CMS retires G2025 for RHC and FQHC telehealth on October 1: bill the individual code plus a modifier
Starting with dates of service on October 1, 2026, rural health clinics and FQHCs stop billing the bundled code G2025 for distant site telehealth and bill the specific CPT or HCPCS code plus modifier 93 or 95. Get the crosswalk and the modifier logic set before the first claim rejects.
By the HCC Buddy Coding Team
Published July 31, 2026
Key Takeaways
- →For dates of service on or after October 1, 2026, RHCs and FQHCs must bill the individual CPT or HCPCS code for distant site telehealth instead of the bundled code G2025 (CMS Change Request 14468 / MLN Matters MM14468, released May 27, 2026).
- →Each distant site telehealth line requires modifier 93 for audio-only visits or modifier 95 for real-time audio-and-video visits.
- →The eligible codes are the ones on the CY List of Telehealth Services that CMS publishes each year with the Physician Fee Schedule, so the crosswalk depends on the code list in effect for the date of service.
- →CMS applies patient coinsurance and deductible to RHC distant site telehealth services and coinsurance to FQHC services, based on the lesser of the payment rate or the submitted charge, with preventive services waived.
- →The billing flexibility runs until January 1, 2028 under Section 6209(c) of the Consolidated Appropriations Act, 2026, so the individual-code method is how these services are billed for at least the next year.
Starting October 1, 2026, RHCs and FQHCs can't bill G2025 for distant site telehealth anymore. You bill the specific CPT or HCPCS code for the service you actually did, plus one telehealth modifier. CMS spelled it out in Change Request 14468 (MLN Matters MM14468, released May 27, 2026): effective for dates of service on or after October 1, 2026, with an implementation date of October 5.
If your clinic bills any distant site telehealth, this is a claim-line change your billing staff has to make on a hard date. A G2025 line submitted for an October date of service is built on a code CMS no longer wants for that service.
What changes on October 1, 2026
Today, RHCs and FQHCs report non-behavioral-health distant site telehealth to Medicare Part B with one code, G2025. From October 1 forward, you report the specific service you actually delivered, using its own CPT or HCPCS code, plus the right revenue code and one telehealth modifier. The service doesn't change. The code you put on the claim does.
| On the claim | Through September 30, 2026 | On and after October 1, 2026 |
|---|---|---|
| Distant site telehealth code | Single bundled code G2025 | The individual CPT or HCPCS code for the service furnished |
| Modifier | None (G2025 took no 93/95) | Modifier 93 or 95, per modality |
| Where the eligible codes come from | n/a | The CY List of Telehealth Services CMS publishes with the Physician Fee Schedule |
| Behavioral health telehealth | Billed separately | Billed separately (this change covers non-behavioral-health) |
One code becomes many
G2025 was a stand-in. It let a clinic bill a distant site telehealth visit without naming the underlying service. That stops. The codes you switch to are the ones on the CY List of Telehealth Services that CMS updates each year alongside the CY2027 Physician Fee Schedule rule, so your crosswalk depends on the code list in effect for the date of service, not last year's.
Practically, that means building a short table for your own clinic: the handful of telehealth services you actually bill, each mapped from G2025 to the specific code you'll report from October 1. Pull the CY List of Telehealth Services, match your real volume against it, and stop there. You don't need the whole list, just the codes your clinic touches.
The modifier call: 93 for audio-only, 95 for audio and video
Every distant site telehealth line now needs one of two modifiers, and the split is the modality of the visit:
| Modifier | Use it when the visit was |
|---|---|
| 93 | Synchronous, audio-only (telephone or other real-time audio) |
| 95 | Synchronous, real-time audio and video |
The modifier is only as good as your intake. If registration or the note doesn't record whether the visit was audio-only or audio-video, there's nothing to pick the modifier from. Fix that recording step first, and the modifier follows.
