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Effective Jan 1, 2026 (telehealth through Dec 31, 2026)
RHC/FQHC Telehealth and Care-Management Billing in 2026: What Changed, What Ends, and What You Must Report Instead
In 2026, CMS keeps RHC/FQHC non-behavioral telehealth billing alive through G2025, retires the RHC/FQHC wrapper codes (G0512 and G0071), and requires the underlying component codes instead—creating a compliance trap for any workflow still assuming the old wrappers.
Last updated: Dec 18, 2025
Audience: RHC/FQHC administrators, billing managers, compliance leads
How to use this page: Summarizes Medicare policy affecting RHCs/FQHCs in CY 2026 for operational planning and compliance design. Not legal advice.
2026 Snapshot
Telehealth
G2025 stays through 12/31/2026 (non-behavioral)
Retired Codes
- G0512 (CoCM wrapper)
- G0071 (CTBS/remote eval wrapper)
- Reminder: G0511 already terminated
Operational Risk
Template drift
Evidence gaps
Claim scrubbers
Section Index
- Key Takeaway in One Sentence
- The Core Rules and Dates
- What Ends in 2026: G0512 and G0071 (and What “Report Component Codes” Means)
- What Continues Through 2026: G2025 and RHC/FQHC Telehealth Boundaries
- Common Failure Patterns / Traps
- Why These Failures Are Non-Compliant
- Edge Cases & Clarifications
- Practical Implications for RHC/FQHC Operations
- Planning Checklist
- How This Fits the Bigger CMS Trajectory
- How FairPath Automates or Enforces This
- FAQs
- References
1. Key Takeaway in One Sentence
RHCs/FQHCs can keep billing non-behavioral telehealth with G2025 through December 31, 2026, but starting January 1, 2026 they must stop reporting G0512 and G0071 and instead report the individual underlying component codes those wrapper codes used to represent.
2. The Core Rules and Dates
Effective: January 1, 2026 (with certain telehealth provisions through December 31, 2026)
Audience: RHC/FQHC administrators, billing managers, compliance leads, medical directors, care-management operators
2.1 Telehealth: G2025 continues through December 31, 2026 (non-behavioral)
- CMS states RHCs/FQHCs may continue to bill non-behavioral services furnished through telecommunications technology by reporting G2025 through December 31, 2026.
- Behavioral health telehealth furnished by an RHC/FQHC is paid under AIR/PPS.
- Operationally: G2025 remains the allowed billing channel for the non-behavioral telehealth category and requires correct classification and documentation.
2.2 Wrapper-code retirement: G0512 and G0071 no longer reportable beginning January 1, 2026
- CMS’s RHC/FQHC pages state: “G0512 and G0071 are no longer reportable beginning January 1, 2026.”
- Instruction: “Report individual codes that make up both the CoCM and the Communications Technology-Based Services (CTBS) and Remote Evaluation Services, previously reported under HCPCS codes G0512 and G0071, respectively.”
- Reminder: G0511 is also terminated. CMS’s inclusion of APCM behavioral-health add-on codes (G0568–G0570) underscores the move toward service-specific reporting.
2.3 Context: CMS is unbundling
CMS already shifted RHCs to component-level reporting for care coordination (G0511 transition in CY 2025). Retiring G0512/G0071 continues this unbundling trend and raises the stakes for component-specific evidence.
3. What Ends in 2026: G0512 and G0071 (and What “Report Component Codes” Means)
CMS instructs RHCs/FQHCs to stop using G0512 and G0071 after January 1, 2026 and to report the component codes instead. Practically, that means:
- Billing systems must capture and submit the specific CPT/HCPCS codes representing the work performed instead of a wrapper line item.
- Evidence must map to each component code’s unit of service: eligibility, attribution, supervision, and any time thresholds.
- Audits will evaluate the claim against the component code definitions, not the retired wrapper.
