G2025 is gone for October dates of service: what FQHCs must bill instead

What changed on October 1

Since the pandemic, FQHCs and RHCs have billed every non-behavioral Medicare telehealth visit on one code, G2025, a placeholder that told Medicare a telehealth visit happened but not what it was. CMS Transmittal 13776 (Change Request 14468, issued May 27, 2026) ends that for dates of service on or after October 1, 2026. The implementation date for Medicare Administrative Contractors is October 5, 2026.

From October 1, the health center bills the individual CPT or HCPCS code that describes the service, chosen from the Medicare telehealth services list that CMS publishes with each Physician Fee Schedule rule, and adds modifier 95 for real-time audio and video or modifier 93 for audio-only. CMS states the reason plainly: it wants to see which services are being furnished, for example so a health center can show an Accountable Care Organization that it delivered certain services.

This is a coding and claims change, not a payment cut. The money still arrives as one national rate per telehealth service line. What changes is the evidence on the claim, and the edits that check it.

How the money works now

Payment for FQHC distant site telehealth is not the PPS encounter rate. Under section 1834(m)(8)(B) of the Social Security Act, CMS pays an amount similar to the national average for comparable telehealth services under the Physician Fee Schedule. For CY 2026 that rate is $97.53. For comparison, the CY 2026 FQHC PPS base payment rate for an in-person qualifying visit is $207.72 before geographic and other adjustments, so a medical telehealth visit pays less than half of the PPS base.

The transmittal lists the rules the contractor will apply to each line:

• The rate is the volume-weighted average of all Physician Fee Schedule telehealth services on the telehealth list, updated each year.
• The rate is not adjusted for geographic locality, so the FQHC geographic adjustment factor does not apply.
• FQHC beneficiary coinsurance applies, based on the lesser of the payment rate or the submitted charge, and is waived for approved preventive services.
• Units on the line are taken into account when the rate is applied, and contractors will bypass edits that would otherwise block multiple units on a modifier 93 or 95 line.
• Costs of distant site telehealth stay out of the FQHC PPS rate calculation, as the statute requires.

The edit that will bounce claims

Change Request 14468 tells the outpatient code editor to assign edit 139 on 77X and 71X bills when modifier 93 or 95 is attached to a HCPCS code that is not a distant site telehealth service code. The contractor then returns the claim to the provider. In practice that means a template that drops 95 onto a code that is not on the telehealth list, or a charge router that still adds a telehealth modifier to an in-person visit, will stop the entire claim, not just the line.

There is a second trap in the training material. The March 2026 edition of the CMS FQHC booklet, MLN006397, still says centers may continue to bill G2025. Staff who learned from that booklet, or from an older cheat sheet, will keep sending G2025 for October dates of service. Treat any G2025 line dated October 1, 2026 or later as an error to fix before the claim leaves the building.

What does not change

Mental health visits delivered by telecommunications are not part of this change. Since January 1, 2022 they count as FQHC visits paid under the PPS, and the transmittal says the new rate table does not apply to service lines with revenue code 0900. Keep billing those with the FQHC mental health payment code and the qualifying service, as today. CMS has also said the in-person mental health visit requirement for FQHC and RHC telehealth will not take effect until after January 1, 2028.

Medicare Advantage plans pay under their own contracts. This change request is an instruction to Original Medicare contractors, so check each MA plan's telehealth billing rules rather than assuming they switched on October 1. Medicaid telehealth rules are set state by state; our FQHC payer matrix tracks the published state notices.

What to do this month

• Pull every Medicare telehealth line with a date of service on or after October 1, 2026 that is still coded G2025 and recode it before submission.
• Map each telehealth visit template in the EHR to the specific CPT or HCPCS code on the CMS telehealth list, with modifier 95 or 93 driven by how the visit actually happened, not by a default.
• Add charge master entries for the telehealth codes you will now bill. FQHC charges must be uniform, so use the same charge you set for that code elsewhere.
• Confirm with your Medicare Administrative Contractor which revenue code it expects on these lines; the transmittal requires the appropriate revenue code but leaves the value to contractor instructions.
• Build a pre-bill check that stops modifier 93 or 95 on any code that is not on the telehealth list, so edit 139 never fires.
• Leave revenue code 0900 mental health telehealth lines alone, and keep them out of any bulk recode.
• Recalculate patient coinsurance on these lines from the $97.53 rate or the charge, whichever is lower, and apply the sliding fee discount to the patient portion where the patient qualifies.
• Watch the first two weeks of remittances for returned claims and for lines paid at an unexpected amount, and fix the template, not just the claim.