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 Jul. 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 Jul. 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.

SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (Accessed Jul. 2025).

We’ll continue to pay Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for:

• Non-behavioral telehealth medical visit services through September 30, 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 and mental health telehealth services 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 until January 1, 2026.

SOURCE: Centers for Medicare and Medicaid Services (CMS), Telehealth Services MLN Fact Sheet, Apr. 2025, (Accessed Jul. 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 Jul. 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. 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. 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.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 3/20/25, pg. 46-47, (Accessed Jul. 2025).

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.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 3/20/25, pg. 43, (Accessed Jul. 2025).

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.

For behavioral and mental telehealth services, FQHCs can serve as distant site providers. For non-behavioral and non-mental health services, FQHCs can serve as distant site providers through September 30, 2025.

Practitioners can provide telehealth from any distant site location, including their home, during the time they’re working for the FQHC, and they can provide any distant site-approved telehealth under the PFS. You can’t bill the visit’s cost or include it in the cost report.

SOURCE: Centers for Medicaid and Medicare Services, Medicare Learning Network Booklet 6397, Federally Qualified Health Centers, Apr. 2024, & MLN Booklet 6398, Rural Health Clinics, Jul. 2025, (Accessed Jul. 2025).

* 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

Not included on distant site provider list in Medicaid Telemedicine Policy.

SOURCE: AL Medicaid Management Information System Provider Manual, Telemedicine Services, Ch. 112, Apr. 2025, (Accessed Jun. 2025).

The department shall pay for all services covered by the medical assistance program provided through telehealth if the department pays for those services when provided in person, including:

…

1. services provided by a rural health clinic or a federally qualified health center;

SOURCE: AK Statute Sec. 47.07.069, (Accessed Jun. 2025).

Submitting a claim for a telemedicine service is identical to the way a claim would be submitted for a face-to-face visit. Depending on the method of telemedicine used and the role of the provider in the consultation determines whether a modifier should be added to the procedure code. The role of the provider falls into three categories:

• Consulting Provider: Evaluates the patient and/or medical data/images using telemedicine mode of delivery upon recommendation of the referring provider.

NOTE: Manual is under review.

SOURCE: AK Dept. of Health and Social Svcs. Billing for Telemedicine Services. Section II: Professional Claims Management [listed under FQHC tab], Feb. 6, 2020, pg. 20, (Accessed Jun. 2025).

Patient Initiated Evaluation and Management Services

Patient initiated evaluation and management services (telephone or online digital) are covered when performed by advanced practice registered nurses (APRNs), audiologists, Community Health Aides (CHAs), direct entry midwives (DEMs), optometrists, physicians, physician assistants, and podiatrists. Federally Qualified Health Centers (FQHCs) and Rural Health Clinic (RHCs) are reimbursed at the facilities encounter rate for services provided by a rendering provider listed here.

See fee schedule for codes.

Patient Initiated Assessment and Management Services

Patient initiated assessment and management services are covered when performed by behavioral health aides (BHAs) under the direction of a physician, psychologists, and school districts enrolled as a school-based service provider. Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs) may be reimbursed at the facilities encounter rate for services provided by licensed clinical social workers (LCSWs), marital and family therapists, professional counselors, and psychologists.

See fee schedule for codes.

SOURCE: Alaska Medicaid, Telehealth Services: Temporary Fee Schedule, Effective 4/30/25, (Accessed Jun. 2025).

Telehealth and telemedicine may qualify as a FQHC/RHC visit if it meets the requirements as specified in AMPM Policy 320-I.  To qualify as a reimbursable telehealth visit, claims with procedure code T1015 must additionally include another eligible code from the AHCCCS Telehealth Code Set.

SOURCE: AZ Health Care Cost Containment System, AHCCCS Fee-For-Service Provider Billing Manual, Ch. 10 Addendum: FQHC/RHC, (8/25/22), pg. 3, (Accessed May 2025.

Telehealth and Telemedicine may qualify as a FQHC/RHC visit if it meets the requirements as specified in AMPM Policy 320-I.

SOURCE: AZ Medical Policy for AHCCCS Covered Services. Federally Qualified Health Centers (FQHC) and Rural Health Clinics (RHC) Reimbursement, Ch 670, (pg. 3), Effective 10/1/15. (Accessed May 2025).

Telehealth may qualify as a Federally Qualified Healthcare Center/Rural Health Clinic (FQHC/RHC) visit, if all other applicable conditions in this Policy are met. Refer to AMPM Policy 670.

SOURCE: AZ Medical Policy for AHCCCS Covered Services. Telehealth and Telemedicine Ch 300, (320-I pg. 5), Approved 10/29/24, (Accessed May 2025)

To comply with CMS mandate, telehealth visits are to be paid the same as a face-to-face encounter visit for FQHC providers. The following procedure codes have had the rates updated to match their encounter rate: G2025

SOURCE: AR Department of Human Services, FQHC Provider Rate for G2025, Sept. 15, 2023, (Accessed May 2025).

The telemedicine procedure code and procedure codes for ancillary services, except for family planning-related laboratory procedures listed in this manual, will be denied.

SOURCE:  AR Medicaid Provider Manual. Section II FQHC. Rule 252.140. Updated Oct. 13, 2003. pg. II-27, (Accessed May 2025).

FQHC Manual refers providers to Telemedicine policy manual for encounters.  

See:  AR Medicaid Live Video Eligible Providers.

Yes, see manual for distant site scenarios and billing/reimbursement policies applicable.

The billable provider, employed or under direct contract with an FQHC or RHC can respond from any location, including their home, during a time that they are scheduled to work for the FQHC or RHC.

For the purposes of payment for covered treatment or services provided through telehealth, the department shall not limit the type of setting where services are provided for the patient or by the health care provider.

SOURCE: CA Department of Health Care Services (DHCS). Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual (Mar. 2024), p. 17-21. (Accessed May 2025).

For Health First Colorado a billable encounter at an FQHC and RHC is an in person or telemedicine face to face visit with a Health First Colorado member. Telemedicine services are limited to the procedure codes identified in the Telemedicine Billing Manual. Services provided via telemedicine must use modifier GT on the claim. All other claim submission information is the same.

Additionally, modifiers FQ and FR can be added to the claim:

• FQ: The service was furnished using audio-only communication technology.
• FR: The supervising practitioner was present through two-way, audio/video communication technology.

