Eligible Distant Site

Temporary Policy – Ends Dec. 31, 2024

In the case that such emergency period ends before December 31, 2024, during the period beginning on the first day after the end of such emergency period and ending on December 31, 2024—

• the Secretary shall pay for telehealth services that are furnished via a telecommunications system by a Federally qualified health center or a rural health clinic to an eligible telehealth individual enrolled under this part notwithstanding that the Federally qualified health center or rural clinic providing the telehealth service is not at the same location as the beneficiary;
• the amount of payment to a Federally qualified health center or rural health clinic that serves as a distant site for such a telehealth service shall be determined under subparagraph (B); and
• for purposes of this subsection—
  • the term “distant site” includes a Federally qualified health center or rural health clinic that furnishes a telehealth service to an eligible telehealth individual; and
  • the term “telehealth services” includes a rural health clinic service or Federally qualified health center service that is furnished using telehealth to the extent that payment codes corresponding to services identified by the Secretary under clause (i) or (ii) of paragraph (4)(F) are listed on the corresponding claim for such rural health clinic service or Federally qualified health center service.

SOURCE:  Social Security Act, Sec. 1834(m) (Title 42, Sec. 1395m).  (Accessed Jul. 2023).

Payment for Medicare Telehealth Services: Section 3704 of the CARES Act authorized RHCs and FQHCs to furnish distant site telehealth services to Medicare beneficiaries during the COVID-19 PHE. Medicare telehealth services generally require an interactive audio and video telecommunications system that permits real-time communication between the practitioner and the patient. (Some telehealth services can be furnished using audio-only technology.) RHCs and FQHCs with this capability could provide and be paid for telehealth services furnished to Medicare patients located at any site, including the patient’s home, through December 31,

2024. Telehealth services could be furnished by any health care practitioner working for the RHC or the FQHC within their scope of practice. Practitioners could furnish telehealth services from any distant site location, including their home, during the time that they are working for the RHC or FQHC, and could furnish any telehealth service that is included on the list of Medicare telehealth services under the Physician Fee Schedule (PFS), including those that have been added on an interim basis during the PHE. A list of these services, including which could be furnished via audio-only technology, is available at https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.

Beginning on or after January 1, 2022, RHCs and FQHCs can report and receive payment for mental health visits furnished via real-time telecommunication technology in the same way in-person visits are reported and reimbursed, including audio-only visits when the beneficiary is not capable of or does not consent to, the use of video technology. Payment under HCPCS code G2025 will no longer apply to mental health visits furnished via telehealth. This payment policy for mental health visits was made permanent for RHCs and FQHCs in the CY 2022 PFS final rule.

SOURCE: Centers for Medicare and Medicaid Services, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs): CMS Flexibilities to Fight COVID-19, 5/10/23, (Accessed Jun. 2023).

Security Act (CARES Act). Section 3704 of the CARES Act authorized RHCs and FQHCs to provide distant site telehealth services to Medicare patients during the COVID-19 PHE. Section 4113 of the Consolidated Appropriations Act, 2023, extended this authority through December 31, 2024.

Any health care practitioner working for you within your scope of practice can provide distant site telehealth services. Practitioners can provide distant site telehealth services – approved by Medicare as a distant site telehealth service under the physician fee schedule (PFS) – from any location, including their home, during the time that they’re working for you.

SOURCE: Centers for Medicare and Medicaid Services, New & Expanded Flexibilities for Rural Health Clinics & Federally Qualified Health Centers, MLN Matters Number: SE20016, May 12, 2023, (Accessed Jun. 2023).

FQHCs are not listed as an eligible distant site provider that can deliver services via telehealth.  However, FQHCs can provide telecommunications for mental health visits using audio-video technology and audio-only technology. See MLN Guidance for requirements.

SOURCE: Mental Health Visits via Telecommunications for Rural Health Clinics and Federally Qualified Health Centers, MLN Matters SE22001, (May 23, 2023), (Accessed Jun. 2023).

Medicare-covered mental health services furnished incident to an RHC or FQHC visit are included in the payment for a medically necessary mental health visit when an RHC or FQHC practitioner furnishes a mental health visit. Group mental health services do not meet the criteria for a one-one-one, face-to-face encounter in an FQHC or RHC.

SOURCE:  CMS, Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) Medicare Benefit Policy Manual Chapter 13 Update, Jan. 26, 2023, pg. 20 (Accessed Jul. 2023).

* The US Health and Human Services Administration maintains a website that summarizes information for Billing Medicare as a safety-net provider.

See: Federal Medicare Live Video Distant Site

Not included on distant site provider list in Medicaid Telemedicine Policy.

SOURCE: AL Medicaid, Telemedicine Policy, 5/26/23, Effective June 1, 2023, (Accessed Jun 2023).

Live Video:

Submitting a claim for a telemedicine service is identical to the way a claim would be submitted for a face-to-face visit. Depending on the method of telemedicine used and the role of the provider in the consultation determines whether a modifier should be added to the procedure code. The role of the provider falls into three categories:

• Consulting Provider: Evaluates the patient and/or medical data/images using telemedicine mode of delivery upon recommendation of the referring provider.

SOURCE: AK Dept. of Health and Social Services, FQHC/RHC (6/12), Accessed Jun. 2023).

Telehealth and telemedicine may qualify as a FQHC/RHC visit if it meets the requirements as specified in AMPM Policy 320-I.  To qualify as a reimbursable telehealth visit, claims with procedure code T1015 must additionally include another eligible code from the AHCCCS Telehealth Code Set.

