Expanded Guidance from CMS for Telehealth Services Provided at Rural Health Clinics and Federally Qualified Health Centers During the COVID-19 Public Health Emergency

On April 30, 2020, CMS issued additional guidance for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) for services related to telehealth. CMS updated the transmittal as of February 23, 2021. The additional guidance recognizes that currently only services furnished during the COVID-19 Public Health Emergency (PHE) are authorized for payment to RHCs and FQHCs. If the PHE is still in effect after December 31, 2021, CMS will update the rate based on the calendar year 2022 physician fee schedule average payment, weighted by volume.

Payment Rate

As a result of expanding telehealth services, which included allowing RHCs and FQHCs to serve as distance sites for telehealth services, it became CMS’s responsibility for developing payment rates for these services. CMS set the rate for services between January 27, 2020, through December 31, 2020, at $92.03, which is based on the average reimbursement amount for all physician fee schedule (PFS) telehealth services on the telehealth list, weighted by volume for these services using the PFS. Effective January 1, 2021, the payment rate for distant site telehealth services is $99.45.

New Service

RHCs and FQHCs can furnish and bill for audio-only telephone evaluation and management services (E/M) under codes 99441, 99442, and 99443. Code specific requirements, such as time spent with the patient and duration since the last office visit or next appointment, still apply.

New Code

CMS now provides the instruction that RHCs and FQHCs should use code G2025, which is the new RHC/FQHC specific G-code for distance site telehealth services, to identify services that were furnished using telehealth beginning January 27, 2020. However, the change in eligible site locations, including the patient’s home during the COVID-19 PHE, became effective March 6, 2020.

Claims Instructions for RHCs

For telehealth distance site services provided between January 27, 2020, and June 30, 2020, RHCs need to report HCPCS code G2025 on their claims with modifier CG. Modifier 95 may also be added but is not required at the time of this release. Claims for this period will be paid at the RHC’s all-inclusive rate (AIR) and will be automatically preprocessed, beginning on July 1, 2020, at the $92.03 rate. Claims do not need to be resubmitted for the payment adjustment. Beginning July 1, 2020, RHCs should no longer use modifier CG on claims with code G2025.

Claims Instructions for FQHCs

For telehealth distance site services provided between January 27, 2020, and June 30, 2020, that are also FHQC qualifying visits, FHQCs should report three HCPCS/CPT codes.

• The FQHC Prospective Payment System (PPS) specific code (G0466, G0467, G0468, or G0470)
• The HCPCS/CPT code describing the telehealth service provided
• Code G2025 with modifier 95

These claims will be paid at the FQHC PPS rate until June 30, 2020, and automatically reprocessed, beginning July 1, 2020, at the $92.03 rate. Claims do not need to be resubmitted for the payment adjustment.For telehealth services that do not qualify as FQHC visits, the claims should be held until July 1, 2020, and then billed with code G2025.

Cost Sharing

CMS will pay all the reasonable costs for specified evaluation and management (E/M) services if the site ordered a COVID-19 test or related services. RHCs and FQHCs must waive the collection of co-insurance from beneficiaries and must include modifier CS for these claims, which will be paid with the co-insurance applied. The claims will be automatically reprocessed beginning July 1, 2020. When coinsurance is waived, it should not be collected from the beneficiary.

Protection for Exemption from the National Per Visit Payment Limit

RHCs that are provider-based to a hospital with less than 50 beds are exempt from the national per-visit payment limit for RHCs. For hospitals that may have increased bed size in response to the COVID-19 PHE, CMS will use the number of beds included in the cost reports filed by the entity before the COVID-19 PHE so hospitals are not discouraged from increasing bed capacity if needed. They will remain exempt from the national per-visit payment limit.

Key Points

• July 1, 2020, is an important date for RHCs and FQHCs providing telehealth services.
• Payment rate for RHC and FQHC telehealth services is $92.03 through December 31, 2020
• Effective January 1, 2021, the payment rate for RHC and FQHC telehealth services is $99.45
• New HCPCS code G2025 and modifiers are required when billing for telehealth services at RHCs and FQHCs.
• RHCs should only use modifier CG through June 30, 2020.
• For FQHC qualifying visits, provide the FHQC PPS code, the CPT code describing the services provided, and G2025.
• For FQHC non-qualifying visits, hold the claims until July 1, 2020, and bill with G2025.
• Coinsurance is waived and should not be collected from beneficiaries.
• Expanding bed size above 50 because of COVID-19 for provider-based RHCs will not remove the exemption from the national payment limit.

Next Steps

• Learn about the MedPAC recommendations for telehealth post-PHE
• Understand the impact of telehealth on healthcare valuation
• Submit your questions to speak with our experienced consultants

Originally published May 1, 2020. Last update June 8, 2021.