SOURCE: CO FQHC & RHC Billing Manual 4/25. (Accessed Jun. 2025).

Health First Colorado allows telemedicine visits to qualify as billable encounters for Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs), and Indian Health Services (IHS). Services allowed under telemedicine may be provided via telephone, live chat, or interactive audiovisual modality for these provider types.

The following provider types may bill using modifier GT: …

• FQHC

When used by an FQHC or RHC, the modifier GT identifies the services as being delivered through telemedicine modality. There is no enhanced payment to FQHCs and RHCs when using the modifier GT.

When a Federally Qualified Health Center (FQHC) or a Rural Health Clinic (RHC) provides care through telemedicine, the claim must include the modifier GT on line(s) identifying the service(s). The claims must follow the other requirements of an FQHC or RHC claim as identified in the FQHC and RHC Billing Manual.

SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 5/25. (Accessed Jun 2025).

Federally Qualified Health Centers (FQHCs) are eligible to bill their encounter rate when an approved, medically necessary telehealth service is rendered. FQHCs must use the services identified on the CMAP Telehealth Table in combination with their approved scope of service to identify the services eligible to be rendered using telehealth. FQHCs must continue to bill HCPCS code, T1015 and all eligible telehealth procedure codes to reflect all of the services rendered during the telehealth visit.

SOURCE: CMAP Telehealth Table. (Accessed May 2025).

FQHCs are listed as eligible providers for a variety of services via telehealth and guidance states that the modifier GT is used when the member’s originating site is located in a healthcare facility or office; or modifier 95 Is used when the member is located at home.

SOURCE: CT Policy – Provider Bulletin 2020-09. March 2020. (Accessed May 2025).

FQHCs are not explicitly listed as eligible distant site providers, although the provider list states that other providers can be approved by DMAP. In addition, COVID-19 guidance implied that FQHCs should “continue” typical billing practices for telehealth services as distant site/rendering providers:

• FQHC Rendering Providers billing for Interactive Telehealth Services or Telephonic Services should continue to bill their appropriate HCPCS (Healthcare Common Procedure Coding System) “G” visit payment code for each payable encounter visit, along with the appropriate code for the service provided and use Place of Service value 02 for all Telehealth Charges. For Telephonic Services, the same codes listed above should be used as appropriate.

SOURCE: DE Medical Assistance Program. Changes to DMMA Telehealth Policies to Respond to COVID-19. April 23, 2020. (Accessed May 2025).

Generally, to receive payment for services delivered through telemedicine technology from DMAP or MCOs, healthcare practitioners must:

• Act within their scope of practice;
• Be licensed (in Delaware, or the State in which the provider is located if exempted under Delaware State law to provide telemedicine services without a Delaware (license) for the service for which they bill DMAP;
• Be enrolled with DMAP/MCOs;
• Be located within the continental United States;
• Be credentialed by DMMA-contracted MCOs, when needed;
• Submit a DMMA Disclosure Form.

SOURCE: DE Adult Behavioral Health Service Certification and Reimbursement. Dec. 1, 2016. Sec. 1.8. Pg. 11. (Accessed May 2025).

Explicitly listed eligible distant site providers include:

• Inpatient/outpatient hospitals (including ER)
• Physicians (or PAs under the physician’s supervision)
• Certified Nurse Practitioners

• Nurse Midwives
• Licensed Psychologists
• Licensed Clinical Social Workers
• Licensed Professional Counselors of Mental Health
• Speech Language Therapists
• Audiologists
• Other providers as approved by the DMAP

SOURCE: Adult Behavioral Health Service Certification and Reimbursement. Dec. 1, 2016. Sec. 1.8. Pg. 12. (Accessed May 2025).

FQHCs are eligible distant site providers.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7,  Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 3. Physicians Billing Manual.  DC Medicaid.  (Jan. 2024) Sec. 15.3. P. 52, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 15.3, P. 50. FQHC Billing Manual, DC Medicaid 15.3, P. 52. (Oct. 2023), Behavioral Health Billing Manual (Feb. 2024) 14.3, p. 69. Outpatient Hospital Billing Guide, 15.8.3, p. 74 (Sept. 2023), Inpatient Hospital Billing Guide, 11.3, p. 61 (Jan. 2024), Long-Term Care Billing Manual, 15.3, p. 52 (Sept. 2023). (Accessed Mar. 2024).

No Reference Found.

FQHC’s and RHC’s are authorized to serve as a distant site for telehealth services, and may bill the cost of the visit.

SOURCE:  Georgia Department of Community Health, Division of Medicaid, Telehealth Guidance, p. 17 (Apr. 1, 2025).  Georgia Department of Community Health, Division of Medicaid, Federally Qualified Health Center Services and Rural Health Clinic Services, p. 27 (Apr. 1, 2025). (Accessed Jun 2025).

Distant/Hub Site:

The location of the enrolled Hawai’i Medicaid provider delivering Medicaid eligible services through telehealth. The U.S. Department of Health and Human Services Office for Civil Rights expects health care providers will implement HIPAA safeguards and conduct telehealth in private settings, such as a doctor in a clinic or office connecting to a patient who is at home or at another clinic.

If a provider does not have the capacity to provide in-person services, they must inform the patient that: the patient has the right to receive in-person services if they prefer; they (the provider) are incapable of providing in-person services; and they (the provider) must inform the patient that their QI MCO can assist with finding a provider who can provide in-person services.

With exceptions, the FQHC provider must be located at their contracted FQHC’s HRSA approved site or satellite.

Exceptions:

• Until December 31, 2024, FQHC behavioral health providers may be located at a non-HRSA approved site or satellite within the United States and the United States’ territories.
• If prescribing controlled substances, the provider must be located in the State of Hawai’i.

SOURCE: Med-QUEST Memo QI-2338/FFS 23-22/CCS-2311.  (Accessed Jun. 2025).

Distant site means the location of the health care provider delivering services through telehealth at the time the services are provided.

SOURCE: HI Revised Statues Section 346-59.1(g). (Accessed Jun 2025).

Teledentistry

Clinics that qualify for FQHC Prospective Payment System (PPS) reimbursement may submit telehealth claims using PPS reimbursement, as long as both the patient and dentist were each physically located at separate eligible FQHC/RHC sites during the encounter and the diagnosis. (Form 5b service sites registered with Med-QUEST as a Medicaid location and issued a HRSA Notice of Award identifying the specific service location address). Refer to Provider Memo QI-2338/ FFS 23-22. The first lines of these claims should be D9999 or D0140.