SOURCE: AZ Health Care Cost Containment System, AHCCCS Fee-For-Service Provider Billing Manual, Ch. 10 Addendum: FQHC/RHC, (8/25/22), pg. 3, (Accessed May 2023). 

Telehealth and Telemedicine may qualify as a FQHC/RHC visit if it meets the requirements as specified in AMPM Policy 320-I.

SOURCE: AZ Medical Policy for AHCCCS Covered Services. Federally Qualified Health Centers (FQHC) and Rural Health Clinics (RHC) Reimbursement, Ch 670, (pg. 3), Effective 10/1/15. (Accessed May 2023).

The telemedicine procedure code and procedure codes for ancillary services, except for family planning-related laboratory procedures listed in this manual, will be denied.

SOURCE:  AR Medicaid Provider Manual. Section II FQHC. Rule 252.140. Updated Oct. 13, 2003. pg. II-27, (Accessed Jan. 2023).

FQHC Manual refers providers to Telemedicine policy manual for encounters.  AR Medicaid manual does not make an explicit reference to whether or not FQHCs are paid as distant site providers. 

See:  AR Medicaid Live Video Eligible Providers.

Yes, see manual for distant site scenarios and billing/reimbursement policies applicable.

The billable provider, employed or under direct contract with an FQHC or RHC can respond from any location, including their home, during a time that they are scheduled to work for the FQHC or RHC.

For the purposes of payment for covered treatment or services provided through telehealth, the department shall not limit the type of setting where services are provided for the patient or by the health care provider

SOURCE: CA Department of Health Care Services (DHCS). Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHC) Outpatient Services Manual (Jan 2023), p. 16-20. (Accessed Jun. 2023).

For Health First Colorado a billable encounter at an FQHC/RHC is an in person or telemedicine face to face visit with a Health First Colorado member. Telemedicine services are limited to the procedure codes identified on the Telemedicine Provider Information web page and Telemedicine Manual under General Billing Information. When a Federally Qualified Health Center or a Rural Health Clinic provides care through telemedicine, the claim must include the modifier GT on line(s) identifying the service(s).

SOURCE: CO FQHC & RHC Billing Manual 8/22. (Accessed Aug. 2023).

Health First Colorado allows telemedicine visits to qualify as billable encounters for Federally Qualified Health Centers (FQHCs), Rural Health Clinic (RHCs), and Indian Health Services (IHS). Services allowed under telemedicine may be provided via telephone, live chat, or interactive audiovisual modality for these provider types.

All distant site rendering providers bill the appropriate procedure code using Place of Service code 02 or 10 and the appropriate modifiers FQ or FR on the CMS 1500 paper claim form or as an 837P transaction.

Place of Services codes 02 and 10 can be used during telehealth encounters:

• POS 02: Telehealth provided other than in the patient’s home. The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
• POS 10: Telehealth Provided in Patient’s Home. The location where health services and health related services are provided or received through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.

Additionally, modifiers FQ, FR, 93, and 95 can be added to POS 2 and 10:

• FQ: The service was furnished using audio-only communication technology.
• FR: The supervising practitioner was present through two-way, audio/video communication technology.
• 93: Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System
• 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System

FQHC/RHCs may bill using modifier GT. When used by an FQHC or RHC, the modifier GT identifies the services as being delivered through telemedicine modality. There is no enhanced payment to FQHCs and RHCs when using the modifier GT.

SOURCE: CO Department of Health Care Policy and Financing. “Telemedicine Billing Manual” 7/23. (Accessed Aug. 2023).

Federally Qualified Health Centers (FQHCs) are eligible to bill their encounter rate when an approved, medically necessary telehealth service is rendered. FQHCs must use the services identified on the CMAP Telehealth Table in combination with their approved scope of service to identify the services eligible to be rendered using telehealth. FQHCs must continue to bill HCPCS code, T1015 and all eligible telehealth procedure codes to reflect all of the services rendered during the telehealth visit.

SOURCE: CMAP Telehealth Table. (Accessed Jul. 2023).

FQHCs are listed as eligible providers for a variety of services via telehealth and guidance states that the modifier GT is used when the member’s originating site is located in a healthcare facility or office; or modifier 95 Is used when the member is located at home.

SOURCE: CT Policy – Provider Bulletin 2020-09. March 2020. (Accessed Jul. 2023).

FQHCs are not explicitly listed as eligible distant site providers, although the provider list states that other providers can be approved by DMAP. In addition, COVID-19 guidance implies that FQHCs should “continue” typical billing practices for telehealth services as distant site/rendering providers:

• FQHC Rendering Providers billing for Interactive Telehealth Services or Telephonic Services should continue to bill their appropriate HCPCS (Healthcare Common Procedure Coding System) “G” visit payment code for each payable encounter visit, along with the appropriate code for the service provided and use Place of Service value 02 for all Telehealth Charges. For Telephonic Services, the same codes listed above should be used as appropriate.

SOURCE: DE Medical Assistance Program. Changes to DMMA Telehealth Policies to Respond to COVID-19. April 23, 2020. (Accessed Jul. 2023).

Generally, to receive payment for services delivered through telemedicine technology from DMAP or MCOs, healthcare practitioners must:

• Act within their scope of practice;
• Be licensed (in Delaware, or the State in which the provider is located if exempted under Delaware State law to provide telemedicine services without a Delaware (license) for the service for which they bill DMAP;
• Be enrolled with DMAP/MCOs;
• Be located within the continental United States;
• Be credentialed by DMMA-contracted MCOs, when needed;
• Submit a DMMA Disclosure Form.

