Live Video
CY 2024 Physician Fee Schedule notes that section 4113 of Division FF, Title IV, Subtitle A of the Consolidated Appropriations Act, 2023 (CAA, 2023) (Pub. L. 117-328, December 29, 2022) extends the telehealth policies enacted in the Consolidated Appropriations Act, 2022 (CAA, 2022) (Pub. L. 117-103, March 15, 2022) through December 31, 2024, if the PHE ends prior to that date, as discussed in section II.D.c. of this final rule. These provisions included:
…
- Temporarily allowing a more expansive list of eligible providers in Medicare to provide services via telehealth such as physical and occupational therapists and federally qualified health centers (FQHCs) and rural health clinics (RHCs)
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Jul. 2025).
Temporary Policy – Ends Sept. 30, 2025
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).
Mental Health Visit – Delayed to Oct. 1, 2025
A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
Beginning January 1, 2026, there must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.
RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audio-only communication.
Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.
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.
Note: Beginning January 1, 2024, group therapy with physicians or psychologists or other mental health professionals to the extent authorized under State law may be covered and paid under the IOP benefit (see section 250 of this chapter).
A mental health service should be reported using a valid HCPCS code for the service furnished, a mental health revenue code, and for FQHCs, an appropriate FQHC mental health payment code. For detailed information on reporting mental health services and claims processing, see Pub. 100-04, Medicare Claims Processing Manual, chapter 9, http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/clm104c09.pdf
Medication management, or a psychotherapy “add on” service, is not a separately billable service in an RHC or FQHC and is included in the payment of an RHC or
FQHC medical visit. For example, when a medically-necessary medical visit with an RHC or FQHC practitioner is furnished, and on the same day medication management or a psychotherapy add on service is also furnished by the same or a different RHC or FQHC practitioner, only one payment is made for the qualifying medical services reported with a medical revenue code. For FQHCs, an FQHC mental health payment code is not required for reporting medication management or a psychotherapy add on service furnished on the same day as a medical service.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 4/21/25, pg. 42-43 (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, 4/21/25, pg. 46-47, (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 and non-mental telehealth services through September 30, 2025, using the national average payment rates for comparable services under the Physician Fee Schedule (PFS) through December 31, 2025
- 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 behavioral and 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).
RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. You may use audio-only technology in situations when your patient can’t access or doesn’t consent to use audio-video technology. You can report and get paid in the same way as in-person visits.
- Audio-video visits: Use modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System).
- Audio-only visits: Use new service-level modifier FQ or 93.
These in-person visit requirements apply only to a patient getting mental health visits via telecommunications at home:
- There must be an in-person mental health visit 6 months before the telecommunications visit
- In general, there must be an in-person mental health visit at least every 12 months while the patient is getting services from you via telecommunications to diagnose, evaluate, or treat mental health disorders
NOTE: Section 4113 of the Consolidated Appropriations Act (CAA), 2023, delayed the in-person visit requirements under Medicare for mental health visits that RHCs and FQHCs provide via telecommunications technology. For RHCs and FQHCs, we won’t require in-person visits until January 1, 2025.
CMS will allow for limited exceptions to the requirement for an in-person visit every 12 months based on patient circumstances in which the risks and burdens of an in-person visit may outweigh the benefit. These include, but aren’t limited to, when:
- An in-person visit is likely to cause disruption in service delivery or has the potential to worsen the patient’s condition
- The patient getting services is in partial or full remission and only needs maintenance level care
- The clinician’s professional judgment says that the patient is clinically stable and that an in-person visit has the risk of worsening the patient’s condition, creating undue hardship on self or family
- The patient is at risk of withdrawing from care that’s been effective in managing the illness
With proper documentation, the in-person visit requirement isn’t applicable for that 12-month period. You must document the circumstance in the patient’s medical record.
SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Jul. 2025).