Claims for patients that were located at “public health settings” not federally registered as a FQHC or RHC service site are not eligible for PPS reimbursement.

SOURCE: HI Med-QUEST Medicaid Provider Manual Dental Benefits (May 2025), p. 40.  (Accessed Jun. 2025).

Medicaid policy is not subject to Medicare restrictions for virtual care unless the participant has Medicare primary. Otherwise, all Medicaid providers, including federally qualified health centers (FQHC’s), rural health centers (RHC’s), and Indian health clinics (IHC’s) may bill for virtual care services according to these guidelines.

FQHC, RHC or IHS providers should not report the GT or FQ modifier with encounter code T1015 but should include it with each applicable supporting codes.

SOURCE: ID Medicaid Provider Handbook: General Information and Requirements for Providers (May 9, 2025), p. 144-5.  ID MedicAide May 2023.  (Accessed Jun 2025).

Virtual care services provided as an encounter by a facility are reimbursable if the services are delivered in accordance with the Virtual Care Services section of the General Information and Requirements for Providers, Idaho Medicaid Provider Handbook.

SOURCE: ID Medicaid Provider Handbook, IHS, FQHC, and RHC Services, p. 17 (Apr. 17, 2025).  (Accessed Jun 2025).

The Distant Site is the site where the provider rendering the telehealth service is located. The Distant Site shall be reimbursed as follows:

• If the Originating Site is an encounter clinic, the Distant Site may not seek reimbursement from the Department for their services. The Originating Site encounter clinic is responsible for reimbursing the Distant Site.
• If the Originating Site is not an encounter clinic, the Distant Site encounter clinic can seek reimbursement from the Department.

For telemedicine services, the provider rendering the service at the Distant Site can be a physician, podiatrist, advanced practice nurse (APN), or a Physician Assistant (PA) who is licensed by the State of Illinois or by the state where the participant is located. For telepsychiatry services, the provider rendering the service at the Distant Site must be a physician licensed by the State of Illinois, or by the state where the patient is located, who has completed an approved general psychiatry residency program or a child and adolescent psychiatry residency program. Telepsychiatry is not a covered service when rendered by an APN or PA. Group psychotherapy is not a covered telepsychiatry service.

SOURCE: Handbook for Encounter Clinic Services. Ch. 200, pg. 17-18.  Aug. 2016. (Accessed Jun 2025).

An encounter clinic serving as the distant site shall be reimbursed as follows:

1. If the originating site is another encounter clinic, the distant site encounter clinic shall receive no reimbursement from the Department.  The originating site encounter clinic is responsible for reimbursement to the distant site encounter clinic; and
2. If the originating site is not an encounter clinic, the distant site encounter clinic shall be reimbursed for its medical encounter.  The originating site provider will receive a facility fee as defined in subsection (a)(4) of this Section.

SOURCE: IL Administrative Code 89 140.403 (3). (Accessed Jun 2025).

See billing examples in appendix.

SOURCE:  IL Dept of Healthcare and Family Services All Providers Handbook Supplement (Sept. 23, 2020). Encounter Clinic Services – Appendices. (Accessed Jun 2025).

FQHCs, RHCs, and ERCs billing for FFS reimbursement of LARCs at the Practitioner Fee Schedule rate, as well as virtual check-in and e-visit services at the FFS rate indicated on the COVID-19 Virtual Healthcare Expansion Billing Codes fee schedule found on the COVID-19 Updates webpage, must adhere to the following guidelines for proper reimbursement:

• Report only the applicable CPT or HCPCS procedure code, without reporting the T1015 encounter code.
• Report one of the following taxonomy codes in billing loop 2010AA, in accordance with the Chapter 300 Taxonomy table for 837P, in order for the clinic to be correctly identified as the provider of record for FFS reimbursement:

o   261QF0400X (FQHC)

o   261QR1300X (RHC)

o   261QP2300X (ERC)

Additional detailed reimbursement criteria specific to FFS billing of LARCs is also found in Topic 210.5.2 of the Handbook for Providers of Encounter Clinic Services.

SOURCE: Provider Notice Billing Procedures for Fee-For-Service Reimbursement and Telehealth Billing Clarification (May 20, 2020). (Accessed Jun 2025).

FQHC and RHC providers may bill for telehealth services if the service rendered is considered a valid FQHC or RHC encounter (as defined in this module) and a covered telehealth service (as defined in Telehealth and Virtual Services Codes, accessible from the Code Sets page at in.gov/medicaid/providers). When billing valid telehealth encounters, the encounter code (T1015 or D9999) should be billed as usual, and each service provided during the encounter must include an appropriate telehealth POS code (02 or 10) and telehealth modifier (93 or 95), as described in the FQHC and RHC Telehealth Services section of the Telehealth and Virtual Services module.

Dental services do not require a modifier indicating the method of telehealth delivery. Dental services cannot be provided via audio-only telehealth. The only dental service that FQHCs and RHCs can bill as telehealth is D0140 – Limited oral evaluation – problem focused.

SOURCE: Indiana Health Coverage Programs, Provider Reference Module, Federally Qualified Health Centers and Rural Health Clinics, p. 6 (May 7, 2024). (Accessed Jul 2025).

When the FQHC or RHC is the distant site, the service provided by the FQHC or RHC must meet the requirements both for a valid encounter and for an approved telehealth service. The claim must include the following:

• Encounter code T1015 (or D9999 for valid dental encounters), billed with POS code 02, 03, 04, 10, 11, 12, 31, 32, 50 or 72
• One or more appropriate procedure codes for the specific services rendered, billed with modifier 93 or 95, and a POS code of either 02 or 10, depending on the originating site/location of the patient

SOURCE: Indiana Health Coverage Programs, Provider Reference Manual, Telehealth and Virtual Services (Oct. 30, 2024), p. 6. (Accessed Jul 2025).

Subject to the following criteria, reimbursement is available to FQHCs and RHCS when they are serving as either the distant site or the originating site for telehealth services.

SOURCE: IHCP Bulletin BT 202239 (May 19, 2022), p. 3. (Accessed Jul 2025).