SOURCE: DE Adult Behavioral Health Service Certification and Reimbursement. Dec. 1, 2016. Sec. 1.8. Pg. 11. (Accessed Jul. 2023).

Explicitly listed eligible distant site providers include:

• Inpatient/outpatient hospitals (including ER)
• Physicians (or PAs under the physician’s supervision)
• Certified Nurse Practitioners

• Nurse Midwives
• Licensed Psychologists
• Licensed Clinical Social Workers
• Licensed Professional Counselors of Mental Health
• Speech Language Therapists
• Audiologists
• Other providers as approved by the DMAP

SOURCE: DE Medical Assistance Program.  Practitioner Provider Specific Manual, 7/1/23. Ch. 16.2.4.3 Telemedicine, pg. 73-74, & Adult Behavioral Health Service Certification and Reimbursement. Dec. 1, 2016. Sec. 1.8. Pg. 12. (Accessed Jul. 2023).

FQHCs are eligible distant site providers.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.7,  Department of Health Care Finance – Telemedicine Provider Guidance, Jan. 2023, pg. 3. Physicians Billing Manual.  DC Medicaid.  (Apr. 2023) Sec. 15.3. P. 52, Clinic Billing Manual, DC Medicaid (Apr. 2023), Sec. 15.3, P. 50. FQHC Billing Manual, DC Medicaid 15.3, P. 52. (Apr. 2023), Behavioral Health Billing Manual (Apr. 2023) 14.3, p. 68. Outpatient Hospital Billing Guide, 15.8.3, p. 74 (Apr. 2023), Inpatient Hospital Billing Guide, 11.3, p. 61 (Apr. 2023), Long-Term Care Billing Manual, 15.3, p. 52 (Apr. 2023) (Accessed June 2023).

No Reference Found.

FQHC’s and RHC’s are authorized to serve as a distant site for telehealth services, and may bill the cost of the visit.

SOURCE:  Georgia Department of Community Health, Division of Medicaid, Telehealth Guidance, p. 42 (Apr.  2023). Georgia Department of Community Health, Division of Medicaid, Federally Qualified Health Center Services and Rural Health Clinic Services, p. 22. (Apr. 2023). (Accessed Jun. 2023).

Providers who are eligible to bill for Hawaii Medicaid services are also eligible providers who can bill for tele-health.  Refer to Hawaii Provider Manual Chapter 21 FQHCs for list of providers who may provide PPS services.

SOURCE: MedQUEST Memo QI-2007/FFS 20-03 (March 16, 2020). (Accessed Jun. 2023).

Medicaid policy is not subject to Medicare restrictions for virtual care unless the participant has Medicare primary. Otherwise, all Medicaid providers, including federally qualified health centers (FQHC’s), rural health centers (RHC’s), and Indian health clinics (IHC’s) may bill for virtual care services according to these guidelines.

FQHC, RHC or IHS providers should not report the GT or FQ modifier with encounter code T1015 but should include it with each applicable supporting codes.

SOURCE: ID Medicaid Provider Handbook: General Information and Requirements for Providers (May 26 2023), p. 131.  ID MedicAide May 2023.  (Accessed Jun. 2023).

Telehealth services provided as an encounter by a facility are reimbursable if the services are delivered in accordance with the Idaho Medicaid Telehealth Policy and applicable handbooks. See the General Information and Requirements for Providers, Idaho Medicaid Provider Handbook for more information about eligible services and billing requirements.

SOURCE: ID Medicaid Provider Handbook, IHS, fQHC, and RHC Services, p. 30 (Nov. 18, 2022).  (Accessed Jun. 2023).

The Distant Site is the site where the provider rendering the telehealth service is located. The Distant Site shall be reimbursed as follows:

• If the Originating Site is an encounter clinic, the Distant Site may not seek reimbursement from the Department for their services. The Originating Site encounter clinic is responsible for reimbursing the Distant Site.
• If the Originating Site is not an encounter clinic, the Distant Site encounter clinic can seek reimbursement from the Department.

For telemedicine services, the provider rendering the service at the Distant Site can be a physician, podiatrist, advanced practice nurse (APN), or a Physician Assistant (PA) who is licensed by the State of Illinois or by the state where the participant is located. For telepsychiatry services, the provider rendering the service at the Distant Site must be a physician licensed by the State of Illinois, or by the state where the patient is located, who has completed an approved general psychiatry residency program or a child and adolescent psychiatry residency program. Telepsychiatry is not a covered service when rendered by an APN or PA. Group psychotherapy is not a covered telepsychiatry service.

SOURCE: Handbook for Encounter Clinic Services. Ch. 200, pg. 17-18.  Aug. 2016. (Accessed Jun. 2023).

An encounter clinic serving as the distant site shall be reimbursed as follows:

1. If the originating site is another encounter clinic, the distant site encounter clinic shall receive no reimbursement from the Department.  The originating site encounter clinic is responsible for reimbursement to the distant site encounter clinic; and
2. If the originating site is not an encounter clinic, the distant site encounter clinic shall be reimbursed for its medical encounter.  The originating site provider will receive a facility fee as defined in subsection (a)(4) of this Section.

SOURCE: IL Administrative Code 89 140.403 (3). (Accessed Jun. 2023).

See billing examples in appendix.

SOURCE:  IL Dept of Healthcare and Family Services All Providers Handbook Supplement (Sept. 23, 2020). Encounter Clinic Services – Appendices. (Accessed Jun. 2023).

