for RHCs was created. Because the RHC payment structure is essential to the RHC program but also quite different from FFS payment, the best way to bring value into the RHC model is to design a program solely for RHCs. NARHC remains engaged with Congress and CMMI on opportunities to better involve RHCs in value-based programs.

Other Rural Health Legislation

So far in the 119th Congress, several rural health related bills have been introduced with bipartisan support. NARHC is supportive of these efforts to increase access to quality health care to patients in rural America and will continue to monitor this legislation. This may not be an exhaustive list of all bills supported by NARHC. With any questions about these bills or others, please contact Sarah.Hohman@narhc.org.

  • Strengthening Pathways to Health Professions Act (H.R.593)
    • Provides tax relief for certain health professional scholarships and loan payments intended to increase availability of health care services in underserved or health professional shortage areas.
  • Rural Health Care Access Act of 2025 (H.R.771)
    • Removes the requirement that prevents hospitals from pursuing a Critical Access Hospital (CAH) designation if it falls within 35-miles of another CAH.
  • Improving Care and Access to Nurses Act (H.R.1317)
    • Under Medicare and Medicaid, this act removes various barriers to practice for several RHC professionals, including NPs, certified nurse-midwives, and advanced practice registered nurses.
  • Reducing Medically Unnecessary Delays in Care Act of 2025 (H.R.2433)
    • Requires Medicare, Medicare Advantage, and Part D prior authorization decisions to be made by physicians in the same specialty as the requesting provider
  • Medicare Audiology Access Improvement Act of 2025 (H.R.2757)
    • This bill adds audiologists as Medicare-covered providers in RHCs.
  • Improving Seniors’ Timely Access to Care Act of 2025 (S.1816)
    • Streamlines the prior authorization process to reduce administrative burden on providers and improve access to care for seniors enrolled in Medicare Advantage (MA) plans.
  • Registered Nurses (RNs) for Rural Health Act (H.R.3878)
    • Allows RNs at RHCs to conduct Annual Wellness Visits (AWVs) and receive reimbursement from Medicare.
  • Critical Access for Veterans Care Act (S.1868)
    • Removes prior authorization and referral requirements for covered veterans seeking care under the Veterans Community Care Program at provider-based RHCs affiliated with CAHs.
  • CONNECT for Health Act of 2025 (S.1261 and H.R. 4206)
    • Includes the language necessary to achieve reimbursement parity for RHC telehealth visits.
  • Save America's Rural Hospitals Act (H.R.3684)
    • Includes the language necessary to achieve reimbursement parity for RHC telehealth visits.
  • Prompt and Fair Pay Act (H.R.4559)
    • Requires Medicare Advantage plans to provide reimbursement that is comparable to Traditional Medicare.
  • Telehealth Modernization Act (H.R.5081)
    • Extend Medicare telehealth flexibilities through fiscal year 2027 and includes the language necessary to achieve reimbursement parity for RHC telehealth visits.
  • Helping Ensure Access to Local TeleHealth (HEALTH) Act (H.R.5496)
    • Allows RHCs to permanently receive Medicare reimbursement for telehealth services.
  • Premium Tax Credit Extension Act
    • Prevents millions of Americans from losing health insurance coverage by extending Affordable Care Act (ACA) subsidies set to expire at the end of 2025.
  • Physical Therapist Workforce and Patient Access Act of 2025 (H.R.5621)
    • Expands Medicare coverage for Physical Therapy services at RHCs.