If your charge capture, care-management logs, or telehealth workflows still assume the legacy wrapper pathways, you will generate claims that look normal internally but do not satisfy CMS’s reporting expectations.
4. What Continues Through 2026: G2025 and RHC/FQHC Telehealth Boundaries
- G2025 remains available through December 31, 2026 for non-behavioral telehealth services furnished by RHCs/FQHCs.
- Behavioral telehealth in RHC/FQHC settings is paid under AIR/PPS and must be classified distinctly from the G2025 pathway.
- CMS’s CY 2026 PFS fact sheet confirms G2025 allowances include audio-only communications technology for this non-behavioral pathway through 12/31/2026.
- The telehealth payment mechanism does not change supervision or delegation rules; classification must be enforced at intake and in documentation.
5. Common Failure Patterns / Traps
- Trap 1: Continuing to use G0512 or G0071 out of habit after January 1, 2026.
- Trap 2: Swapping wrapper codes for component codes without changing the evidence model (eligibility, attribution, time thresholds).
- Trap 3: Treating G2025 as a general-purpose “telehealth flag” instead of the specific non-behavioral pathway CMS allows.
- Trap 4: Confusing telehealth continuation with supervision or delegation allowances.
- Trap 5: Missing component-code exclusivity constraints (collision risks across practitioners/facilities in the same period).
6. Why These Failures Are Non-Compliant
- “No longer reportable” is literal: CMS explicitly instructs that G0512 and G0071 are not reportable beginning January 1, 2026.
- Component codes require component evidence: Claims will be judged on the unit of service, time requirements, supervision, and attribution for each component code.
- G2025 has scope boundaries: CMS frames G2025 as the RHC/FQHC billing mechanism for non-behavioral telecommunications services through 12/31/2026 and treats behavioral telehealth separately under AIR/PPS.
7. Edge Cases & Clarifications
Behavioral vs non-behavioral telehealth in RHC/FQHC settings
CMS distinguishes behavioral health telecommunications services (paid under AIR/PPS) from non-behavioral telecommunications services billed via G2025 through 12/31/2026. Scheduling and documentation must force classification at intake.
Audio-only nuance for 2026
CMS’s 2026 PFS fact sheet notes that G2025 policies include services furnished using audio-only communications technology through December 31, 2026 for the non-behavioral pathway. Treat this as a narrow allowance tied to that pathway.
In-person mental health visit timing
CMS flags timing nuances for the in-person mental health visit requirement associated with telecommunications mental health services. Treat this as a separate compliance workstream rather than folding it into G2025 logic.
Reporting rules vs payment mechanics
Even when payment uses national non-facility PFS rates in RHC/FQHC contexts, reporting rules still determine compliance. Component reporting and correct telehealth routing remain mandatory.
8. Practical Implications for RHC/FQHC Operations
- Charge capture must be granular: Replace wrapper picks with component code selection backed by component evidence.
- Compliance must be service-aware: Eligibility, attribution, time thresholds, and collision detection need to be explicit for each component code.
- Worklists must map to claimable units: Ensure operational views expose the units that become claims.
- Hard stop on retired codes: Block G0512/G0071 on or after 1/1/2026 and prevent claim generation with these codes.
9. Planning Checklist
- Identify every workflow that produces G0512 or G0071 and redesign to output component codes with component evidence.
- Remove G0512/G0071 from charge capture picklists and fee schedules for dates of service on/after 1/1/2026.
- Build a pre-claim validator that blocks retired codes after 1/1/2026, component codes without required evidence, and collision scenarios.
- Confirm telehealth classification logic: behavioral telecommunications services under AIR/PPS; non-behavioral via G2025 through 12/31/2026.
- Train staff on the new unit-of-service reality: component-level documentation and audit trails.