FQHCs, RHCs, and ERCs billing for FFS reimbursement of LARCs at the Practitioner Fee Schedule rate, as well as virtual check-in and e-visit services at the FFS rate indicated on the COVID-19 Virtual Healthcare Expansion Billing Codes fee schedule found on the COVID-19 Updates webpage, must adhere to the following guidelines for proper reimbursement:

• Report only the applicable CPT or HCPCS procedure code, without reporting the T1015 encounter code.
• Report one of the following taxonomy codes in billing loop 2010AA, in accordance with the Chapter 300 Taxonomy table for 837P, in order for the clinic to be correctly identified as the provider of record for FFS reimbursement:

o   261QF0400X (FQHC)

o   261QR1300X (RHC)

o   261QP2300X (ERC)

Additional detailed reimbursement criteria specific to FFS billing of LARCs is also found in Topic 210.5.2 of the Handbook for Providers of Encounter Clinic Services.

SOURCE: Provider Notice Billing Procedures for Fee-For-Service Reimbursement and Telehealth Billing Clarification (May 20, 2020). (Accessed Jun. 2023).

When the FQHC or RHC is the distant site, the service provided by the FQHC or RHC must meet the requirements both for a valid encounter and for an approved telehealth service. The claim must include the following:

• Encounter code T1015 (or D9999 for valid dental encounters), billed with POS code 02, 03, 04, 10, 11, 12, 31, 32, 50 or 72
• One or more appropriate procedure codes for the specific services rendered, billed with modifier 93 or 95, and a POS code of either 02 or 10, depending on the originating site/location of the patient

SOURCE: Indiana Health Coverage Programs, Provider Reference Manual, Telehealth and Virtual Services (Sept. 27, 2022), p. 6. (Accessed Jun. 2023).

Subject to the following criteria, reimbursement is available to FQHCs and RHCS when they are serving as either the distant site or the originating site for telehealth services.

SOURCE: IHCP Bulletin BT 202239 (May 19, 2022), p. 3. (Accessed Jun. 2023).

The Indiana Health Coverage Programs (IHCP) published IHCP Banner Page BR202152 introducing the addition of place of service (POS) code 10. The Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) is clarifying that the IHCP will allow the use of POS code 10 for federally qualified healthcare centers (FQHCs) and rural health clinics (RHCs) for dates of service (DOS) on or after July 21, 2022. Any FQHC or RHC claims with DOS before July 21, 2022, will deny if the POS 10 is present on the claim. Please correct these claims using the appropriate POS 02 and resubmit. The definitions for the telehealth POS codes changed on Jan. 1, 2022:

• POS 02 – Telehealth provided other than in patient’s home
• POS 10 – Telehealth provided in patient’s home

As posted in IHCP Bulletin BT202239, the following modifiers are used on telehealth claims:

• Modifier 95 – Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system
• Modifier 93 – Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system

Beginning July 21, 2022, FQHC and RHC providers must have one or more appropriate procedure codes for the specific services rendered, billed with modifier 93 or 95, and a POS code of either 02 or 10, depending on the originating site/location of the patient.

SOURCE: IHCP Allows New POS Code for FQHCs and RHCs July 21 BT 202253 (July 14, 2022).  (Accessed Jun. 2023).

The office shall reimburse the following Medicaid providers for medically necessary telehealth services:

• A federally qualified health center
• A rural health clinic
• A community mental health center
• A critical access hospital
• A home health agency licensed under IC 16-27-1.
• A provider, as determined by the office to be eligible, providing a covered telehealth service.

SOURCE: IN Admin Code, “Article 5” 405 5-38-4(3) p. 196-197 & IN Code, 12-15-5-11 (Accessed Jun. 2023).  

FQHCs may serve as distant sites.

See: IA Medicaid Live Video Distant Sites

SOURCE:  Iowa Dep. of Human Services.  Informational Letter No. 2103-MC-FFS. (Feb. 20, 2020). (Accessed Aug. 2023).

The consulting or expert provider at the distant site must bill an appropriate code from the list below with place of service (POS) 02 – Telemedicine and will be reimbursed at the same rate as face-to-face services.

SOURCE: KS Dept. of Health and Environment, Kansas Medical Assistance Program, Provider Manual, FQHC/RHC, 8-13 (Apr. 2023), (Accessed Jul. 2023).

See: KS Medicaid Live Video Eligible Providers

For rural health clinics, federally qualified health centers, and federally qualified health center look-alikes, reimbursement for covered telehealth services and telehealth consultations shall:

• To the extent permitted under federal law, include an originating site fee in an amount equal to that which is permitted under 42 U.S.C. sec. 1395m for Medicare-participating providers if the Medicaid beneficiary who received the telehealth service or telehealth consultation was physically located at the rural health clinic, federally qualified health center, or federally qualified health center look-alike at the time of service or consultation delivery and the provider of the telehealth service or telehealth consultation is not employed by the rural health clinic, federally qualified health center, or federally qualified health center look-alike; or
• If the telehealth service or telehealth consultation provider is employed by the rural health clinic, federally qualified health center, or federally qualified health center look-alike, include a supplemental reimbursement paid by the Department for Medicaid Services in an amount equal to the difference between the actual reimbursement amount paid by a Medicaid managed care organization and the amount that would have been paid if reimbursement had been made directly by the department.

A health-care facility that receives reimbursement under this section for consultations provided by a Medicaid-participating provider who practices in that facility and a health professional who obtains a consultation under this section shall establish quality-of-care protocols, which may include a requirement for an annual in-person or face-to-face consultation with a patient who receives telehealth services, and patient confidentiality guidelines to ensure that telehealth consultations meet all requirements and patient care standards as required by law.

