Oasis Medical Solutions Blog
Updated September, 2026
By: Ashley Williams
Good news: Congress extended the telehealth flexibilities that allow RHCs and FQHCs to serve as distant site providers of telehealth services until January 1, 2028, under the Consolidated Appropriations Act, 2026. This means your clinic can continue offering telehealth services through the end of CY 2027.
However, a significant billing change takes effect on October 1, 2026. RHCs and FQHCs must stop using HCPCS code G2025 for distant site telehealth services and instead bill the individual CPT or HCPCS code for each service, along with the correct telehealth modifier (93 for audio-only, 95 for audio + video). The CY 2026 payment rate is $97.53 per service.
CMS has also added several new telehealth codes for CY 2026. We’ve put together a complete guide with a downloadable quick reference and the full code list: New CMS Telehealth Billing Rules for RHCs and FQHCs: What Your Practice Needs to Do Before October 1, 2026.
The original article below covers the October 2025 policy changes and claims hold that preceded this extension.
It’s understandable if your Rural Health Clinic is confused. The telehealth reimbursement policy landscape is evolving rapidly, making it hard 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.
...and be ready to switch at-home visits back on instantly when policy (and payment) changes again.
While the policy landscape is chaotic, your technology partner shouldn't be. Oasis Medical Solutions helps RHCs implement and optimize these tools, so you have the stability and flexibility to be ready for whatever comes next.
Learn more about how Oasis Medical Solutions and Azalea Health provide a stable, all-in-one solution for Rural Health Clinics, or contact us today for a consultation.