RHC and FQHC claims manual aligns telehealth and deductible instructions
Oct 11, 2026 edition · GC-2026-0159 · Published 2026-10-11 · Version 3 · Final
CMS aligns RHC/FQHC manual instructions with existing telehealth policy, separating non-behavioral distant-site coding, mental-health visits, and the originating-site facility fee. Deductible and preventive-service treatment depend on the service being billed.
What happened
The September 29 transmittal is effective October 1 and implemented October 5, and expressly says it makes no policy changes. From October 1, non-behavioral distant-site telehealth uses individual CPT or HCPCS codes describing the service rather than G2025, with the appropriate revenue code and audio-only modifier 93 or audio/video modifier 95. FQHCs do not add an FQHC PPS payment code for these services. Preventive-service deductible and coinsurance waivers remain, without the former need to identify them through the CS modifier.
Mental-health visits through telecommunications retain their separate billing approach equivalent to in-person visits, also distinguishing audio/video from audio-only modifiers. An originating-site facility fee is a different claim component, using Q3014 and revenue code 0780. The manual preserves Part B deductible treatment for that telehealth facility-fee context while generally excluding FQHC services from the deductible and retaining RHC preventive-service exceptions. Those distinctions make one generic telehealth charge or deductible edit inadequate across all three pathways; the manual alignment does not create a new unrestricted telehealth entitlement.
Scope and timing
- Authority status
- Final
- Applicability
- Operationally relevant
- Audience
- Health systems, Provider networks
- Jurisdiction
- Federal
- Affected functions
- Revenue Cycle, Compliance, Clinical Operations
- Responsible owner
- Revenue Cycle
- Recorded date
- 2026-10-05
- Date type
- implementation
Why it matters
Clinics should reconcile current billing instructions without treating the manual update as a new telehealth entitlement.
Recommended action
Clinic billing owners should validate individual distant-site CPT/HCPCS codes and modifiers for October services, separate mental-health visit and Q3014 rules, test deductible and preventive-service edits, and correct affected claims through the applicable process.
Implementation playbook
- Compare clinic billing templates with the updated manual and the previously issued distant-site telehealth instruction. Revenue Cycle · Due 2026-10-05
- Record the applicability assessment and validate the affected workflow with its operational owner. This is an internal review target, not an additional statutory deadline. Compliance · Due 2026-10-12
Sources
- CMS Transmittal R13975CPOfficial · Centers for Medicare & Medicaid Services · 2026-09-29 · Source review 2026-10-11
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This finding in the complete approved report →Regulatory horizons, CIA trends and implementation trackers remain in the full report.
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