Medicare FFS Telehealth Guidance for FQHCs (Updated February 2026)

Last Updated: 2/19/26 (reflects extensions through 12/31/27)

This guidance explains Medicare Fee-for-Service telehealth payment and billing rules for FQHCs.

Scope: Medicare Fee-for-Service only.
Medicare Advantage, New York State Medicaid, and commercial payer telehealth policies are separate.

Telehealth Authority & Extensions

• Congress extended the statutory authority for FQHCs to furnish Medicare telehealth services through December 31, 2027.
• The Medicare behavioral health telehealth in-person visit requirement is currently delayed until January 1, 2028.

Medical Telehealth Services

How these services are paid:
• Bill HCPCS G2025 for telehealth distant site services furnished by an FQHC.
• Paid at the Medicare Physician Fee Schedule rate associated with G2025.
• These services do not pay PPS.

G2025 is a single payment code used to reimburse telehealth visits furnished via telecommunications technology by FQHCs as distant site providers under Medicare FFS.

Behavioral Health Telehealth Services

How these services are paid:
• Paid under the FQHC Prospective Payment System (PPS).
• Bill G0469 for new patient mental/behavioral health visits.
• Bill G0470 for established patient mental/behavioral health visits.

Behavioral health telehealth provided by an FQHC continues to be paid under PPS and is permanent authority and unaffected by the non-behavioral telehealth extension dates.

Behavioral Health Telehealth In-Person Requirement

• The Medicare requirement for an in-person visit before or during a course of behavioral health telehealth services has been delayed and will be effective no sooner than January 1, 2028.
• Until that date, FQHCs are not required to meet the six-month/12-month in-person visit standard for Medicare behavioral health telehealth.

Resources & Links
CMS FQHC PPS-Specific Payment Codes
CMS Medicare Telehealth FAQ