Through September 30, 2025:
- Medicare patients can get non-behavioral and non-mental telehealth services in their home
- You can deliver non-behavioral and non-mental telehealth services using audio-only communication platforms
You may continue to bill for telehealth services using HCPCS code G2025. We’ll base the payment amount on the average amount for all Medicare telehealth services paid under the PFS, weighted by volume through December 31, 2025.
You may use 2-way, interactive, audio-only technology for any telehealth visits if the distant site provider is technically capable of using an audio-video telehealth system, but the patient isn’t capable of, or doesn’t consent to, using video technology. You don’t need any additional documentation except to append the FQ modifier on the claim.
We pay for mental health visits using telehealth in the same way as face-to-face services. The changes also allow you to use audio-only telehealth in cases where patients can’t, or don’t consent to, using audio-video telehealth. You can report and get paid in the same way as in-person visits.
SOURCE: Centers for Medicaid and Medicare Services, Medicare Learning Network Booklet 6397, Federally Qualified Health Centers, Apr. 2025, & MLN Booklet 6398, Rural Health Clinics, Apr. 2025, (Accessed Jul. 2025).
We may cover these behavioral health and wellness services:
- Depression screening through telehealth
- Digital mental health treatment (DMHT) devices provided “incident to” professional behavioral health services used along with ongoing treatment under a behavioral health treatment plan or therapy plan of care.
- The billing practitioner must prescribe or order the DMHT device that’s been cleared under section 510(k) of the Food, Drug, and Cosmetics Act
- The patient can use the DMHT device at home or in an outpatient setting, if that’s how FDA classified the device for use under 21 CFR 882.5801
- Telehealth, defined as 2-way, interactive, audio-video technology, to diagnose, evaluate, or treat certain mental health or SUDs if the patient is in their home. Practitioners must be able to provide 2-way, real-time, audio-video technology services but may use audio-only technology given an individual patient’s technological limitations, abilities, or preferences. We cover telehealth for behavioral and mental health on a permanent basis.
Starting October 1, 2025, in-person visit requirements will apply for mental health services provided by telehealth. This includes a required in-person visit within the 6 months before the initial telehealth treatment, as well as the required subsequent in-person visits at least every 12 months.
Telehealth also applies to mental health services provided by Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs). For RHCs and FQHCs, we don’t require the in-person visit for mental health services provided through telehealth to patients in their homes until January 1, 2026.
The regulations at 42 CFR 410.78(b)(3)(xiv) describe 2 exceptions to the in-person requirements that take effect on October 1, 2025:
- Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate
- Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability.
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, Apr. 2025, (Accessed Jul. 2025).
Supervision
CMS will continue to allow use of video to meet direct supervision requirements in specific cases:
…
- Continue to allow the current flexibility for federally qualified health centers (FQHCs) and Rural Health Clinics (RHCs) to use live video to meet the “immediately available” requirement for direct supervision to December 31, 2025.
SOURCE: Center for Medicare and Medicaid Services, CY 2025 Physician Fee Schedule, Final Rule, CMS 1807-F and 4201-F5, (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
Store and Forward
General Care Management Services (which includes store-and-forward elements) include: Chronic Care Management (CCM), Principal Care Management (PCM), Chronic Pain Management (CPM), General Behavioral Health Integration (BHI) services, Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), Community Health Integration (CHI), Principal Illness Navigation (PIN), PIN Peer-Support (PIN-PS) and Advanced Primary Care
Management. See manual for details.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 4/21/25, pg. 56-69, (Accessed Jul. 2025).
Also see Virtual Communications section below.
See: Federal Medicare Store-and-forward
Remote Patient Monitoring
Services such as RPM are not separately billable because they are already included in the RHC AIR or FQHC PPS payment.
SOURCE: CY 2020 Final Physician Fee Schedule. CMS, p. 432, (Accessed Jul. 2025).
FQHCs can also be reimbursed for chronic care management, which can include elements of RPM.
