According to the National Health Center Financial and Operational Performance Analysis (2020–2023), rural FQHCs delivered 3 million telehealth visits in 2023, but billing these services has only gotten more complex. Medicare’s non-behavioral telehealth flexibility expired September 30, 2025, and Medicaid policies vary significantly across all 50 states. Most billing teams struggle with which codes to use and what payment rates to expect.
This guide clarifies the current FQHC telehealth billing environment. We’ll walk through Medicare FQHC telehealth billing policies that apply nationwide, then break down Medicaid telehealth billing coverage and payment structures for each state. You’ll get the specific information needed to bill telehealth services correctly without going through the policy theory.
Medicare telehealth policies apply uniformly across the country. Whether your FQHC operates in Alaska or Florida, you follow the same federal rules. The challenge is that these rules are split into two distinct categories with different expiration dates and payment structures.
FQHCs have permanent authorization to bill Medicare for behavioral and mental health services delivered via telehealth. This includes substance use disorder treatment. You receive your standard PPS rate, the same payment you’d get for an in-person visit.
Patients can receive these services at home with no geographic restrictions. Audio-only visits are allowed when patients cannot or will not use video technology.
| Code | Description | Payment | Modifier | Status |
|---|---|---|---|---|
| G0469 | Mental health - new patient | PPS Rate | 95 (video) or FQ (audio) | Permanent |
| G0470 | Mental health - established patient | PPS Rate | 95 (video) or FQ (audio) | Permanent |
Important Note:
The in-person visit requirement remains waived through December 31, 2025. Starting January 1, 2026, patients must have an in-person visit within six months before their first telehealth mental health session, then annually thereafter.
Non-behavioral telehealth services faced a significant change on September 30, 2025, when the distant site flexibility expired. FQHCs can no longer bill Medicare for providing general medical telehealth services to patients in their homes or other non-clinical locations.
Before this expiration, FQHCs used the payment structure below. Without legislative action, FQHCs revert to pre-pandemic limitations: billing only as originating sites where patients physically present at your facility connect with distant providers.
| Code | Description | Payment | Status | Expiration |
|---|---|---|---|---|
| G2025 | Non-behavioral telehealth | $96.87 | Expired for distant site | Sept 30, 2025 |
| Q3014 | Originating site facility fee | $28.64 | Active | N/A |
Important Note:
The G2025 payment methodology continues through December 31, 2025, but only applies if Congress extends the distant site authorization. Typical Federally Qualified Health Centers' PPS rates range from $180-$250, making the G2025 rate significantly lower than standard reimbursement.
Medicare Administrative Contractors automatically apply minor geographic adjustments (±5-15%) based on local cost indices, but the base rates and coverage rules remain identical nationwide.
Medicaid operates fundamentally differently from Medicare. Instead of one federal program, you’re dealing with 50 separate state programs that each make their own rules within federal guidelines.
States decide three critical aspects of FQHC telehealth billing:
Current data shows significant state adoption of FQHC telehealth policies, though gaps remain:
| Coverage Area | Number of States |
|---|---|
| Allow FQHCs as distant site providers | 39 states + DC |
| Allow FQHCs as originating site providers | 35 states + DC |
| Cover live video telehealth | 50 states + DC + PR |
| Cover audio-only telehealth | 45 states + DC |
| Cover remote patient monitoring (RPM) | 42 states |
| Cover store-and-forward | 37 states |
| Cover all four modalities | 31 states |
| Provide facility fee reimbursement | 35 states |
Important Note:
These numbers reflect policies explicitly documented in state Medicaid manuals and regulations as of Fall 2024. States without explicit FQHC telehealth policies may still reimburse services under general telehealth provisions, but clarity varies significantly. So, be mindful.
Rather than listing all 50 states individually, we’ve grouped them by coverage patterns. This shows you immediately which category your state falls into and what billing options are available.
These 31 states cover live video, audio-only, store-and-forward, AND remote patient monitoring for FQHCs:
| States | FQHC as Distant Site | Payment Method | Facility Fee |
|---|---|---|---|
| Alaska, Arizona, California, Colorado, Delaware, Hawaii, Illinois, Iowa, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, New Hampshire, New York, North Carolina, North Dakota, Ohio, Oregon, Pennsylvania, South Carolina, South Dakota, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin | All except California (care management services only) | PPS Rate | Yes (except CA, IL, MA, OR) |
Important Note:
While all these states cover all four modalities, specific requirements vary. California requires patient choice between audio and video. Hawaii requires separate FQHC sites for dental services.
