Eligible Distant Site
Temporary Policy – Ends Dec. 31, 2024
During the emergency period described in section 1320b–5(g)(1)(B) of this title and, in the case that such emergency period ends before December 31, 2024, during the period beginning on the first day after the end of such emergency period and ending on September 30, 2025—
- the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;
- the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and
- for purposes of this subsection—
- the term “distant site” includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and
- the term “telehealth services” includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service.
SOURCE: Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m). (Accessed Apr. 2025).
RHCs and FQHCs can continue to provide on a temporary basis, for non-behavioral health visits furnished via telecommunication technology under the methodology that has been in place for these services during and after the COVID-19 PHE through December 31, 2024. Specifically, RHCs and FQHCs can continue to bill for RHC and FQHC services furnished using telecommunication technology by reporting HCPCS code G2025 on the claim, including services furnished using audio-only communications technology through December 31, 2025. For payment for non-behavioral health visits furnished via telecommunication technology in CY 2025, the payment amount is based on the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS
SOURCE: CMS Manual System, Transmittal 13133, March 20, 2025, (Accessed Apr. 2025).
CMS will continue to allow on a temporary basis payment to FQHCs and RHCs for non-behavioral health visits that use telecommunications technology. This temporary policy would allow other non-mental health services to be provided via telehealth by FQHCs and RHCs through 2025 by continuing to use the code G2025 to bill. CMS notes that this will help ensure continuation of services if the current telehealth waivers do expire on December 31, 2024. It should be noted that in calculating the amount to be reimbursed for G2025, CMS will be basing it on the average amount for all PFS telehealth services on the telehealth list, weighted by the volume for those services reported under the PFS.
We’ll continue to pay Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for:
- Non-behavioral telehealth medical visit services through March 31, 2025, using the payment amount based on the average amount for all Medicare telehealth services paid under the Physician Fee Schedule (PFS), weighted by volume
- Behavioral health services provided on or after January 1, 2022, under the RHC All-Inclusive Rate (AIR) and FQHC Prospective Payment System (PPS), respectively
We’ll delay the in-person visit requirements for mental health visits that RHCs and FQHCs provide via telecommunications technology through March 31, 2025
We’ll continue to pay Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for:
- Non-behavioral telehealth medical visit services through March 31, 2025, using the payment amount based on the average amount for all Medicare telehealth services paid under the Physician Fee Schedule (PFS), weighted by volume
- Behavioral health services provided on or after January 1, 2022, under the RHC All-Inclusive Rate (AIR) and FQHC Prospective Payment System (PPS), respectively
We’ll delay the in-person visit requirements for mental health visits that RHCs and FQHCs provide via telecommunications technology through March 31, 2025
Q4: How does CMS make payment for telehealth services furnished in RHCs and FQHCs? Can Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) continue to serve as distant sites for the provision of telehealth services?
A4: Any behavioral health service furnished by an RHC or FQHC on or after January 1, 2022 through interactive telecommunications technology is paid under the All Inclusive Rate (AIR) and Prospective Payment System (PPS), respectively. Through March 31, 2025, RHCs and FQHCs may continue to bill for non-behavioral health services furnished through interactive telecommunications technology by reporting HCPCS code G2025 on the claim.
Q5: Will in person visit requirements apply to behavioral health services furnished by professionals through Medicare telehealth? What about behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, or behavioral health visits furnished by RHCs, and FQHCs where the patient is present virtually?
A5: The American Relief Act, 2025 has delayed in-person visit requirements for behavioral health services for professionals billing for Medicare telehealth services until April 1, 2025.
Regarding behavioral health services furnished remotely by hospital staff to beneficiaries in their homes, we are continuing to align our policy with requirements for Medicare telehealth services billed under the PFS. Accordingly, we are also delaying the in-person visit requirements for these services until April 1, 2025.
In the CY 2025 PFS final rule, we finalized that for behavioral health visits furnished by RHCs and FQHCs where the patient is present virtually, we are delaying in-person visit requirements until January 1, 2026.
SOURCE: CMS, Telehealth FAQ Calendar Year 2025, (Accessed Apr. 2025).
Prior to March 27, 2020, RHCs and FQHCs were not authorized to serve as a distant site for telehealth consultations, which is the location of the practitioner at the time the telehealth service is furnished, and they could not bill or include the cost of a visit on the cost report. This included telehealth services that are furnished by an RHC or FQHC practitioner who is employed by or under contract with the RHC or FQHC, or a non-RHC or FQHC practitioner furnishing services through a direct or indirect contract. For more information on Medicare telehealth services, see Pub. 100-02, Medicare Benefit Policy Manual, chapter 15, and Pub. 100-04, Medicare Claims Processing Manual, chapter 12.
On March 27, 2020, Congress signed into law the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Section 3704 of the CARES Act authorized RHCs and FQHCs to provide distant site telehealth services to Medicare patients during the COVID-19 PHE. Section 4113 of the Consolidated Appropriations Act, 2023, extended this authority through December 31, 2024. Any health care practitioner working within their scope of practice can provide distant site telehealth services. Practitioners can provide distant site telehealth services – approved by Medicare as a distant site telehealth service under the physician fee schedule (PFS) – from any location in the United States (see 42 CFR 411.9(a)(1)), including their home, during the time that they’re employed by or under contract with the RHC or FQHC.
FQHCs are not listed as an eligible distant site provider that can deliver services via telehealth. However, FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. See MLN Guidance for requirements.
Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.
A distant site is the location where a physician or practitioner provides telehealth. Before the COVID-19 PHE, only certain types of distant site providers could provide and get paid for telehealth. Through December 31, 2024, all providers who are eligible to bill Medicare for professional services, including FQHCs/RHCs, can provide distant site telehealth.
Practitioners can provide telehealth from any distant site location, including their home, during the time they’re working for the FQHC/RHC, and they can provide any distant site-approved telehealth under the PFS. You can’t bill the visit’s cost or include it on the cost report.
SOURCE: Centers for Medicaid and Medicare Services, Medicare Learning Network Booklet 6397, Federally Qualified Health Centers, Jan. 2024, & MLN Booklet 6398, Rural Health Clinics, Mar. 2024, (Accessed Apr. 2024).
* The US Health and Human Services Administration maintains a website that summarizes information for Billing Medicare as a safety-net provider.
See: Federal Medicare Live Video Distant Site
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