The Department for Medicaid Services and any managed care organization with whom the department contracts for the delivery of Medicaid services shall not deny reimbursement for telehealth services covered by this section based solely on quality-of-care protocols adopted by a health-care facility.

SOURCE: KY Statute Sec. 205.559. (Accessed Jul. 2023).

See: KY Medicaid Live Video Eligible Providers

Reimbursement for service codes appropriate to telemedicine/telehealth will be at the all-inclusive prospective payment rate on file for the date of service (DOS).

SOURCE: LA Dept. of Health, Informational Bulletin 20-1. (May 20, 2022). (Accessed Jun. 2023).

See: LA Medicaid Live Video Eligible Providers

If approved, FQHCs may serve as the provider site and bill under the encounter rate.

SOURCE: MaineCare Benefits Manual, Telehealth, 10-144 Ch. 101, Ch. 1, Sec. 4., p. 13. (June 15, 2020). (Accessed May 2023).

Also see: ME Medicaid Live Video Eligible Providers

FQHCs are permitted places of service from where to deliver services via telehealth. All distant site providers enrolled in Maryland Medicaid may provide services via telehealth as long as telehealth is a permitted delivery model within the rendering provider’s scope of practice.

SOURCE: MD Medicaid Telehealth Program FAQs. p. 1-2, Updated April 2020. (Accessed May 2023).

The Program shall provide health care services appropriately delivered through telehealth to Program recipients regardless of the location of the Program recipient at the time telehealth services are provided and allow a distant site provider to provide health care services to a Program recipient from any location at which the health care services may be appropriately delivered through telehealth.

SOURCE: MD General Health Code 15-141.2(b). (Accessed May 2023).

MassHealth lists specific codes that may be used by community health centers for services delivered through telehealth.

SOURCE: MassHealth, Community Health Center Manual, Service Codes and Descriptions, 1/1/23, (Access Aug. 2023).

See: MA Medicaid Live Video Distant Site

Clinics are also permitted to submit for reimbursement telemedicine services (using simultaneous audio/visual technologies) per bulletin MSA 20-09 if all other provisions of telemedicine policy are maintained. Simultaneous audio/visual telemedicine services, as indicated by CPT/HCPCS codes listed on the telemedicine fee schedule and considered qualifying visits, will also be considered face-to-face and will trigger the PPS/AIR if the service billed is listed as a qualifying visit.

Federally Qualified Health Center (FQHC)/Rural Health Clinic (RHC)/Tribal Health Center (THC)/ Tribal Federally Qualified Health Centers (Tribal FQHC) Considerations – PT, OT and ST, when provided in accordance with this policy using both audio/visual modalities, will be considered face-to-face and will trigger the PPS AIR if the service billed is listed as a qualifying visit. For FQHCs, RHCs, THCs and Tribal FQHCs, the appropriate CPT/HCPCS code, PPS/AIR payment code (if the service generates a Qualifying Visit), and modifier 95 – synchronous telemedicine must be used. Refer to www.michigan.gov/medicaidproviders >> Provider Specific Information for additional information.

SOURCE:  MI Dept. of Health and Human Services., Bulletin 23-10, Telemedicine Policy Post-COVID PHE, Mar. 2, 2023, (Accessed Sept. 2023).

All current Medicaid policy for telemedicine services, including definitions requirements and parameters of telemedicine apply to FQHCs and RHCs. FQHCs and RHCs are responsible for ensuring compliance with all telemedicine policy within the Medicaid provider manual and any applicable supplemental Medicaid policy bulletins.

Distant site services, provided by qualified Medicaid enrolled practitioners, may be covered when the qualified practitioner is employed by the clinic or working under the terms of a contractual agreement with the clinic. FQHCs and RHCs must maintain all practitioner contracts and provide them to MDHHS upon request.

During the Medicaid provider enrollment process contracted providers must associate to the FQHC or RHC billing national provider identifier. Refer to the billing and reimbursement for institutional providers chapter of the Medicaid provider manual for further information.

Telemedicine service(s) provided at the distant site that qualify as a face-to-face visit may generate the PPS payment. All current PPS rules and encounter criteria apply to telemedicine visits.

If both originating and distant sites submit identical procedure codes for a telemedicine visit for the same beneficiary on the same date of service it is considered a duplicate billing. MDHHS will recover payment from the appropriate FQHC, RHC or contracted provider. Recovery will be based on the terms specified in the contract.

SOURCE:  MI Dept. of Health and Human Services. Bulletin 20-09, General Telemedicine Policy, Mar. 12, 2020, [Provider Bulletin 23-10 indicates policy is permanent] & Dept. of Health and Human Services Medicaid Provider Manual, p. 2127, Jul. 1, 2023 (Accessed Sept. 2023).

Claims for telemedicine services must be submitted using the ASC X 12N 837 5010 form using the appropriate telemedicine HCPCS or CPT code. All telemedicine claims must include the corresponding modifier 95- “Synchronous Telemedicine Service rendered via a real-time interactive audio and video telecommunications system” or 93 – “Synchronous Telemedicine Service rendered via telephone or other real-time interactive audio-only telecommunications system” and the appropriate revenue code.

SOURCE: Dept. of Health and Human Services Medicaid Provider Manual, p. 2127, Jul. 1, 2023 (Accessed Sept. 2023).