SOURCE: Centers for Medicare and Medicaid Services, Care Management in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), Frequently Asked Questions, Dec. 2019, (Accessed Jul. 2025).
General Care Management Services include: Chronic Care Management (CCM), Principal Care Management (PCM), Chronic Pain Management (CPM), General Behavioral Health Integration (BHI) services, Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), Community Health Integration (CHI), Principal Illness Navigation (PIN), PIN Peer-Support (PIN-PS) and Advanced Primary Care
Management. See manual for details.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 4/21/25, pg. 56-69, (Accessed Jul. 2025).
CMS will include the CPT codes related to RPM and RTM in the general care management code HCPCS G0511 which will provide FQHCs/RHCs payment for RTM and RPM services. CMS noted that these services are similar to the nonface-to-face requirements for general care management services and reflect the additional resources needed to provide such services by an FQHC/RHC.
SOURCE: Center for Medicare and Medicaid Services, CY 2024 Physician Fee Schedule, Final Rule, CMS 1784-F, (Accessed Jul. 2025).
FQHCs/RHCs provide:
- Certain care coordination services like transitional care management (TCM), chronic care management (CCM), advanced primary care management (APCM), general behavioral health integration (BHI), principal care management (PCM), chronic pain management (CPM), psychiatric collaborative care model (CoCM) services, remote physiologic monitoring (RPM), remote therapeutic monitoring (RTM), community health integration (CHI), principal illness navigation (PIN), and PIN-Peer Support (PIN-PS).
SOURCE: Centers for Medicaid and Medicare Services, Medicare Learning Network Booklet 6397, Federally Qualified Health Centers, Apr. 2025, & MLN Booklet 6398, Rural Health Clinics, Mar. 2024, (Accessed Jul. 2025).
See: Federal Medicare Remote Patient Monitoring
Audio-Only
Temporary Policy – Ends Sept. 30, 2025
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).
Mental Health Visit – Delayed to Oct. 1, 2025
A mental health visit is a medically-necessary face-to-face encounter between an RHC or FQHC patient and an RHC or FQHC practitioner during which time one or more RHC or FQHC mental health services are rendered. Effective January 1, 2022, a mental health visit is a face-to-face encounter or an encounter furnished using interactive, real-time, audio and video telecommunications technology or audio-only interactions in cases where the patient is not capable of, or does not consent to, the use of video technology for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
Beginning January 1, 2026, there must be an in-person mental health service furnished within 6 months prior to the furnishing of the mental health service furnished via telecommunications and that an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders, unless, for a particular 12-month period, the physician or practitioner and patient agree that the risks and burdens outweigh the benefits associated with furnishing the in-person item or service, and the practitioner documents the reasons for this decision in the patient’s medical record.
RHCs and FQHCs are instructed to append modifier 95 (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) in instances where the mental health visit was furnished using audio-video communication technology and to append modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) in cases where the service was furnished using audioonly communication.
Mental health services that qualify as stand-alone billable visits in an FQHC are listed on the FQHC center website, http://www.cms.gov/Center/Provider-Type/FederallyQualified-Health-Centers-FQHC- Center.html. Services furnished must be within the practitioner’s state scope of practice.
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, 4/21/25, pg. 42-43, (Accessed Jul. 2025).
We may cover these behavioral health and wellness services:
- Depression screening through telehealth
- Digital mental health treatment (DMHT) devices provided “incident to” professional behavioral health services used along with ongoing treatment under a behavioral health treatment plan or therapy plan of care.
- The billing practitioner must prescribe or order the DMHT device that’s been cleared under section 510(k) of the Food, Drug, and Cosmetics Act
- The patient can use the DMHT device at home or in an outpatient setting, if that’s how FDA classified the device for use under 21 CFR 882.5801
- Telehealth, defined as 2-way, interactive, audio-video technology, to diagnose, evaluate, or treat certain mental health or SUDs if the patient is in their home. Practitioners must be able to provide 2-way, real-time, audio-video technology services but may use audio-only technology given an individual patient’s technological limitations, abilities, or preferences. We cover telehealth for behavioral and mental health on a permanent basis.