Effective July 28, 2025, the Indiana Health Coverage Programs (IHCP) will include the Current Procedural Terminology (CPT®1) codes and Current Dental Terminology (CDT®2) code in Table 1 as valid encounter codes for federally qualified health center (FQHC) and rural health clinic (RHC) claims. This update applies retroactively to claims with dates of service (DOS) on or after Jan. 1, 2025.

SOURCE: Indiana Health Coverage Programs, IHCP Bulletin “IHCP Updates FQHC and RHC Encounter Codes” BT202593 (June 26, 2025).  (Accessed Jul. 2025).

The Indiana Health Coverage Programs (IHCP) published IHCP Banner Page BR202152 introducing the addition of place of service (POS) code 10. The Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) is clarifying that the IHCP will allow the use of POS code 10 for federally qualified healthcare centers (FQHCs) and rural health clinics (RHCs) for dates of service (DOS) on or after July 21, 2022. Any FQHC or RHC claims with DOS before July 21, 2022, will deny if the POS 10 is present on the claim. Please correct these claims using the appropriate POS 02 and resubmit. The definitions for the telehealth POS codes changed on Jan. 1, 2022:

• POS 02 – Telehealth provided other than in patient’s home
• POS 10 – Telehealth provided in patient’s home

As posted in IHCP Bulletin BT202239, the following modifiers are used on telehealth claims:

• Modifier 95 – Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system
• Modifier 93 – Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system

Beginning July 21, 2022, FQHC and RHC providers must have one or more appropriate procedure codes for the specific services rendered, billed with modifier 93 or 95, and a POS code of either 02 or 10, depending on the originating site/location of the patient.

SOURCE: IHCP Allows New POS Code for FQHCs and RHCs July 21 BT 202253 (July 14, 2022).  (Accessed Jul 2025).

Reimbursement for medically necessary telemedicine services is available to the following providers regardless of the distance between the provider and member:

• A federally qualified health center
• A rural health clinic
• A community mental health center
• A critical access hospital
• A home health agency licensed under IC 16-27-1.
• A provider, as determined by the office to be eligible, providing a covered telehealth service.

SOURCE: IN Admin Code, “Article 5” 405 5-38-4(3) & IN Code, 12-15-5-11 (Accessed Jul 2025).  

FQHCs may serve as distant sites.

See: IA Medicaid Live Video Distant Sites

SOURCE:  Iowa Dep. of Human Services.  Informational Letter No. 2103-MC-FFS. (Feb. 20, 2020). (Accessed Apr. 2025).

Telemedicine – Note: Refer to Section 2720 of the General Benefits Fee-for-Service Provider Manual for complete details regarding Telemedicine.

SOURCE: KS Dept. of Health and Environment, Kansas Medical Assistance Program, Provider Manual, FQHC/RHC, 8-14 (4/25), (Accessed Jun 2025).

See: KS Medicaid Live Video Eligible Providers

For rural health clinics, federally qualified health centers, and federally qualified health center look-alikes, reimbursement for covered telehealth services and telehealth consultations shall:

• To the extent permitted under federal law, include an originating site fee in an amount equal to that which is permitted under 42 U.S.C. sec. 1395m for Medicare-participating providers if the Medicaid beneficiary who received the telehealth service or telehealth consultation was physically located at the rural health clinic, federally qualified health center, or federally qualified health center look-alike at the time of service or consultation delivery and the provider of the telehealth service or telehealth consultation is not employed by the rural health clinic, federally qualified health center, or federally qualified health center look-alike; or
• If the telehealth service or telehealth consultation provider is employed by the rural health clinic, federally qualified health center, or federally qualified health center look-alike, include a supplemental reimbursement paid by the Department for Medicaid Services in an amount equal to the difference between the actual reimbursement amount paid by a Medicaid managed care organization and the amount that would have been paid if reimbursement had been made directly by the department.

A health-care facility that receives reimbursement under this section for consultations provided by a Medicaid-participating provider who practices in that facility and a health professional who obtains a consultation under this section shall establish quality-of-care protocols, which may include a requirement for an annual in-person or face-to-face consultation with a patient who receives telehealth services, and patient confidentiality guidelines to ensure that telehealth consultations meet all requirements and patient care standards as required by law.

The Department for Medicaid Services and any managed care organization with whom the department contracts for the delivery of Medicaid services shall not deny reimbursement for telehealth services covered by this section based solely on quality-of-care protocols adopted by a health-care facility pursuant to paragraph (a) of this subsection.

SOURCE: KY Statute Sec. 205.559. (Accessed Jun. 2025).

See: KY Medicaid Live Video Eligible Providers

Reimbursement for service codes appropriate to telemedicine/telehealth will be at the all-inclusive prospective payment rate on file for the date of service (DOS).

SOURCE: LA Dept. of Health, Informational Bulletin 20-1. (May 20, 2022). (Accessed Jun. 2025).

FQHC manual refers to provider manual for billing instructions for telemedicine services.

SOURCE: LA Dept. of Health, Federally Qualified Health Centers Provider Manual, Chapter 22, Sec. 22.4, pg. 33, (As issued on Jun. 30, 2022), (Accessed Jun. 2025).

See: LA Medicaid Live Video Eligible Providers

Telehealth Services may be included in a Federally Qualified Health Center (FQHC), Rural Health Clinic (RHC), or Indian Health Center (IHC) scope of practice, as approved by the State. If approved, these facilities may serve as the provider site and bill under the encounter rate.

SOURCE: MaineCare Benefits Manual, Telehealth, 10-144 Ch. 101, Ch. 1, Sec. 4., p. 12. (Nov. 6, 2023). (Accessed May 2025).

Also see: ME Medicaid Live Video Eligible Providers

All distant site providers enrolled in Maryland Medicaid may provide services via telehealth as long as telehealth is a permitted delivery model within the rendering provider’s scope of practice.

SOURCE: MD Medicaid Synchronous Telehealth Policy Guide, p. 1, 7. (May 15, 2025). (Accessed May 2025).

The Program shall provide health care services appropriately delivered through telehealth to Program recipients regardless of the location of the Program recipient at the time telehealth services are provided and allow a distant site provider to provide health care services to a Program recipient from any location at which the health care services may be appropriately delivered through telehealth.

SOURCE: MD General Health Code 15-141.2(b). (Accessed May 2025).

