
For Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), CMS will extend through December 31, 2026, the ability to bill for medical (non-behavioral health) telehealth visits—including audio-only—using code G2025.
These services will continue to be paid based on the PFS methodology rather than the PPS/AIR rate. CMS acknowledged stakeholder requests to permanently allow PPS/AIR reimbursement for FQHC and RHC telehealth medical visits, as is now the case for mental health visits provided via telecommunications technology but declined to adopt that change due to cost concerns.
With the expiration of the Medicare telehealth waivers on September 30, 2025, CMS finalized new in-person requirements for telemental health services furnished by FQHCs and RHCs. Under the final policy for services provided on and after October 1, 2025, an in-person visit must occur within six months prior to the first telemental health service, and at least once every 12 months thereafter, unless the provider and patient document that the risks and burdens of in-person care outweigh the benefits.
CMS also acknowledged concerns raised in public comments about provider privacy and the use of home addresses when enrolling as distant-site telehealth providers. While CMS declined to extend the temporary allowance that let providers continue using their practice location instead of their home address, CMS referenced a recently published FAQ explaining the process for suppressing address information from public display.