Starting October 1, 2025, in-person visit requirements will apply for mental health services provided by telehealth. This includes a required in-person visit within the 6 months before the initial telehealth treatment, as well as the required subsequent in-person visits at least every 12 months.
Telehealth also applies to mental health services provided by Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs). For RHCs and FQHCs, we don’t require the in-person visit for mental health services provided through telehealth to patients in their homes until January 1, 2026.
The regulations at 42 CFR 410.78(b)(3)(xiv) describe 2 exceptions to the in-person requirements that take effect on October 1, 2025:
- Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate
- Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability.
The telehealth policies described above also apply to Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
SOURCE: Centers for Medicare and Medicaid Services, Medicare Learning Network Booklet 1986542, Medicare & Mental Health Coverage, Apr. 2025, (Accessed Jul. 2025).
RHCs and FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. Use audio-only technology in situations when the patient can’t access or doesn’t consent to use audio-video technology. They can report and get paid in the same way as in-person visits.
Audio-only visits: Use new service-level modifier FQ or 93.
SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Jul. 2025).
Through September 30, 2025:
- Medicare patients can get non-behavioral and non-mental telehealth services in their home
- You can deliver non-behavioral and non-mental telehealth services using audio-only communication platforms
You may use 2-way, interactive, audio-only technology for any telehealth visits if the distant site provider is technically capable of using an audio-video telehealth system, but the patient isn’t capable of, or doesn’t consent to, using video technology. You don’t need any additional documentation except to append the FQ modifier on the claim.
We pay for mental health visits using telehealth in the same way as face-to-face services. The changes also allow you to use audio-only telehealth in cases where patients can’t, or don’t consent to, using audio-video telehealth. You can report and get paid in the same way as in-person visits.
Revenue code 0900, use FQ or 93 for audio only moidifiers.
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. 2025).
Mental health visit includes audio-only interaction in cases where beneficiaries are not capable of, or do not consent to, the use of devices that permit a two-way, audio/video interaction for the purposes of diagnosis, evaluation or treatment of a mental health disorder.
RHCs and FQHCs can report and be paid for furnishing those visits in the same way they currently do when these services are furnished in-person. RHCs and FQHCs will be paid for mental health visits furnished via telecommunications technology at the same rate they are paid for in-person mental health visits (that is, the AIR or FQHC PPS).
There must be an in-person mental health service furnished within 6 months prior to the furnishing of the telecommunications service and that in general, there must be an in-person mental health service (without the use of telecommunications technology) must be provided at least every 12 months while the beneficiary is receiving services furnished via telecommunications technology for diagnosis, evaluation, or treatment of mental health disorders. This applies only to patients receiving services at home. If the patient and practitioner consider the risks and burdens of an in-person service and agree that, on balance, these outweigh the benefits, and the practitioner documents the basis for that decision in the patient’s medical record, then the in-person visit requirement is not applicable for that 12-month period.
In person requirement delayed under Medicare until on or after January 1, 2025.
SOURCE: CY 2022 Physician Fee Schedule, CMS, p. 214-215 & delay in implementation in HR 2617 (2022 Session). (Accessed Jul. 2025).
Virtual Communications
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes communication technology-based services (may include audio-only/telephone) to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, & Virtual Communication Services RHCs and FQHCs FAQs, December 2018, (Accessed Jul. 2025).
General Care Management Services include: Chronic Care Management (CCM), Principal Care Management (PCM), Chronic Pain Management (CPM), General Behavioral Health Integration (BHI) services, Remote Patient Monitoring (RPM), Remote Therapeutic Monitoring (RTM), Community Health Integration (CHI), Principal Illness Navigation (PIN), PIN Peer-Support (PIN-PS) and Advanced Primary Care
Management. See manual for details.