“Distant site provider” means the licensed, certified, or otherwise authorized provider at the distant site who provides medically necessary services via telehealth to the patient

“Provider” means:

• An individual, association, partnership, corporation, unincorporated group, or any other person authorized, licensed, or certified to provide services for Medical Assistance participants and who, through appropriate agreement with the Department, has been identified as a Maryland Medical Assistance Provider by the issuance of an individual account number;
• An agent, employee, or related party of a person identified in §B(12)(a) of this regulation;
• An individual or any other person with an ownership interest in a person identified in §B(12)(a) of this regulation.

SOURCE: Code of Maryland Admin. Regs. Sec. 10.09.49.02. (Accessed May 2025).

MassHealth lists specific codes that may be used by community health centers for services delivered through telehealth.

SOURCE: MassHealth, Community Health Center Manual, Service Codes and Descriptions, 11/21/24, (Accessed Apr. 2025).

Additionally, for any institutional claim, providers are allowed to use the following modifiers:

• modifier 95 to indicate counseling and therapy services rendered via audio-video telecommunications;
• modifier 93 to indicate services rendered via audio-only telehealth;
• modifier GT to indicate services rendered via interactive audio and video telecommunications systems;
• modifier FQ to indicate counseling and therapy services provided using audio-only telecommunications;
• modifier FR to indicate that a supervising practitioner was present through a real-time two-way, audio and video communication technology; and/or
• modifier GQ to indicate services rendered via asynchronous telehealth.

Modifier GT is required on the institutional claim, for the distant-site provider, when there is an accompanying professional claim containing POS 02 or 10.

Effective August 31, 2023, modifier V3, which was previously used to indicate services rendered via audio-only telehealth, will no longer be available. Providers must use modifier 93 in its place.

Billing and Payment Rates for Services

Providers billing under an 837I/UB-04 form must include the modifier GT when submitting claims for services delivered via telehealth. Providers billing under an 837P/1500 form must include the place of service (POS) code 02 or 10 when submitting claims for services delivered via telehealth.

Additionally, for any such professional claim, providers must include:

• modifier 95 to indicate counseling and therapy services rendered via audio-video telehealth;
• modifier 93 to indicate services rendered via audio-only telehealth;
• modifier GQ to indicate services rendered via asynchronous telehealth;
• modifier FQ to indicate counseling and therapy services provided using audio-only telecommunications; and/or
• modifier FR to indicate a supervising practitioner was present through a real-time two-way, audio and video communication technology.

Rates of payment for services delivered via telehealth will be the same as the rates of payment for services delivered via traditional (i.e., in-person) methods as set forth in the applicable regulations.

Providers may not bill MassHealth a facility claim for originating sites.

SOURCE: MassHealth All Provider Bulletin 379, Oct. 2023. (Accessed Apr. 2025).

See: MA Medicaid Live Video Distant Site

Clinics are also permitted to submit for reimbursement telemedicine services (using simultaneous audio/visual technologies) per bulletin MSA 20-09 if all other provisions of telemedicine policy are maintained. Simultaneous audio/visual telemedicine services, as indicated by CPT/HCPCS codes listed on the telemedicine fee schedule and considered qualifying visits, will also be considered face-to-face and will trigger the PPS/AIR if the service billed is listed as a qualifying visit.

Center (THC)/ Tribal Federally Qualified Health Centers (Tribal FQHC) Considerations – PT, OT and ST, when provided in accordance with this policy using both audio/visual modalities, will be considered face-to-face and will trigger the PPS AIR if the service billed is listed as a qualifying visit.

For FQHCs, RHCs, THCs and Tribal FQHCs, the appropriate CPT/HCPCS code, PPS/AIR payment code (if the service generates a Qualifying Visit), and modifier 95 – synchronous telemedicine must be used. Refer to www.michigan.gov/medicaidproviders >> Provider Specific Information for additional information.

SOURCE:  MI Dept. of Health and Human Services., Bulletin 23-10, Telemedicine Policy Post-COVID PHE, Mar. 2, 2023, (Accessed Apr. 2025).

Claims for telemedicine services must be submitted using the ASC X 12N 837 5010 form using the appropriate telemedicine HCPCS or CPT code. All telemedicine claims must include the corresponding modifier 95- “Synchronous Telemedicine Service rendered via a real-time interactive audio and video telecommunications system” or 93 – “Synchronous Telemedicine Service rendered via telephone or other real-time interactive audio-only telecommunications system” and the appropriate revenue code.

Distant site services provided by qualified Medicaid enrolled providers may be covered when the qualified provider is employed by the clinic or working under the terms of a contractual agreement with the clinic. FQHCs and RHCs must maintain all practitioner contracts and provide them to MDHHS upon request.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2211, Apr. 1, 2025  (Accessed Apr. 2025).

When the outpatient facility provides administrative support for a telemedicine service, the outpatient hospital facility may bill the hospital outpatient clinic visit on the institutional claim with modifier 95 or modifier 93 and the appropriate revenue code.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2207, Apr. 1, 2025, (Accessed Apr. 2025).

A Tribal facility may choose to enroll as a Tribal FQHC and be reimbursed for outpatient face-to-face visits within the FQHC scope of services provided to Medicaid beneficiaries, including telemedicine and services provided by contracted employees. Tribal FQHCs are eligible to receive the IHS outpatient AIR for eligible encounters.

A THC can be either an originating or distant site for telemedicine services.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2253 & 2257, Apr. 1, 2025, (Accessed Apr. 2025).

An FQHC can be either an originating or distant site for telemedicine services.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 801, Apr. 1, 2025, (Accessed Apr. 2025).

See: MI Medicaid Live Video Distant Site

Face-to-face includes telehealth services provided by an eligible provider.

SOURCE: MN Dept of Human Services, Federally Qualified Health Center and Rural Health Clinic, Mar. 18, 2024, (Accessed Jun. 2025).

Telehealth visits provided through audio and visual communication or accessible video-based platforms may be used to satisfy the face-to-face requirement for reimbursement under the payment methods that apply to a federally qualified health center, rural health clinic, Indian health service, 638 tribal clinic, and certified community behavioral health clinic, if the service would have otherwise qualified for payment if performed in person.

SOURCE: MN Statute Sec. 256B.0625, Subd. 3b(d). (Accessed Jun. 2025).

An encounter for face-to-face telehealth services provided by the FQHC acting as a distant site provider. MS Medicaid reimburses a FQHC for both the distant and originating provider site when such services are appropriately provided by the FQHC.

