NGS Telehealth Services Update for FQHCs and RHCs: Virtual Communication Services

Meaningful Use Audits Are Coming: Is Your Organization Ready?
Co-authored by Dianne Rodrigue

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)

On March 25, 2020, National Government Services (NGS) hosted a webinar related to Telehealth Services during this time of COVID-19.  It was clarified that at this point, The Centers for Medicare and Medicaid Services (CMS) has not made changes to the RHC and FQHC telehealth guidelines.  Neither RHC nor FQHC organizations can provide telehealth services as a distant site, as geographic and site restrictions still apply.  However, they can serve as the originating site for telehealth services, and can bill for Virtual Communication Services.

Virtual Communication Services:

  • Require at least 5 minutes of communication, or technology-based, or remote evaluation services.
  • Services must be provided by an RHC or FQHC practitioner who has had an FQHC or RHC billable visit within the previous year.
  • Discussion or evaluation must not be related to an FQHC or RHC service provided within the previous 7 days, and/or does not lead to an FQHC or RHC visit within the next 24 hours (or the soonest available appointment).
  • Use code G0071: Communication Services by RHC/FQHC 5 min: Payment for communication technology-based services for 5 minutes or more of a virtual (non-face-to-face) communication between an RHC or FQHC practitioner and RHC or FQHC patient, or 5 minutes or more of remote evaluation of recorded video and/or images by an RHC or FQHC practitioner, occurring in lieu of an office visit; RHC or FQHC only.
  • Payment rate is set at the average (PFS) non-facility payment rate for HCPCS codes G2012 and G02010. FQHCs and RHCs should not use codes G2012 and G2010.  Claims containing these codes will not be paid.



Eric Wetherell, CPA: Principal and Healthcare Advisory Group Lead

Gina Hobert, MBA, CHC, CPC-I, CEMC, CRC, CPMA:  Senior Manager

Dianne Rodrigue, PA, MHP, CCDS, CRC, CPC: Senior Manager

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.

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