CMS Will Require Rural Health Clinics and FQHCs to Bill Individual Telehealth Codes Instead of G2025 Starting October 1, 2026

Rural health clinics and federally qualified health centers are the safety net practices that deliver primary care, and a growing share of telehealth, to many rural and underserved communities. Starting October 1, 2026, Medicare is changing the mechanics of how those clinics bill for the telehealth visits they provide as the distant site. The change is administrative: it affects the codes on the claim, not whether Medicare covers the service. This piece explains what CMS is requiring, when it takes effect, and what stays the same, based on the agency's own billing instruction.

What CMS is changing

For dates of service on or after October 1, 2026, RHCs and FQHCs must bill the individual CPT or HCPCS code that describes the distant site telehealth service they furnish, instead of the single HCPCS code G2025 they use today. CMS publishes the list of billable telehealth codes each year alongside the Physician Fee Schedule (PFS) rule. The agency issued the requirement as Change Request 14468 (Transmittal R13776OTN), released May 27, 2026, with an effective date of October 1, 2026 and an implementation date of October 5, 2026.

The new coding and modifier requirements

Under the instruction, claims for distant site telehealth furnished by RHCs and FQHCs must carry the appropriate revenue code plus one of two modifiers:

• Modifier 93: a synchronous telemedicine service rendered via telephone or other real time interactive audio only telecommunications system.
• Modifier 95: a synchronous telemedicine service rendered via a real time interactive audio and video telecommunications system.

In practical terms, that replaces one bundled code (G2025) with the specific service code plus a modifier that signals whether the visit was audio only or audio and video.

What stays the same: payment and coverage

CMS describes this as a change in how services are coded and reported, not a change to the payment basis or to what is covered. For non-behavioral health distant site telehealth furnished by RHCs and FQHCs, CMS says it:

• Updates the payment rate annually.
• Bases the rate on the average amount for all PFS telehealth list services, weighted by volume for those services reported under the PFS.
• Does not adjust the rate for geographic locality.
• Applies patient coinsurance and deductible to RHC services, and coinsurance to FQHC services, based on the lesser of the payment rate or submitted charges.
• Waives coinsurance and deductibles for preventive services.

CMS also notes that it does not use the costs of distant site telehealth services when setting the FQHC prospective payment system rate or the RHC all inclusive rate, citing section 1834(m)(8)(B)(ii) of the Social Security Act.

The authority behind it

The ability of RHCs and FQHCs to act as distant site telehealth providers is a temporary, statutory flexibility rather than a permanent feature of Medicare. Section 6209(c) of the Consolidated Appropriations Act, 2026 extended that flexibility until January 1, 2028. Through calendar year 2027, section 1834(m)(8)(B)(i) of the Social Security Act directs CMS to pay for these distant site services at rates similar to the national average for comparable telehealth services under the PFS. CMS notes that RHC and FQHC practitioners can furnish approved distant site telehealth services that are within their scope of practice, from any location, while they are working for the clinic.

Why it matters

For patients, nothing about eligibility changes: the visits Medicare covered before the switch remain covered after it. For the clinics, the change is operational. Billing staff and clearinghouses need to map each distant site telehealth service to its specific CPT or HCPCS code and append modifier 93 or 95, rather than reporting everything under G2025. Because the implementation date is October 5, 2026 for a change effective October 1, 2026, clinics have a narrow window to update billing systems and train staff. Getting the codes and modifiers right is what keeps clean claims moving and reduces the risk of denials during the transition.

What to do next

This is general information about a Medicare billing change, not billing, legal, or medical advice. CMS issued Change Request 14468 to Medicare Administrative Contractors (MACs) as the official instruction and directs providers to their MAC for specifics. RHCs and FQHCs with questions about how to code a particular service should consult the annual PFS telehealth list, their MAC's guidance, and a qualified billing or compliance adviser.