Medicare FFS Telehealth Guidance for FQHCs (Updated January 2026)

Last Updated: 1/29/26

This guidance outlines current Medicare Fee-for-Service telehealth payment and billing rules for FQHCs, including:

Medical telehealth
Behavioral health telehealth
In-person visit requirements for behavioral health telehealth

Scope: Medicare Fee-for-Service only.
Medicare Advantage, New York State Medicaid, and commercial payer telehealth policies are separate.
For New York State Medicaid, refer to the Medicaid Telehealth Policy Manual.

Medicare telehealth rules for FQHCs

Medical services provided via telehealth
How these services are paid

Billed using G2025
Paid at the fee schedule (G2025) rate
Do not pay PPS

CMS policy

CMS has stated it will continue paying FQHCs for medical telehealth services through December 31, 2026

Important operational distinction

If the underlying service is medical, it is treated as medical telehealth for payment purposes
This includes psychiatry visits billed using E and M codes
These visits roll up to G2025 and pay at the fee schedule (G2025) rate, even if the visit is behavioral health in nature

Behavioral health services provided via telehealth

How these services are paid

Paid at the PPS rate
Billed using:
- G0469 for new patient behavioral health visits
- G0470 for established patient behavioral health visits

Permanent authority

Medicare payment for behavioral health telehealth under PPS is permanent and does not require further Congressional action

Important distinction for psychiatry

Psychiatry visits billed using E and M codes are treated as medical services, not behavioral health, and therefore:
- Roll up to G2025
- Pay at the fee schedule (G2025) rate, not PPS

CMS outlines these distinctions in the FQHC PPS-specific payment codes document linked below.

Behavioral health telehealth: in-person visit requirement

Unless Congress delays it again, the in-person visit requirement for Medicare behavioral health telehealth takes effect January 31, 2026.

New behavioral health telehealth patients

An in-person visit with the same provider or a member of the same clinical team:
- Within the six months prior to starting tele-behavioral health services
- At least once every 12 months thereafter

Existing behavioral health telehealth patients

Patients who began receiving behavioral health telehealth services prior to January 31, 2026 must have:
- At least one in-person visit every 12 months after that date
Practically, this gives FQHCs until January 30, 2027 to meet the requirement

Congress has delayed these requirements in prior funding bills, so further delays remain possible.

Key resources

FAQ

Can FQHCs continue providing telehealth to Medicare Fee-for-Service patients during a federal shutdown?

Yes. There is no prohibition on providing telehealth. Payment follows the rules described above.

How are medical telehealth services paid?

Bill G2025
Paid at the fee schedule (G2025) rate
PPS does not apply

How are behavioral health telehealth services paid?

Paid at PPS
Bill G0469 for new patients or G0470 for established patients
Subject to the in-person visit requirement described above

Is audio-only behavioral health telehealth allowed?

Yes, when video is not available or feasible for the patient, as long as all Medicare requirements are met.

Why do some CMS materials reference a January 30, 2026 “sunset” if FQHCs can still bill telehealth?

Some CMS materials reference January 30, 2026 because that is the date when statutory authorization for FQHCs to serve as Medicare distant site providers for medical telehealth is scheduled to expire.

However, this does not mean payment stops on January 30, 2026.

CMS has stated in official guidance that it will continue paying FQHCs for medical telehealth services through December 31, 2026, as long as Congress has not explicitly prohibited those payments. In this situation, the statute does not prohibit telehealth; it is simply silent after January 30, 2026. CMS regulations and guidance therefore govern, and CMS has authorized continued payment.

Operationally, this means:

FQHCs may continue billing G2025 for medical telehealth services after January 30, 2026
Payment continues at the fee schedule (G2025) rate through December 31, 2026
Behavioral health telehealth under PPS is unaffected

This is why CMS materials may reference both dates and why CMS guidance, rather than the statutory sunset alone, controls billing and payment during this period.

Topics

Medicare

Current:

Medicare FFS Telehealth Guidance for FQHCs (Updated January 2026)