CMS has released updated telehealth billing guidance for Federally Qualified Health Centers (FQHCs) & Rural Health Clinics (RHCs).
Source: CMS Telehealth FAQ- Updated November 26, 2025
Key Takeaways
- CMS has extended Medicare telehealth billing flexibility for FQHCs and RHCs for non-behavioral health services through December 31, 2026.
- Behavioral health telehealth services remain permanently payable under existing rules.
- All telehealth claims must flow through UB-04 FQHC PPS.
Duration of Telehealth Flexibilities
Non-Behavioral (Medical) Telehealth Services
- Billable through: December 31, 2026
- Billing Code: HCPCS G2025
- Patient Location: May be anywhere (home, rural, urban).
- Service Type: Audio-video or audio-only.
- Reimbursement: Paid based on PFS (Physician Fee Schedule) national average rates.
Important: Payment for non-behavioral telehealth services under G2025 is scheduled to end January 1, 2027, unless Congress or CMS extends the policy again. *
Behavioral Health & Substance Use Disorder (SUD) Telehealth Services
These services remain permanently authorized under Medicare:
- No geographic restrictions.
- No originating-site restrictions.
- Patient may be located in the home.
- Audio-only allowed when video is unavailable or declined.
- Paid under the standard FQHC/RHC PPS/AIR rate.
- Includes:
- Mental health evaluations.
- Psychotherapy.
- Substance use disorder treatment.
Required Coding and Claim Type for FQHC Telehealth
- Non-Behavioral Telehealth:
- G2025
- UB-04
- Behavioral Health Telehealth:
- Qualifying CPT/ FQHC PPS qualifying G-code (G0469, G0470)
- UB-04
What This Means for FQHC Operations
You May Continue to:
- Provide medical telehealth visits under Medicare using G2025 through 12/31/2026.
- Provide behavioral health telehealth services without geographic limits.
- Use audio-only for behavioral health when clinically appropriate.
- Serve patients in their homes.