HCPCS G2025: Payment for RHC and FQHC Telehealth Services

Obtain a list of the documentation and billing requirements needed to properly use and bill for HCPCS code G2025 from our short guide.

Use Code

## **What is HCPCS code G2025?** HCPCS code G2025, which has a full description of payment for a telehealth distant site service furnished by a rural health clinic (RHC) or federally qualified health center (FQHC) only, is maintained by the Centers for Medicare and Medicaid Services (CMS) and falls under Care Management Services. It is a temporary Medicare payment code specifically designated for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) when acting as the distant site provider for non-behavioral/mental health telehealth services. The purpose of this service and its dedicated code is to increase access to essential medical care for beneficiaries in rural and underserved areas who face geographic or other barriers to an in-person visit. Instead of billing under the traditional Medicare Physician Fee Schedule (PFS), RHCs and FQHCs use G2025 to receive a flat rate payment (currently set based on the average of all PFS telehealth services) for the service, which must be furnished using real-time, interactive telecommunications technology (audio-video or, in certain cases, audio-only). This billing mechanism allows RHCs and FQHCs to be reimbursed for services that would normally be considered clinic visits, effectively granting them parity with other telehealth providers during a time when broader telehealth flexibilities were in effect. The G2025 policy and its associated payment rate are temporary, having been repeatedly extended by CMS, and are currently set to expire on December 31, 2025. It is crucial to note that this code is not used for behavioral or mental health services, which have separate, permanent telehealth billing rules for RHCs and FQHCs under their All-Inclusive Rate (AIR) or Prospective Payment System (PPS).

## **Documentation requirements** While specific documentation may vary by payer and state, for Medicare, the general documentation requirements for a telehealth service billed under G2025 should include: - **Medical necessity**: Clear justification that the service provided via telehealth was medically necessary. - **Patient consent**: Documentation of the patient's verbal or written consent to receive the service via telehealth technology. - **Modality**: The type of telecommunications technology used (e.g., two-way, real-time audio-video, or audio-only, when permitted). - **Distant and originating site**: Although RHCs/FQHCs are the distant site, the patient's location (the originating site, which is currently often their home) must be documented. - **Clinical content**: Standard medical record documentation for the visit, including a history, physical examination (to the extent possible via telehealth), diagnosis, risk assessment, and plan of care. The documentation should be sufficient to support the services provided and billed.

## **Billing requirements** Key billing guidelines for G2025 under Medicare for RHCs/FQHCs: - **Rate**: Payment is based on the average amount for all Medicare telehealth services paid under the Physician Fee Schedule (PFS), weighted by volume. The specific reimbursement rate is subject to change annually. - **Claim form**: Typically billed on a UB-04 claim form. - **Revenue code**: Generally reported with Revenue Code 052X (RHC/FQHC service). - **Exclusions**: This code is only for non-behavioral/mental health telehealth services (e.g., general medical visits). - **Expiration**: The ability to bill for non-behavioral health services using G2025 is scheduled to expire on December 31, 2025.

## **Other relevant codes** - **G0071**: Payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between a rural health clinic (RHC) or federally qualified health center (FQHC) practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; RHC or FQHC only - **99421 – 99423 (CPT)**: Online Digital Evaluation and Management (E/M) Services

Frequently asked questions

Only for non-behavioral/mental health services furnished as the distant site provider via telecommunications technology.

Yes, if the service meets Medicare’s requirements for audio-only telehealth in certain situations (e.g., behavioral health).

No. The authorization to use G2025 for non-behavioral health services is temporary and is currently set to expire on December 31, 2025, unless Congress or CMS extends the waiver.