| States | FQHC as Distant Site | FQHC with No Distant Site | Payment Method | Facility Fee |
|---|---|---|---|---|
| Arkansas, Florida, Georgia, Indiana, Kansas, Montana, Nebraska, Nevada, New Jersey, New Mexico, Tennessee | Arkansas, Georgia, Indiana, Kansas, Montana, Nebraska, Nevada | Florida, New Jersey, New Mexico, Tennessee | PPS Rate | Yes |
| States | Coverage | FQHC as Distant Site | Payment Method | Facility Fee |
|---|---|---|---|---|
| Idaho | Video + Audio | No | PPS Rate | Yes |
| Rhode Island | Video only | No | PPS Rate | Yes |
While most states follow standard Medicaid telehealth policies, some have implemented unique requirements that directly affect how FQHCs bill. These distinctions matter because failing to meet state-specific documentation or procedural requirements can result in claim denials, even when the service itself is covered.
New York Medicaid released a specific Telehealth Provider Manual for fee-for-service providers, consolidating all telehealth policies in one accessible location. The state added reimbursement for eVisits (patient-initiated virtual check-ins through asynchronous communication) and clarified that doula services can be provided via telehealth under certain circumstances.
Texas allows FQHCs to bill the Q3014 facility fee, but multiple facility fee payments for the same patient on the same day require specific documentation. You must obtain a signed letter from the treating provider at your FQHC documenting that the patient suffered an injury requiring additional diagnosis or treatment by a distant site provider. Without this documentation, the second facility fee will be denied.
Mississippi explicitly recognizes FQHCs as both originating and distant site providers simultaneously. If your FQHC provides both roles in a single encounter, for example, when the patient is at your facility connecting to one of your specialists in another location, you can bill for both the distant site service and the originating site facility fee. This applies when services are “appropriately provided by the same organization.”
Montana Medicaid prohibits telehealth when the originating site and distant provider are “located within the same facility or community.” The state doesn’t define “community,” creating ambiguity. FQHCs with multiple sites in the same town or county should verify with Montana Medicaid whether their configurations qualify before submitting distant site claims.
Nebraska specifies that distant sites must bill with place of service code 02 (telehealth not in the patient’s home) or code 10 (telehealth in the patient’s home). This differs from states that don’t require specific POS codes for telehealth. The reimbursement rate matches face-to-face services, and documentation requirements mirror in-person visit standards.
For dental telehealth services billed under PPS, Hawaii requires both the patient and dentist to be physically located at separate eligible FQHC or RHC sites. Both sites must be registered with Med-QUEST as Medicaid locations and have HRSA Notice of Award documentation identifying the specific service location address. Services where patients are at “public health settings” not federally registered as FQHC sites don’t qualify for PPS reimbursement.
California Medicaid updated its provider manual to require FQHCs to allow patients to choose between synchronous audio/visual or audio-only telehealth modalities. Patients can change their choice at any time. Additionally, FQHCs must either offer in-person services directly or maintain a documented process for referring patients to in-person care within a reasonable timeframe.
Pennsylvania recently expanded its definition of an FQHC/RHC encounter to explicitly include telehealth, telemedicine, and teledentistry. The state also added store-and-forward reimbursement and became one of the newest states to implement private payer telehealth laws, though its interprofessional consultation policy requires real-time interactive communication, excluding asynchronous store-and-forward for consultations.
Indiana permits FQHCs and RHCs to bill for telehealth encounters if the service qualifies as both a valid FQHC encounter and a covered telehealth service. Encounter codes (T1015 or D9999) must be billed as usual, while each service within the encounter must carry the appropriate telehealth place of service and modifier (93 or 95). Payment for the encounter code is made at the facility’s PPS rate.
Missouri provided billing clarifications ensuring that telehealth visits count as eligible threshold encounters for FQHCs and RHCs. The state also issued guidance on facility fee billing procedures, helping clarify longstanding confusion about when and how to submit originating site facility fee claims.
Medicare telehealth operates uniformly nationwide with permanent mental health coverage at PPS rates. Non-behavioral services expired September 30, 2025, limiting medical telehealth to originating site scenarios unless Congress extends coverage. Medicaid functions as 50 separate programs; 39 states plus DC authorize FQHCs as distant site providers with varying modality coverage.
Check your state’s policies using the comparison tables above and verify specific requirements through the Center for Connected Health Policy’s database or your state Medicaid services manual. Focus Medicare billing on behavioral health, where coverage remains stable, and contact your state Medicaid office directly for clarification on undocumented policies.
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