The patient cost-sharing that G2025 was masking
The switch isn't only about which code. The rate is set differently now. CMS pays a volume-weighted average of the services on the PFS telehealth list, with no geographic adjustment, updated every year. What patients owe rides on that rate: RHC services carry coinsurance and the deductible, FQHC services carry coinsurance, both figured on the lesser of the payment rate or the submitted charge. Preventive services stay waived.
If your patient statements and estimates were built around how G2025 behaved, re-check them against the individual-code rates before October, so a patient's first post-switch bill isn't a surprise your front desk has to defend.
This is still your documentation problem
A telehealth encounter is still a valid source for a risk-adjustment diagnosis when the visit meets the requirements, and the diagnosis you put on that claim still needs MEAT-level support in the note, the same as any in-person visit. See why telehealth counts as a risk-adjustment source and the MEAT criteria before you lean on a telehealth encounter to carry an HCC. A clean code on the claim doesn't rescue a note that doesn't support the diagnosis.
There's also a denial angle. Coding-related denials are already a growing share of completed payer-audit denials, and a code-and-modifier switch on a hard date is exactly the kind of change that produces a rejection wave when a clinic misses it. Test a few claims before October rather than finding out from your remittance.
How long this method lasts
This isn't a one-quarter blip to wait out. Section 6209(c) of the Consolidated Appropriations Act, 2026 extended the flexibility that lets RHCs and FQHCs serve as distant site telehealth providers until January 1, 2028, and through CY 2027 CMS is required to pay these services at roughly the national average of comparable PFS telehealth rates. The individual-code method is how you bill distant site telehealth for at least the next year, so it's worth setting up cleanly once.
What coders should do now
- 1Build a clinic-specific crosswalk: list the distant site telehealth services you actually bill, and map each from G2025 to its individual CPT or HCPCS code using the current CY List of Telehealth Services.
- 2Set the modifier logic in your claim workflow so every distant site telehealth line carries 93 (audio-only) or 95 (audio and video), and fix the intake step that records which modality each visit used.
- 3Re-check your patient cost estimates and statements against the individual-code payment method, since coinsurance and the deductible now ride on the specific service code rather than the bundled G2025 line.
- 4Run a few test claims with the new codes and modifiers before October 1 so a code-and-modifier miss shows up in a test, not in a wave of October remittance rejections.
- 5Confirm each risk-adjustment diagnosis coded from a telehealth encounter still has MEAT-level support in the note, because the billing change doesn't change the documentation standard for the diagnosis.
Frequently Asked Questions
When do RHCs and FQHCs have to stop billing G2025 for telehealth?
For dates of service on or after October 1, 2026. CMS Change Request 14468 (MLN Matters MM14468, released May 27, 2026) instructs RHCs and FQHCs to bill the individual CPT or HCPCS code for the distant site telehealth service instead of the bundled code G2025 from that date, with an implementation date of October 5, 2026.
Which modifier do I use for RHC and FQHC telehealth after October 1, 2026?
Modifier 93 for a synchronous audio-only visit (telephone or other real-time audio) and modifier 95 for a synchronous real-time audio-and-video visit. One of the two modifiers goes on every distant site telehealth line along with the appropriate revenue code.
Where do the individual telehealth codes come from?
They're the codes on the CY List of Telehealth Services that CMS publishes annually with the Physician Fee Schedule. You bill the specific code that describes the service you furnished, so map your clinic's telehealth services against the code list in effect for the date of service.
Does the G2025 change affect what patients owe?
It can. CMS applies coinsurance and the deductible to RHC distant site telehealth services and coinsurance to FQHC services, based on the lesser of the payment rate or the submitted charge, with preventive services waived. Because cost-sharing now attaches to the individual service code, check your estimates and statements before the switch.
Sources
- MLN Matters MM14468: Rural Health Clinics and Federally Qualified Health Centers, Billing Distant Site Telehealth Services — CMS, May 27, 2026
- Change Request 14468, Transmittal R13776OTN, Billing of Distant Site Telehealth Services in RHCs and FQHCs — CMS, May 27, 2026
- List of Telehealth Services — CMS, Jan 1, 2026
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