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As required by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, on April 17, 2020, the Centers for Medicare and Medicaid Services (CMS) issued new guidance authorizing community health centers to furnish telehealth services to Medicare beneficiaries during the COVID-19 pandemic.  

Health centers were previously ineligible to receive Medicare payment for telehealth services and this guidance follows several recent regulatory actions by CMS to expand the delivery of care through virtual visits.


As specified by the guidance, for the duration of the national emergency:

  • Medicare “distant site” telehealth services can be furnished by any healthcare practitioner working for a Federally Qualified Health Center (FQHC) within their scope of practice. 
  • An FQHC practitioner can furnish distant site telehealth services from any location, including their home, during the time that they are working for an FQHC.
  • An FQHC practitioner can furnish any of the nearly 200 telehealth services that are currently approved as distant site telehealth services under Medicare’s Physician Fee Schedule.
  • Patients can receive telehealth services from any “originating site” location, including their home.  

As is the case for all Medicare practitioners - both prior to and during the emergency- CMS will require FQHC practitioners to use a live audio and video telecommunications system to conduct telehealth visits.

Billing & Payment

As for reimbursement, the CARES Act established that CMS set a single payment rate for all FQHC telehealth services at a level equal to the national average payment rates for telehealth services delivered under the Physician Fee Schedule (PFS). The guidance sets that payment rate at $92, which it says is “the average amount for all PFS telehealth services on the telehealth list, weighted by volume for those services reported under the PFS.”

As for billing, for telehealth services furnished between January 27, 2020, and June 30, 2020, FQHCs must put Modifier “95” (Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System) on all claims. Medicare will pay those claims at the 2020 FQHC Prospective Payment System (PPS) rate, which is $173.50. However, as noted by CMS: “these claims will be automatically reprocessed in July when the Medicare claims processing system is updated with the new payment rate.”  

For telehealth services furnished between July 1, 2020, and the end of the emergency, FQHCs should submit claims using the code G2025, which will be paid at the $92 rate.

Bottom Line

Medicaid is the largest payer for most community health centers and over the past several weeks most state Medicaid programs have established policies to expand coverage of and payment for telehealth services during the COVID-19 emergency. CMS has supported these efforts from the federal level, recently approving Section 1135 Medicaid program waivers for 48 states and the District of Columbia.

However, many community health centers also care for large populations of Medicare patients and this guidance should enable those centers to better care for those patients while getting paid to do so. During this crisis, every little bit helps, both for our nation’s seniors and our community health centers. 

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Chris Emper

Government Affairs Advisor, NextGen Healthcare

Chris Emper, JD, MBA, is government affairs advisor at NextGen Healthcare and president of Emper Healthcare Advisors—a health IT industry advisory and consulting services firm in Washington, D.C. that specializes in helping healthcare providers and technology companies successfully navigate and comply with complex regulations and value-based reimbursement models. Prior to forming Emper Healthcare Advisors in 2016, Chris was vice president of Government Affairs at NextGen Healthcare (NASDAQ: NXGN) and Chair of the Electronic Health Record Association (EHRA) Public Policy committee.

An expert in The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), The Patient Protection and Affordable Care Act (ACA), and The 21st Century Cures Act, Chris is a frequent speaker at industry conferences and has written or appeared in articles in publications such as Politico, Health Data Management, Accountable Care News, and Medical Economics. From 2016-2019, Chris served as Chair of the HIMSS Government Relations Roundtable, a leading coalition of health IT government affairs professionals.

Prior to joining NextGen Healthcare in 2013, Chris served as a Domestic Policy Advisor for former Massachusetts Governor Mitt Romney’s 2012 Presidential Campaign, where he advised the campaign on policy issues including healthcare, technology, and innovation. He holds a law degree and an MBA from Villanova University and a BA from Boston College.