Medicare Telehealth Billing Is Changing Again: What RHCs and FQHCs Need to Update

Medicare Telehealth Billing Changes Take Effect October 1, 2026

Beginning October 1, 2026, Medicare changed how Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) bill for distant-site telehealth services.

For several years, these providers have commonly used HCPCS code G2025 when billing Medicare for qualifying telehealth encounters.

That has now changed.

Under the new billing requirements, RHCs and FQHCs must report the specific CPT or HCPCS code that describes the telehealth service performed, along with the appropriate telehealth modifier.

What Was G2025?

G2025 was created as a telehealth billing code for RHCs and FQHCs furnishing distant-site telehealth services.

Instead of billing Medicare using the individual CPT or HCPCS code associated with the service, the provider could report G2025 for the qualifying telehealth encounter.

In practical terms, the claim identified the service as a telehealth encounter, but did not always show the specific underlying service that had been performed.

What Changed on October 1?

For dates of service beginning October 1, 2026, RHCs and FQHCs are required to report the actual CPT or HCPCS code for the telehealth service provided rather than billing G2025 for those services.

The claim must also include the appropriate telehealth modifier.

Modifier 93

Modifier 93 is used for synchronous telehealth services provided through audio-only communication.

This applies when the provider and patient interact in real time using audio only.

Modifier 95

Modifier 95 is used for synchronous telehealth services provided through audio and video communication.

This applies when the provider and patient interact in real time using both audio and video technology.

What Does This Look Like in Practice?

Under the previous billing structure, an eligible RHC or FQHC telehealth encounter may have been reported using:

G2025

Under the new structure, the claim identifies the actual service provided.

For example:

99213 + Modifier 95

could be used when an eligible established-patient office or outpatient service is performed through real-time audio and video, assuming the service meets Medicare's telehealth requirements.

For an eligible audio-only service, the applicable CPT or HCPCS code would instead be reported with:

Modifier 93

The exact service code depends on what was performed and whether that service is included on Medicare's approved telehealth services list.

Why Did Medicare Make the Change?

Using a single code such as G2025 made it difficult to identify the specific service being furnished during the telehealth encounter.

Reporting the individual CPT or HCPCS code gives Medicare more detailed information about the services being provided through telehealth.

It also brings RHC and FQHC telehealth reporting closer to the service-specific coding used in other Medicare telehealth billing.

Does This Apply to Every Medical Practice?

No.

This specific October 1 billing change applies to Rural Health Clinics and Federally Qualified Health Centers furnishing qualifying Medicare distant-site telehealth services.

Other physicians, practitioners, and healthcare organizations may already follow different Medicare telehealth billing rules.

Providers should always verify the requirements that apply to their specific provider type and service.

Are All CPT and HCPCS Codes Eligible for Telehealth?

No.

A service must be included on Medicare's approved telehealth services list in order to qualify for Medicare telehealth billing.

Adding modifier 93 or 95 to a service does not automatically make that service eligible for telehealth reimbursement.

CMS maintains a list of services that may be furnished through Medicare telehealth, and those requirements should be reviewed when determining whether a particular service qualifies.

What Happens to G2025?

For the affected RHC and FQHC distant-site telehealth services, G2025 is no longer the code used in the same way it was before October 1.

Instead, Medicare now requires the specific service code to be reported with the appropriate telehealth modifier.

Providers should pay close attention to the date of service, since claims for services performed before and after October 1 may follow different billing requirements.

The Bottom Line

The Medicare telehealth billing change effective October 1, 2026, marks a shift away from the general G2025 telehealth code for affected RHC and FQHC services.

The new approach requires providers to identify:

The actual service performed

and

How the telehealth service was delivered

For qualifying services, that means reporting the appropriate CPT or HCPCS code along with either modifier 93 for audio-only or modifier 95 for audio-and-video telehealth.

For RHCs and FQHCs, understanding the change is important when billing Medicare telehealth services with dates of service beginning October 1, 2026.

Sources

Centers for Medicare & Medicaid Services (CMS). Rural Health Clinics & Federally Qualified Health Centers: Billing Distant Site Telehealth Services — MLN Matters MM14468.
Effective October 1, 2026, RHCs and FQHCs must report the individual CPT or HCPCS code describing the distant-site telehealth service instead of G2025, along with modifier 93 or 95 as applicable.
https://www.cms.gov/files/document/mm14468-rural-health-clinics-federally-qualified-health-centers-billing-distant-site-telehealth.pdf

Centers for Medicare & Medicaid Services (CMS). FQHC/RHC News & Announcements — CY 2026 Physician Fee Schedule Final Rule Highlights.
CMS summary of the October 1, 2026 telehealth billing change, including the definitions of modifiers 93 and 95.
https://www.cms.gov/fqhc-rhc-news-announcements

Centers for Medicare & Medicaid Services (CMS). List of Telehealth Services.
CMS's current list of services payable under the Medicare Physician Fee Schedule when furnished via telehealth.
https://www.cms.gov/medicare/coverage/telehealth/list-services

Centers for Medicare & Medicaid Services (CMS). Non-Behavioral Services Furnished via Telehealth From a Distant Site — Change Request 13975.
Provides additional background on G2025, its use beginning in 2021, and the transition to individual CPT/HCPCS reporting effective October 1, 2026.
https://www.cms.gov/files/document/r13975cp.pdf