10. How This Fits the Bigger CMS Trajectory
CMS is pushing toward auditable specificity: fewer broad buckets, more explicit attribution, and clearer units of service. Retiring G0512 and G0071 while directing clinics to report component codes repeats the unbundling pattern (e.g., the G0511 transition) and aligns with the broader move to make integrated services auditable and evidence-backed.
11. How FairPath Automates or Enforces This
- Retired-code hard block: G0512 and G0071 are not selectable for dates on/after 1/1/2026; claims containing them are blocked.
- Component-code enforcement: component selections require matching evidence packs (eligibility, attribution, time where applicable).
- Telehealth pathway gating: workflows require classification (behavioral vs non-behavioral) and route to the correct claim mechanism (G2025 where applicable).
- Collision detection: system checks for conflicting care coordination billing during the same period where CMS policy constrains that behavior.
Result
Operational guardrails prevent retired-code usage, enforce component-grade documentation, and align telehealth routing before claims are generated.
12. FAQs
1
Can RHCs/FQHCs continue billing non-behavioral telehealth in 2026?
Yes. CMS states through December 31, 2026 RHCs/FQHCs may continue to bill non-behavioral services furnished via telecommunications technology by reporting G2025.
2
Is audio-only allowed for the RHC/FQHC non-behavioral telehealth pathway in 2026?
CMS’s 2026 PFS fact sheet indicates this policy includes services furnished using audio-only communications technology through December 31, 2026 for the G2025 pathway.
3
Do G0512 and G0071 remain usable in 2026?
No. CMS states G0512 and G0071 are no longer reportable beginning January 1, 2026. They must be replaced by the underlying component codes.
4
What must we bill instead of G0512 and G0071?
CMS instructs clinics to report the individual codes that make up the services previously reported under G0512 (CoCM) and G0071 (CTBS and remote evaluation services). The evidence model must match those component codes.
5
Does this mean CMS reduced requirements for those services?
No. Reporting changed. Component codes still require eligibility, time thresholds (where applicable), attribution, and supervision that align with the specific service definitions.
6
What if our EHR still has G0512/G0071 as selectable charge options?
Remove them from picklists for 2026 dates of service and add a claim scrubber rule to block any claim that includes them after 1/1/2026.
7
How does this interact with the earlier G0511 change?
CMS already moved RHCs to reporting individual care coordination codes instead of G0511 in CY 2025. The 2026 retirement of G0512/G0071 creates a second unbundling wave.
8
Does G2025 apply to tele-mental health in RHCs/FQHCs?
No. CMS distinguishes behavioral telecommunications services (paid under AIR/PPS) from non-behavioral telecommunications services billed via G2025 through 12/31/2026.
9
Do these changes affect APCM behavioral-health add-ons in RHC/FQHC settings?
They are separate policy surfaces, but both point toward service-specific attribution and evidence. CMS references APCM behavioral integration add-ons (G0568–G0570) as part of the 2026 environment.
10
What KPI prevents end-of-month surprises?
Track a component-code readiness metric: the share of encounters/worklogs with complete component evidence (eligibility + time where applicable + attribution) before claim generation.
13. References
- CMS Telehealth FAQ (Updated 11/26/2025): RHC/FQHC behavioral vs non-behavioral telecommunications services; G2025 through 12/31/2026.
- CMS Rural Health Clinics Center: G0512 and G0071 no longer reportable beginning 1/1/2026; report the individual codes that make up CoCM and CTBS/remote evaluation services; reminder that G0511 is terminated.
- CMS Federally Qualified Health Centers (FQHC) Center: 2026 telehealth and related updates; reference to APCM behavioral integration add-ons.
- CMS Fact Sheet (CMS-1832-F): CY 2026 PFS final rule summary including RHC/FQHC policies allowing G2025 through 12/31/2026 (including audio-only for that pathway).
- CMS MLN Booklet MLN006398 (July 2025): RHC care coordination reporting shift to individual codes and operational constraints.
- Federal Register proposed rule docket (context for terminology; final CMS instructions govern operations).