SOURCE: CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, 4/21/25, pg. 56-69, (Accessed Jul. 2025).
FQHCs provide:
- Virtual communication services like communication-based technology and remote evaluation services.
You can also provide virtual communication services, which you bill differently than telehealth.
Virtual communication services are services where a practitioner meets with a patient for at least 5 minutes to decide if the patient needs a visit. The 2 ways to provide virtual communication services are:
- Through communication-based technology
- With remote evaluation services
We pay for virtual communication services when an FQHC practitioner meets certain requirements, including the:
- Practitioner provides at least 5 minutes of billable FQHC virtual communications, either through communication-based technology or remote evaluation services
- Patient had at least 1 face-to-face billable visit within the previous year
- Virtual visit isn’t related to services provided within the last 7 days
- Virtual visit doesn’t lead to an in-person FQHC service within the next 24 hours or at the next appointment
When the virtual communication HCPCS code G0071 is on an FQHC claim alone or with other payable services, we require FQHCs to submit HCPCS code G2012 (communication technologybased services) or HCPCS code G2010 (remote evaluation services).
When an FQHC practitioner provides virtual communication services, they don’t need to meet face-to-face, so the coinsurance doesn’t apply.
See Virtual Communication Services FAQs for more information.
We require patient consent for all services, including non-face-to-face services. You may get patient consent at the same time you initially provide the services. We don’t require direct supervision to get consent. In general, auxiliary personnel under general supervision of the FQHC practitioner can get patient consent for these services.
SOURCE: Centers for Medicaid and Medicare Services, Medicare Learning Network Booklet 6397, Federally Qualified Health Centers, Apr. 2025, & MLN Booklet 6398, Rural Health Clinics, Apr. 2025, (Accessed Jul. 2025).
RHCs and FQHCs are not eligible for reimbursement of interprofessional consultation services, as only practitioners that can bill Medicare independently for evaluation and management services are eligible.
SOURCE: CY 2019 Final Physician Fee Schedule. CMS, p. 31-40, (Accessed Jul. 2025).
Medicare waives the RHC and FQHC face-to-face requirements when an RHC or FQHC furnishes these services to an RHC or FQHC patient. RHCs and FQHCs receive payment for communication technology-based services or remote evaluation services when an RHC or FQHC practitioner provides at least 5 minutes of communications-based technology or remote evaluation services to a patient who has been seen in the RHC or FQHC within the previous year.
RHCs and FQHCs may only bill for these services when the medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and does not lead to an RHC or FQHC service within the next 24 hours or at the soonest available appointment, since in those situations, Medicare already pays for the services as part of the RHC or FQHC per-visit payment.
RHCs and FQHCs can bill G0511, G0512, and G0071 alone or with other payable services on an RHC or FQHC claim.
SOURCE: Medicare Learning Network Matters Factsheet, MM10843, Aug. 10, 2018, (Accessed Jul. 2025)
What are “virtual communication services” for RHCs and FQHCs?
In the 2019 Physician Fee Schedule (PFS) Final Rule, CMS finalized a policy that, effective January 1, 2019, RHCs and FQHCs can receive payment for virtual communication services when at least 5 minutes of communication technology-based or remote evaluation services are furnished by an RHC or FQHC practitioner to a patient who has had an RHC or FQHC billable visit within the previous year, and both of the following requirements are met:
- The medical discussion or remote evaluation is for a condition not related to an RHC or FQHC service provided within the previous 7 days, and
- The medical discussion or remote evaluation does not lead to an RHC or FQHC visit within the next 24 hours or at the soonest available appointment.
See FAQ for more details.
SOURCE: Virtual Communication Services RHCs and FQHCs FAQs, December 2018, (Accessed Jul. 2025).
See: Federal Medicare Email, Phone & Fax
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