A Tribal facility may choose to enroll as a Tribal FQHC and be reimbursed for outpatient face-to-face visits within the FQHC scope of services provided to Medicaid beneficiaries, including telemedicine and services provided by contracted employees. Tribal FQHCs are eligible to receive the IHS outpatient AIR for eligible encounters.

SOURCE: Dept. of Health and Human Services Medicaid Provider Manual, p. 2171, Jul. 1, 2023 (Accessed Sept. 2023).

An FQHC can be either an originating or distant site for telemedicine services.

SOURCE: MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 750, Jul. 1, 2023 (Accessed Sept. 2023).

See: MI Medicaid Live Video Distant Site

Face-to-face service includes telehealth services provided by an eligible provider

SOURCE: MN Department of Human Services, Federally Qualified Health Center and Rural Health Center, Revised Jan. 10, 2022. (Accessed Jun. 2023).

Telehealth visits provided through audio and visual communication or accessible video-based platforms may be used to satisfy the face-to-face requirement for reimbursement under the payment methods that apply to a federally qualified health center, rural health clinic, Indian health service, 638 tribal clinic, and certified community behavioral health clinic, if the service would have otherwise qualified for payment if performed in person.

SOURCE: MN Statute 256B.0625. (Accessed Jun. 2023).

Federally Qualified Healthcare Clinics (FQHC)

FQHC providers must remove originating site charges and payments for telemedicine services from their year-end cost reports.

FQHC providers must leave the Rendering Provider ID field (24j on CMS-1500) blank on their claims when billing the Q3014 originating site facility charge.

FQHC Cost Reporting: Distant Site

The telemedicine charges and costs, including the depreciation cost for equipment, are allowed on the FQHC cost report.

The clinic must have medical records in their clinic for the person being seen to be able to report these charges on their cost report. If the person being seen is not one of the clinic’s patients, all costs will need to be removed from the cost report.

SOURCE: MO HealthNet Telemedicine Billing PPT, Education and Training Unit, Revised July 2022, (Accessed Sept. 2023).

See:  MO Medicaid Live Video Distant Site

No direct reference to whether or not FQHCs can be eligible distant site providers.

See: MT Medicaid Live Video Eligible Providers

FQHC and RHC payment for telehealth services is the Medicaid rate for a comparable in-person service. FQHC & RHC core services provided via telehealth are not covered under the encounter rate.

SOURCE: NE Admin. Code Title 471, Sec. 29-004.05, Ch. 29. (Accessed Aug. 2023).

See: NE Medicaid Live Video Distant Site

See: NV Medicaid Live Video Eligible Providers

Not listed as eligible distant site, however there is no restriction on eligible distant sites according to statute.

SOURCE: NH Revised Statutes 167:4-d (Accessed Jul. 2023).

See: NH Medicaid Live Video Distant Site

For the provision of services, providers are expected to follow the same rules they would follow if the patient visit was face-to-face. This includes instances when a license is for an entity such as an independent clinic (which includes FQHC). This license is for a specific address and is not tied to specific personnel. In this instance, the service may only be billed when provided at the address listed on the license. When billed by the clinic, the service provider (for example a physician) may provide services from a remote location but the patient must receive those services while physically present at the independent clinic (licensed location). Independent practitioners have a person specific license that is not tied to a specific address. Services billed by independent practitioners do not have location restrictions. The patient and/or the provider may be at any location as long as the provider is licensed to practice in New Jersey.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter Vol. 28, No. 17, Sept. 2018, p. 2 (Accessed Aug. 2023).

See: NJ Medicaid Live Video Distant Site

An originating clinical service fee is billed at the encounter rate.

SOURCE: NM Behavioral Health Policy and Billing Manual for Providers, pg. 30, (Accessed Jun. 2023).

All specialized behavioral health services provided within the HRSA-approved scope of practice of the FQHC will be paid using the prospective payment system rate.

SOURCE: NM Behavioral Health Policy and Billing Manual for Providers, pg. 33, (Accessed Jun. 2023).

See:  NM Medicaid Live Video Distant Sites

Any secure site within the fifty United States (U.S.) or U.S. territories, is eligible to be a distant site for delivery and payment purposes, including Federally Qualified Health Centers (FQHCs) and providers homes, for NYS Medicaid-enrolled patients. To receive reimbursement from NYS Medicaid, providers submitting telehealth claims or encounters must be NYS-licensed and enrolled in NYS Medicaid.

SOURCE: NY Dept. of Health, Medicaid Update, Vol. 39, Number 3, February 2023, p. 3. (Accessed June 2023).

The distant site is the location from which the provider furnishes the telehealth, virtual communications, or remote patient monitoring services. There are no restrictions on distant sites. Distant sites may be wherever the provider may be located. Provider(s) shall ensure that beneficiary privacy is protected (such as taking calls from private, secure spaces; using headsets).

Telehealth is the use of two-way real-time interactive audio and video to provide and support health care services when participants are in different physical locations. Federally Qualified Health Centers (FQHCs), FQHC Look-Alikes and Rural Health Centers (RHCs) are considered eligible distant sites and shall follow the coding and billing guidelines in Attachment A below.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1H, Telehealth, Virtual Communications and Remote Patient Monitoring, Jun. .2, 2023. (Accessed Jul. 2023).

Core Visit Services: Federally Qualified Health Center (FQHC) and Rural Health Clinic (RHC) core service providers may deliver core services via telehealth if the service is:

• Defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics; and,
• Covered as a telehealth-eligible core visit service in Attachment A, Section C.1 of this policy.