SOURCE: MS Admin. Code Title 23, Part 211, Rule. 1.5. (Accessed Apr. 2025).

Providers delivering simultaneous distant and originating site services to a beneficiary are reimbursed: …

• Either the originating or distant site facility fees, not both, except for RHC, FQHC and CMHC when such services are appropriately provided by the same organization.

SOURCE: MS Admin. Code Title 23, Part 225, Rule. 1.5 (Accessed Apr. 2025).

See: MS Medicaid Live Video Distant Site

FQHC Cost Report

• The telemedicine charges and costs, including the depreciation cost for equipment, are not allowed on the FQHC cost report.
• FQHC providers must remove charges and payments for telemedicine services from their year-end cost reports.

See document for billing scenarios.

SOURCE: MO HealthNet Telemedicine Billing Presentation, (Accessed Apr. 2025).

See:  MO Medicaid Live Video Distant Site

No direct reference to whether or not FQHCs can be eligible distant site providers.

See: MT Medicaid Live Video Eligible Providers

Payment for telehealth services will be the Medicaid rate for the comparable in-person service. FQHC core services provided via telehealth technologies are not covered under the encounter rate.

SOURCE: NE Admin. Code Title 471, Sec. 29-004.05, Ch. 29. (Accessed Apr. 2025).

See: NE Medicaid Live Video Distant Site

See: NV Medicaid Live Video Eligible Providers

Not listed as eligible distant site, however there is no restriction on eligible distant sites according to statute.

SOURCE: NH Revised Statutes 167:4-d (Accessed Jul. 2025).

See: NH Medicaid Live Video Distant Site

For the provision of services, providers are expected to follow the same rules they would follow if the patient visit was face-to-face. This includes instances when a license is for an entity such as an independent clinic (which includes FQHC). This license is for a specific address and is not tied to specific personnel. In this instance, the service may only be billed when provided at the address listed on the license. When billed by the clinic, the service provider (for example a physician) may provide services from a remote location but the patient must receive those services while physically present at the independent clinic (licensed location). Independent practitioners have a person specific license that is not tied to a specific address. Services billed by independent practitioners do not have location restrictions. The patient and/or the provider may be at any location as long as the provider is licensed to practice in New Jersey.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter Vol. 28, No. 17, Sept. 2018, p. 2 (Accessed May 2025).

Teledentistry (D9995) can only be billed in conjunction with CDT code D0140 – limited oral evaluation – problem focused. For Federally Qualified Health Centers – the encounter code (D0120 with modifier 22), along with D9995 and D0140, must be billed for the same date with all services submitted on the same claim.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter Vol. 33, No. 13, Aug. 2023, p. 3. (Accessed May 2025).

See: NJ Medicaid Live Video Distant Site

No reference found.

See:  NM Medicaid Live Video Distant Sites

Any secure site within the fifty United States (U.S.) or U.S. territories, is eligible to be a distant site for delivery and payment purposes, including Federally Qualified Health Centers (FQHCs) and providers homes, for NYS Medicaid-enrolled patients. To receive reimbursement from NYS Medicaid, providers submitting telehealth claims or encounters must be NYS-licensed and enrolled in NYS Medicaid.

SOURCE: NY Dept. of Health, Medicaid Update, Vol. 39, Number 3, February 2023, p. 4. (Accessed Mar. 2024).

The distant site is the location from which the provider furnishes telehealth, virtual communications, or remote patient monitoring services. There are no restrictions on distant sites. Distant sites may be wherever the provider may be located. Provider(s) shall ensure that beneficiary privacy is protected (such as taking calls from private, secure spaces; using headsets). Federally Qualified Health Centers (FQHCs), FQHC Look-Alikes and Rural Health Centers (RHCs) are considered eligible distant sites and shall follow the coding and billing guidelines in Attachment A below.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1H, Telehealth, Virtual Communications and Remote Patient Monitoring, Feb. 15, 2025. (Accessed Jun. 2025).

Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs) may bill for telehealth, virtual communication, and remote patient monitoring services if the service follows core service billing requirements as outlined in clinical coverage policy 1D-4, Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1H, Telehealth, Virtual Communications and Remote Patient Monitoring, Attachment A, Feb. 15, 2025. (Accessed Jun. 2025).

FQHCs/RHCs

Eligible providers include all core service providers as defined in Section 3.2.1 of the FQHC/RHC clinical policy, which includes physicians, physician assistants, nurse practitioners, nurse midwives, clinical psychologists, clinical social workers, licensed psychological associates, licensed clinical mental health counselors, licensed marriage and family therapists, advance practice nurse specialists, clinical nurse specialists, and licensed clinical addiction specialists.

Core Visit Services: Federally Qualified Health Center (FQHC) and Rural Health Clinic (RHC) core service providers may deliver core services via telehealth if the service is:

• Defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics; and,
• Covered as a telehealth-eligible core visit service in Attachment A, Section C.1 of this policy.

Non-Core Visit Services: FQHCs and RHCs may also deliver a select set of services via telehealth, virtual patient communications, and remote patient monitoring that are not
defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics. FQHCs and RHCs would be reimbursed on a fee-for-service basis for delivering non-core visit services via telehealth, virtual patient communications, or remote patient monitoring. See Attachment A, Section C.1 of this policy for further guidance for billing virtual patient communications and remote patient monitoring codes.

In addition, FQHC and RHC core service providers may conduct telehealth visits with a supporting home visit by a delegated staff member (“hybrid model”) with new or established patients and bill using HCPCS code T1015 (or T1015-HI, T1015-SC), for a range of scenarios including (but not limited to) chronic disease management and perinatal visits.

Use modifier SC to bill non–behavioral health visits that occur after the first encounter in which the beneficiary appears with, presents with, or suffers illness or injury requiring additional diagnosis or treatment.

Please refer to Clinical Coverage Policy 1-H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring for a list of other related clinical coverage policies that include telehealth, virtual patient communications and remote patient monitoring-eligible non-core visit services that may be delivered by eligible providers at an FQHC or RHC.

