The South Central Region Virtual Visit Billing Guides have been updated with the most recent payor changes. Below is this announcement's most recent updates, or click on any state to go directly to that state's guide.
The quarterly updates for the Arkansas, Tennessee, and Mississippi Virtual Visit Billing Guides are now available! Payors were fairly quiet this past quarter, but with 2026 on the horizon, we can expect some shifts when CMS releases finalized 2026 telehealth guidance.
CMS has released the Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (CMS-1832-P), which includes several important telehealth changes detailed below. Remember, this is still a proposed rule, the final version will be published in November, and some details may change.
Medicare
- Reminder: Effective September 30, 2025- For care coordination services furnished by RHCs and FQHCs, bill the individual CPT and HCPCS base/add-on codes rather than G0511. CMS began this requirement on January 1, 2025 and allowed a transition period—initially through July 1, 2025, later extended through September 30, 2025. As of September 30, 2025, G0511 is no longer valid for billing.
- Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule (CMS-1832-P):
- Streamlined Process for the Medicare Telehealth Services List: Drop the “provisional vs. permanent” distinction; focus reviews on whether a service can be safely furnished via interactive two-way audio-video (not audio-only)
- Frequency Limits: Permanently eliminate visit frequency caps for subsequent inpatient, subsequent nursing facility, and critical care telehealth services
- Virtual direct supervision: Permanently allow direct supervision to be satisfied virtually via real-time audio-video for applicable services (e.g., incident-to, diagnostic tests, pulmonary rehab, cardiac rehab/ICR)
- Excludes procedures with 010/090 global periods; audio-only does not qualify.
- Teaching Physician Supervision: End the pandemic-era allowance for a teaching physician’s virtual presence across all settings and return to pre-PHE rules (physical presence required in MSAs for key portions)
- FQHCs/RHCs: Continue allowance of billing medical visits via telecommunications, including audio-only, by reporting G2025 through December 31, 2026
- Proposed updates to the Telehealth List:
- Add: 90849, G0473, G0545, 92622–92623.
- Remove: G0136 (SDOH risk assessment)
- Remote Monitoring: New RPM/RTM codes proposed for shorter episodes (<16 days data; <20 minutes/month)
- Digital Mental Health Treatment (DMHT): Clarifications to requirements and expanded device coverage (including certain ADHD devices)
Medicare Telehealth Coverage & Billing: Post-Expiration
On October 1, 2025, the federal government shut down after Congress failed to pass a FY 2026 spending bill. With that, the Medicare telehealth flexibilities, which had been extended throughout the pandemic, have officially expired. What This Means for Healthcare Providers:
Coverage Rules
- Patient Location (Originating Site)
- For non-behavioral or non-mental telehealth, there are now originating site requirements and geographic location restrictions
- Telehealth is only covered when patient is located in an approved healthcare facility (e.g., physician’s office, hospital, rural health clinic)
- Not covered if patient is at home (with limited exceptions for ESRD, substance use disorder, and mental health)
- For non-behavioral or non-mental telehealth, there are now originating site requirements and geographic location restrictions
- Eligible Providers
- Only Physicians, NPs, PAs, CNMs, CNSs, CRNAs, CPs, CSWs, RDs, nutrition professionals, MHCs, and MFTs may bill for telehealth
- Audiologists, OTs, PTs, and SLPs are no longer eligible
- Mental Health Telehealth
- For behavioral or mental services, all patients can continue to receive treatment via telehealth wherever they’re located, with no originating site requirements or geographic location restrictions.
- The patient’s home is a permissible originating site for services provided for diagnosing, evaluating, or treating
- In-person requirement has taken effect, must see patient in-person within 6 months before the first telehealth visit, and every 12 months thereafter
- CMS permanently allowed audio-only communication technology for any telehealth service furnished to a patient in their home, provided that the furnishing physician or practitioner is technically capable of using audio-video communication technology and that the beneficiary is not capable of or does not consent to using audio-video communication technology
- For behavioral or mental services, all patients can continue to receive treatment via telehealth wherever they’re located, with no originating site requirements or geographic location restrictions.
- RHCs/FQHCs
- Medical Telehealth:
RHCs and FQHCs may continue billing Medicare for telehealth services as distant site providers through December 31, 2025 utilizing HCPCS G2025
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- Mental Health Telehealth
- RHCs and FQHCs are permanently allowed to be a distant site provider for mental health telehealth
- Through December 1st, 2025 the in-person visit requirement is waived
- RHCs and FQHCs are permanently allowed to be a distant site provider for mental health telehealth
- Mental Health Telehealth
Billing & Claims Processing:
- Temporary Claims Hold
- CMS instructed Medicare Administrative Contractors (MACs) to place a hold on telehealth claims (effective Oct. 1).
- Providers may continue submitting claims, but payments are paused until Congress acts or CMS issues further instructions
- Advance Beneficiary Notice (ABN)
- CMS recommends considering ABNs when furnishing telehealth services that may not meet coverage requirements, to protect against nonpayment.