Non-Core Visit Services: FQHCs and RHCs may also deliver a select set of services via telehealth, virtual patient communications, and remote patient monitoring that are not
defined as a core visit service in Section 5.3 of Clinical Coverage Policy 1D-4: Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics. FQHCs and RHCs would be reimbursed on a fee-for-service basis for delivering non-core visit services via telehealth, virtual patient communications, or remote patient monitoring. See Attachment A, Section C.1 of this policy for further guidance for billing virtual patient communications and remote patient monitoring codes.

Please refer to Clinical Coverage Policy 1-H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring for a list of other related clinical coverage policies that include telehealth, virtual patient communications and remote patient monitoring-eligible non-core visit services that may be delivered by eligible providers at an FQHC or RHC.

Core Services: Core visit services delivered via telehealth are billed under the FQHC and RHC provider number using the HCPCS code T1015 (clinic visit/encounter, all-inclusive), T1015-HI (for behavioral health services), or T1015-SC (subsequent sick visit) and appended with the GT modifier. Eligible providers include all core service providers as defined in Section 3.2.1 of this policy, which includes physicians, physician assistants, nurse practitioners, nurse midwives, clinical psychologists, clinical social workers, licensed psychological associates, licensed clinical mental health counselors, licensed marriage and family therapists, advance practice nurse specialists, clinical nurse specialists, and licensed clinical addiction specialists.

Hybrid Telehealth with Supporting Home Visit: In addition, FQHC and RHC core service providers may conduct telehealth visits with a supporting home visit by a delegated staff member (“hybrid model”) with new or established patients and bill using HCPCS code T1015 (or T1015-HI, T1015-SC), for a range of scenarios including (but not limited to) chronic disease management and perinatal visits.  See manual for additional guidance.

Telehealth Claims: Modifier GT must be appended to the CPT or HCPCS code to indicate that a service has been provided via interactive audio-visual communication. This modifier is not appropriate should not be used for virtual patient communications (including telephonic evaluation and management services) or remote patient monitoring.

SOURCE: NC Div. of Medical Assistance, Medicaid and Health Choice Manual, Clinical Coverage Policy No: 1D-4, Core Services Provided in Federally Qualified Health Centers and Rural Health Clinics, p. 19, Dec. 1, 2020. (Accessed Jul. 2023).

See: NC Medicaid Live Video Eligible Providers

FQHCs and RHCs

When providing telehealth services to patients located in their homes or another facility, FQHCs and RHCs should continue to bill the revenue codes listed in the FQHC and RHC portions of this manual along with the CPT® or HCPCS code for the service rendered appended with modifier GT or 95.

SOURCE: ND Medicaid General Information Provider Manual, May 2023, pg. 158, (Accessed Jun. 2023).

See: ND Medicaid Live Video Eligible Providers

See: OH Medicaid Live Video Distant Site

Not listed as eligible distant site.

See: OK Medicaid Live Video Distant Site

OR Medicaid requires providers to be enrolled and meet certain requirements.  They also state that the distant site can be any location in which appropriate privacy and confidentiality is ensured, however no explicit reference is made to FQHCs.

See: OR Medicaid Live Video Distant Site

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health  Clinics”(https://www.dhs.pa.gov/providers/QuickTips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Sept. 2023).

Telepsychiatry Services – Only applicable to Behavioral Health Managed Care delivery system claims and not fee-for-service delivery. Mental health services are provided through the use of approved electronic communication and information technologies to provide or support clinical psychiatric care at a distance. Qualifying telepsych services utilize real-time, two-way interactive audio-video transmission, and do not include a telephone conversation, electronic mail message, or facsimile transmission between a health care practitioner and a service recipient, or a consultation between two healthcare practitioners, although these activities may support the delivery of telepsych services. Telepsych services require service providers to have a service description approved by the Office of Mental Health and Substance Abuse Services (OMHSAS) and deliverable through the managed care option.

SOURCE: PA PROMISe, 837 Professional/CMS-1500 Claim Form, Provider Handbook, Appendix E – FQHC/RHC. p. 10 (Apr. 22, 2014). (Accessed Sept. 2023).

I work as a licensed professional at a Federally Qualified Health Center (FQHC). Will I be able to bill for services delivered via telemedicine after October 31, 2022?

Yes, as clarified in MA Bulletin 99-22-02 (NOTE: Bulletin 99-22-02 has been replaced by 99-23-08) telemedicine remains a mode of service delivery that providers can utilize.  Providers that are licensed by the Office of Mental Health and Substance Abuse Services should refer to bulletin OMHSAS-22-02 – Revised Guidelines for Delivery of BH Services Through Telehealth 7.1.22.pdf (pa.gov) when rendering the behavioral health services for which they are licensed.  In addition, DHS recently issued MA Bulletin 08-22-13, 27-22-07 related to tele dentistry services that is also relevant to FQHC providers that offer dental services.

See: PA Medicaid Live Video Distant Site

No reference found.

An encounter must include a face-to-face or telemedicine (telephone-only and tele video services) visit with a physician (including optometrists and psychiatrists), physician assistant, nurse practitioner (advanced practice registered nurses), clinical social worker, clinical psychologist, certified nurse midwife, clinical nurse specialist, licensed mental health counselor, licensed marriage and family therapist, dentist or registered dental hygienist.

SOURCE:  RI Executive Office of Health and Human Services, Principles of Reimbursement for FQHCs, Aug. 2022, pg. 5-6, (Accessed May 2023).