Core Services: Core visit services delivered via telehealth are billed under the FQHC and RHC provider number using the HCPCS code T1015 (clinic visit/encounter, all-inclusive), T1015-HI (for behavioral health services), or T1015-SC (subsequent sick visit) and appended with the GT modifier. Eligible providers include all core service providers as defined in Section 3.2.1 of this policy, which includes physicians, physician assistants, nurse practitioners, nurse midwives, clinical psychologists, clinical social workers, licensed psychological associates, licensed clinical mental health counselors, licensed marriage and family therapists, advance practice nurse specialists, clinical nurse specialists, and licensed clinical addiction specialists.

Hybrid Telehealth with Supporting Home Visit: In addition, FQHC and RHC core service providers may conduct telehealth visits with a supporting home visit by a delegated staff member (“hybrid model”) with new or established patients and bill using HCPCS code T1015 (or T1015-HI, T1015-SC), for a range of scenarios including (but not limited to) chronic disease management and perinatal visits.  See manual for additional guidance.

Telehealth Claims: Modifier GT must be appended to the CPT or HCPCS code to indicate that a service has been provided via interactive audio-visual communication. This modifier is not appropriate should not be used for virtual patient communications (including telephonic evaluation and management services) or remote patient monitoring.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1D-4, Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics, Aug. 15, 2023. (Accessed Jun. 2025).

See: NC Medicaid Live Video Eligible Providers

Payment to FQHCs for covered services furnished to members is made by means of an all-inclusive rate for each encounter. FQHCs may furnish services that qualify as a medical, dental, or behavior health encounter. Each encounter includes services and supplies incident to the service.

SOURCE: ND Div. of Medical Assistance, Federally Qualified Health Center, (Aug. 2024), (Accessed Jun. 2025).

When providing telehealth services to patients located in their homes or another facility, FQHCs and RHCs should continue to bill the revenue codes listed in the FQHC and RHC portions of this manual along with the CPT® or HCPCS code for the service rendered appended with modifier GT or 95.

Refer to the FQHC and RHC policies for the revenue codes to bill for the various services.

SOURCE: ND Div. of Medical Assistance, Telehealth, (May 2025), (Accessed Jun. 2025).

FQHCs and RHCs – Dentistry

When providing teledentistry services to patients located in their homes or another facility, FQHCs and RHCs should continue to bill the revenue code listed below along with the CDT© code for the service rendered appended with modifier GT or 95.

Revenue Code 512: Dental Clinic.

One dental encounter is allowed per day. The encounter must be a face to face encounter to qualify for payment. Asynchronous teledentistry performed as a stand-alone service does not qualify for an encounter payment. At least one covered service must be performed as a face to face service to qualify for the dental encounter payment.

Refer to the FQHC and RHC portions of this manual for the revenue codes to bill for the various services.

SOURCE: North Dakota Human Services Dental Manual, Teledentistry, pg. 11-12(Jul. 2024), (Accessed Jun. 2025).

See: ND Medicaid Live Video Eligible Providers

Clinic Services

Telehealth and audio-only health service delivery requires either the provider or the member to be located at the freestanding clinic that is providing services pursuant to 42 Code of Federal Regulations (CFR) § 440.90. Refer to section Oklahoma Administrative Code (OAC) 317:30-3-27 for telehealth policy and OAC 317:30-3-27.1 for audio-only telecommunication policy.

SOURCE: OK Admin Code Sec. 317.30-5-575, (Accessed Jun. 2025).

See: OK Medicaid Live Video Distant Site

OR Medicaid requires providers to be enrolled and meet certain requirements.  They also state that the distant site can be any location in which appropriate privacy and confidentiality is ensured, however no explicit reference is made to FQHCs.

See: OR Medicaid Live Video Distant Site

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health  Clinics”(https://www.dhs.pa.gov/providers/QuickTips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Apr. 2025).

Telemedicine encounters must be provided according to the same standard of care as if delivered in-person. FQHCs/RHCs providing physical health services are to refer to MA Bulletin 99-23-08, titled “Updates to Guidelines for the Delivery of Physical Health Services via Telehealth,” or the current MA Bulletin or Department guidance, for more information. (https://www.dhs.pa.gov/docs/Publications/Documents/FORMS%20AND%20PUBS%20OMAP/MAB2023080201.pdf).

Telehealth encounters must be provided according to the same standard of care as if delivered in-person. FQHCs/RHCs providing behavioral health services licensed by OMHSAS are to refer to OMHSAS Bulletin OMHSAS-22-02, titled “Revised Guidelines for the Delivery of Behavioral Health Services Through Telehealth,” or the current OMHSAS Bulletin or Department guidance, for more information (https://www.dhs.pa.gov/docs/Documents/OMHSAS/Bulletin%20OMHSAS-22-02%20­%20Revised%20Guidelines%20for%20Delivery%20of%20BH%20Services%20Through%20Telehealth%207.1.22.pdf)

Some dental services can be provided using teledentistry. FQHCs/RHCs are to refer to MA Bulletin 08-22-13, titled “Teledentistry Guidelines and Dental Fee Schedule Updates,” or the current MA Bulletin, for more information (https://www.dhs.pa.gov/docs/Publications/Documents/FORMS%20AND%20PUBS%20OMAP/MAB2022061301.pdf).

SOURCE:  PA Department of Human Services, Medical Assistance Bulletin, Updates to The PROMISe™ Provider Handbook 837 Professional/CMS-1500 Claim Form, Appendix E – FQHC/RHC Handbook, Nov. 1, 2024, Number 08-24-16, (Accessed Apr. 2025).

I work as a licensed professional at a Federally Qualified Health Center (FQHC). Will I be able to bill for services delivered via telemedicine after October 31, 2022?

Yes, as clarified in MA Bulletin 99-23-08, telemedicine remains a mode of service delivery that providers can utilize. Providers that are licensed by the Office of Mental Health and Substance Abuse Services should refer to bulletin OMHSAS-22-02 – Revised Guidelines for Delivery of BH Services Through Telehealth 7.1.22.pdf (pa.gov) when rendering the behavioral health services for which they are licensed. In addition, DHS recently issued MA Bulletin 08-22-13, 27-22-07 related to tele dentistry services that is also relevant to FQHC providers that offer dental services.

SOURCE: PA Department of State, Frequently asked Questions About Telemedicine in Pennsylvania, (Accessed Apr. 2025).

See: PA Medicaid Live Video Distant Site

No reference found.

An encounter must include a face-to-face or telemedicine (telephone-only and tele video services) visit with a physician (including optometrists and psychiatrists), physician assistant, nurse practitioner (advanced practice registered nurses), clinical social worker, clinical psychologist, certified nurse midwife, clinical nurse specialist, licensed mental health counselor, licensed marriage and family therapist, dentist or registered dental hygienist.

