RHC Telehealth Whiplash: What to Know About the Oct. 1 Policy Changes & New Claims Hold

It’s understandable if your Rural Health Clinic is confused. The policy landscape for telehealth reimbursement is evolving rapidly, making it challenging to stay current.

This "telehealth whiplash" is a significant source of frustration for clinics just trying to serve their patients.

First, it was the problematic G2025 flat rate, which was lower than the RHC all-inclusive rate.

Now, with the Oct. 1 expiration of pandemic flexibilities, Medicare reimbursement for RHC at-home telehealth visits has lapsed. Patients must now be in another medical facility, creating a massive new barrier to care.

To further complicate matters, on October 15, CMS announced that all Medicare Administrative Contractors (MACs) will temporarily hold all FQHC and Physician Fee Schedule claims (which includes RHCs) with a date of service of October 1, 2025, or later. They are doing this "in anticipation of possible Congressional action" to extend the expired telehealth rules.

Just one week later, on October 22, CMS updated this guidance, adding to the confusion. They instructed MACs to lift the hold for most standard claims (such as RHC in-person visits and FQHC claims), but to continue holding the specific non-behavioral telehealth claims that are at the center of the policy debate.

This places clinics in a difficult position: you must continue to submit claims, but you will not be paid for non-behavioral telehealth services until the hold is lifted.

In the same announcement, CMS suggests that practitioners may want to provide an Advance Beneficiary Notice (ABN) for at-home telehealth services, as they are not currently payable by Medicare.

The only exception to the at-home rule remains mental health telehealth services, which are exempt from this requirement and are reimbursed at the standard rate.