Law requires that all medically necessary and clinically appropriate telemedicine services delivered by in-network primary care providers, registered dietitian nutritionists and behavioral health providers be reimbursed at a rate not lower than services provided in-person. No explicit reference is made to FQHCs.

See: RI Medicaid Live Video Eligible Providers

The RHCs and FQHCs would bill an encounter code when operating as the consulting site. Only one encounter code can be billed for a DOS. Both provider types will use the appropriate encounter code for the service along with the “GT” modifier (via interactive audio and video telecommunications system) indicating interactive communication was used.

SOURCE: SC Health and Human Svcs. Dept. Physicians Provider Manual, p. 215 (Jul. 2023). (Accessed Aug. 2023).

A consultant site means the site at which the specialty physician or practitioner providing the medical care is located at the time the service is provided via telehealth. The health professional providing the medical care must be currently and appropriately licensed in South Carolina. FQHC and RHC providers are eligible to serve as consulting site providers for telehealth services.

SOURCE: SC Health and Human Svcs. Dept. Physicians Provider Manual, p. 32 (Jul. 2022). (Accessed Aug. 2023).

Federally Qualified Health Centers (FQHC) and Rural Health Centers (RHC) will continue to be eligible for reimbursement for services rendered via telehealth. When billing for any telehealth procedure code, providers must submit claims with a GT modifier. If a code requires any other billing modifiers when submitting claims, the GT modifier should be listed after any other modifiers.

SOURCE: SC Dept. of Health and Human Services. Medicaid Bulletin 23-018. (May 2023). (Accessed Aug. 2023).

FQHC/RHCs are eligible to serve as an originating site for telemedicine services and may also provide distant site telemedicine services. An originating site is the physical location of the Medicaid recipient at the time the service is provided. A distant site is the physical location of the practitioner providing the service via telemedicine. Please refer to the Telemedicine manual for additional information.

SOURCE: SD Medicaid Billing and Policy Manual, FQHC and RHC Services, Jun. 2023, (Accessed Aug. 2023).

The following providers can provide services via telemedicine at a distant site:

• Federally Qualified Health Center (FQHC)

SOURCE: SD Medicaid Billing and Policy Manual: Telemedicine, p. 1 (Jun. 2023), (Accessed Aug. 2023),

See: SD Medicaid Live Video Distant Site

A provider-based telemedicine provider who seeks to contract with or who has contracted with a health insurance entity to participate in the health insurance entity’s network is subject to the same requirements and contractual terms as any other healthcare services provider in the health insurance entity’s network.

SOURCE:  TN Code Annotated, Sec. 56-7-1003, (Accessed Aug. 2023).

A telehealth provider who seeks to contract with or who has contracted with a health insurance entity to participate in the health insurance entity’s network shall be subject to the same requirements and contractual terms as a healthcare services provider in the health insurance entity’s network.

SOURCE:  TN Code Annotated, Sec. 56-7-1002, (Accessed Aug. 2023).

“Healthcare services provider” means an individual acting within the scope of a valid license issued pursuant to title 63 or title 68, chapter 24, part 6, or any state-contracted crisis service provider employed by a facility licensed under title 33 .

SOURCE:  TN Code Annotated, Sec. 56-7-1002 & 1003, (Accessed Aug. 2023).

See: TN Medicaid Live Video Distant Site

• FQHC practitioners may be employees of the FQHC or contracted with the FQHC

SOURCE:  TX Medicaid Telecommunication Services Handbook, p. 12 (Aug. 2023). (Accessed Aug. 2023).

Telemedicine eligible distant site providers are enrolled as a Texas Medicaid provider and are a:

• Federally Qualified Health Center (FQHC)

SOURCE: TX Medicaid Telecommunication Services Handbook, p. 8 (Aug. 2023) (Accessed Aug. 2023).

See: TX Medicaid Live Video Distant Site

Not mentioned explicitly, however state does not have a specific provider list.

See: UT Medicaid Live Video Eligible Providers

A distant site is defined broadly to mean the location of a health care provider delivering services through telemedicine at the time the services are provided. However, there is no explicit reference to FQHCs.

See: VT Medicaid Live Video Eligible Providers.

No reference found.

Telehealth services may be included in a Federally Qualified Health Center (FQHC), Rural Health Clinic (RHC), or Indian Health Center (IHC) scope of practice, as approved by HRSA and the Commonwealth. If approved, these facilities may serve as the Provider site and bill under the encounter rate.

SOURCE:  VA Dept. of Medical Assistant Svcs., Medicaid Provider Manual Supplement-Telehealth Services (Available in multiple manuals, including physician/practitioner, see overview for full list), (Oct. 2022) (Accessed Aug. 2023).

See: VA Medicaid Live Video Distant Site

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FQHCs may now serve as a distant site for Telehealth consultations by a psychiatrist or psychologist only and be reimbursed at the encounter rate. The distant-site practitioner must bill the appropriate Current Procedural Technology/Healthcare Common Procedure Coding System (CPT/HCPCS) code with the appropriate Place of Service on a HCFA1500 form.

SOURCE: WV Dept. of Health and Human Svcs. Medicaid Provider Manual. Chapter 522.8 Federally Qualified Health Center and Rural Health Clinic Svcs. P. 9. (July 1, 2019); WV Dept. of Health and Human Svcs. Medicaid Provider Manual, Chapter–519.17 Practitioner Services: Telehealth Services., p. 3 (Effective Jan. 1, 2022). (Accessed May 2023).

See: WI Medicaid Live Video Distant Site

Not explicitly listed on eligible provider list.

See: WY Medicaid Live Video Eligible Providers