SOURCE:  RI Executive Office of Health and Human Services, Principles of Reimbursement for FQHCs, Aug. 2022, pg. 5-6, (Accessed May 2025).

Law requires that all medically necessary and clinically appropriate telemedicine services delivered by in-network primary care providers, registered dietitian nutritionists and behavioral health providers be reimbursed at a rate not lower than services provided in-person. No explicit reference is made to FQHCs.

See: RI Medicaid Live Video Eligible Providers

Federally Qualified Health Centers (FQHC) and Rural Health Centers (RHC) will continue to be eligible for reimbursement for services rendered via telehealth. When billing for any telehealth procedure code, providers must submit claims with a GT modifier. If a code requires any other billing modifiers when submitting claims, the GT modifier should be listed after any other modifiers.

SOURCE: SC Dept. of Health and Human Services. Medicaid Bulletin 23-018. (May 2023). (Accessed Jun. 2025).

FQHC services are allowed to be performed in the following settings: …

• Telehealth or Telehealth at Home

Modifier GT is required for all services provided via telehealth and must be recorded secondary to any other applicable modifiers.

FQHCs may operate as the consulting site. If the visit is done via telehealth FQHCs must bill the appropriate procedure code for the service along with the “GT” modifier (via interactive audio and video telecommunications system) indicating interactive communication was used.

SOURCE: SC Health and Human Svcs. Dept. FQHC Services Provider Manual (Apr. 2025), p. 14-15, 23. (Accessed Jun. 2025).

FQHC/RHCs are eligible to serve as an originating site for telemedicine services and may also provide distant site telemedicine services. An originating site is the physical location of the Medicaid recipient at the time the service is provided. A distant site is the physical location of the practitioner providing the service via telemedicine. Please refer to the Telemedicine manual for additional information.

SOURCE: SD Medicaid Billing and Policy Manual, FQHC and RHC Services, Jun. 2024, (Accessed Apr. 2025).

The following providers can provide services via telemedicine at a distant site:

• Federally Qualified Health Center (FQHC)

FQHC/RHC providers may bill for these services on a fee for service basis using their non-Prospective Payment System (PPS) NPI if the service is ordered by one of the allowable practitioner types.

Providers must bill for services at their usual and customary charge. Providers are reimbursed the lesser of their usual and customary charge or the fee schedule rate. Reimbursement for distant site telemedicine services is limited to the individual practitioner’s professional fees or the encounter rate if the service qualifies as an FQHC/RHC or IHS/Tribal 638 clinic service. The maximum allowable reimbursement for distant site services is listed on the applicable fee schedule. The maximum allowable amount for services provided via telemedicine is the same as services provided in-person. Facility related charges for distant site telemedicine providers are not reimbursable.

SOURCE: SD Medicaid Billing and Policy Manual: Telemedicine, p. 3 (Feb. 2025), (Accessed Apr. 2025),

See: SD Medicaid Live Video Distant Site

A provider-based telemedicine provider who seeks to contract with or who has contracted with a health insurance entity to participate in the health insurance entity’s network is subject to the same requirements and contractual terms as any other healthcare services provider in the health insurance entity’s network.

SOURCE:  TN Code Annotated, Sec. 56-7-1003, (Accessed Apr. 2025).

A telehealth provider who seeks to contract with or who has contracted with a health insurance entity to participate in the health insurance entity’s network shall be subject to the same requirements and contractual terms as a healthcare services provider in the health insurance entity’s network.

SOURCE:  TN Code Annotated, Sec. 56-7-1002, (Accessed Apr. 2025).

“Healthcare services provider” means an individual acting within the scope of a valid license issued pursuant to title 63 or any state-contracted crisis service provider employed by a facility licensed under title 33

SOURCE:  TN Code Annotated, Sec. 56-7-1002 & 1003, [slight variation exists] (Accessed Apr. 2025).

See: TN Medicaid Live Video Distant Site

See: TX Medicaid Live Video Distant Site

Not mentioned explicitly, however state does not have a specific provider list.

See: UT Medicaid Live Video Eligible Providers

A distant site is defined broadly to mean the location of a health care provider delivering services through telemedicine at the time the services are provided. However, there is no explicit reference to FQHCs.

See: VT Medicaid Live Video Eligible Providers.

No reference found.

Telehealth services may be included in a Federally Qualified Health Center (FQHC), Rural Health Clinic (RHC), or Indian Health Center (IHC) scope of practice, as approved by HRSA and the Commonwealth. If approved, these facilities may serve as the Provider or originating site and bill under the encounter rate. The encounter rate methodology for FQHCs and RHCs is described in 12VAC30-80-25; the encounter rate for IHCs (including Tribal clinics) is the All Inclusive Rate set by Indian Health Services.

SOURCE:  VA Dept. of Medical Assistance Svcs., Medicaid Provider Manual Supplement-Telehealth Services, (5/13/24) (Accessed Apr. 2025).

See: VA Medicaid Live Video Distant Site

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FQHCs may now serve as a distant site for Telehealth consultations by a psychiatrist or psychologist only and be reimbursed at the encounter rate. The distant-site practitioner must bill the appropriate Current Procedural Technology/Healthcare Common Procedure Coding System (CPT/HCPCS) code with the appropriate Place of Service on a HCFA1500 form.

SOURCE: WV Dept. of Health and Human Svcs. Medicaid Provider Manual. Chapter 522.8 Federally Qualified Health Center and Rural Health Clinic Svcs. P. 9. (July 1, 2019); WV Dept. of Health and Human Svcs. Medicaid Provider Manual, Chapter–519.17 Practitioner Services: Telehealth Services., p. 3 (Effective Jan. 1, 2022). (Accessed May 2025).

See: WI Medicaid Live Video Distant Site

Not explicitly listed on eligible provider list.

“Visit” means a face-to-face encounter between a FQHC or RHC client and a FQHC or RHC professional staff member for the purpose of providing FQHC or RHC services.  Telehealth visits are considered face-to-face visits.

SOURCE: WY Admin Rules. Department of Health, (Title 48). Medicaid Program 37, Ch. 37 Sec. 3. (Accessed May 2025).

See: WY Medicaid Live Video Eligible Providers