CMS Issues COVID-19 Billing Guidance
for FQHC's & RHC's
April 17, 2020

Earlier this afternoon, the Center for Medicare and Medicaid Services (CMS) released MLN SE20016 : New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE).

Among other topics, the MLN provides instructions for FQHCs and RHCs regarding distant site fee payment.

Keep reading for a outline of the information covered in the MLN, or click the link above (or the image to the right) to access the CMS document.
Payment Guidance for FQHC and RHC
Telehealth Services as a Distant Site
For CMS claims effective January 27, 2020 through June 30, 2020:
FQHCs/RHCs are eligible to furnish any telehealth service that is already approved as a distant site telehealth service within the 2020 Physician Fee Schedule .

When billing as the telehealth distant site, FQHCs/RHCs must use Modifier 95 on the claim, & FQHCs/RHCs will be paid their AIR/PPS rate.

Per the MLN, FQHCs/RHCs do not need to resubmit existing claims for this payment modification; these claims will be automatically refiled in July 2020 when the Medicare claims processing system has been updated with the new payment rate.

For claims effective July 1, 2020 through the end of the PHE:

FQHCs/RHCs will use G2025 to identify services that were furnished via telehealth. Claims with the new G code will be paid at the $92 rate.

Only distant site telehealth services furnished during the PHE are authorized for payment; If the public health emergency is still in effect after December 31, 2020, the MLN states that this rate will be updated based on the 2021 Physician Fee Schedule average payment rate for these services.

Addtional CMS Guidance Covered

Along with the distant site payment directives, the new CMS MLN provides guidance for FQHCs and RHCs regarding:

  • Accelerated/advanced payment structures;
  • Consent Processes (Documentation and Timing), and
  • Scope of home health/visiting nursing services.

FCC Funding Opportunity Updates:
ICYMI: Application Period Now Open!
Hot off the Press: 1st Round of Awardees Announced
Funding Opportunity Background
Earlier this month, the FCC announced the The COVID-19 Telehealth Program, which will provide $200 million in funding, appropriated by Congress as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, to help health care providers provide connected care services to patients at their homes or mobile locations in response to the novel Coronavirus 2019 disease (COVID-19) pandemic. 

The Program aims to provide immediate support to eligible health care providers responding to the COVID-19 pandemic by fully funding their telecommunications services, information services, and devices necessary to provide critical connected care services until the program’s funds have been expended or the COVID-19 pandemic has ended. Please note that the COVID-19 Telehealth Program is limited to nonprofit and public eligible health care providers, for more information see here , or click the PDF of the 4/10/20 Press Release on the right

First Program Awardees Announced
As referenced above, the FCC has promised to evaluate and award the applications on a rolling basis until the funds are depleted, 3 days after applications began being accepted, we've seen 6 health systems from across the United States receive funding!

See here and here for write-ups about the various systems and their application goals from Healthcare IT News and mHealth Intelligence respectively.
About the NETRC
The Northeast Telehealth Resource Center (a proud member of the  National Consortium of Telehealth Resource Centers) aims to increase access to quality health care services for rural and medically underserved populations through Telehealth. Our service area includes New England, Northern New Jersey, and New York. Learn more at
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This communication was made possible by grant number G22RH30352 from the Office for the Advancement of Telehealth, Health Resources and Services Administration, DHHS