Stay current with 2026 FQHC policy updates, including PPS rates, APCM codes, RPM expansion, telehealth rules, and key billing changes.
The 2026 Medicare Physician Fee Schedule Final Rule delivered more FQHC-specific policy changes than any single rule in recent years - retiring legacy codes, introducing new billing pathways, updating PPS rates, and expanding telehealth and remote monitoring access. For FQHC administrators, billing teams, and clinical leadership, the changes are not optional adjustments. Several became mandatory on January 1, 2026.
At a Glance: 2026 FQHC Policy Changes That Took Effect January 1
Update 1: G0511 Is Gone - What Replaces It
The most operationally significant change for most FQHCs is the mandatory retirement of G0511 - the bundled care management code used by RHCs and FQHCs since 2020.
G0511 (care management) is no longer reportable as of January 1, 2026. FQHCs and RHCs must now report the individual codes that make up what G0511 previously bundled - including CCM, PCM, and behavioural health integration services - each billed separately under their standard CPT codes.
What G0511 previously covered, now billed individually:
- CCM: CPT 99490, 99439, 99487, 99489
- PCM: CPT 99424, 99425, 99426, 99427
- BHI: CPT 99484
- Collaborative Care Model: CPT 99492, 99493, 99494
FQHCs struggling to generate enough revenue following the G0511 sunset can offset losses by billing APCM with BHI or CoCM add-on codes, and reporting G0512 and G0071 individually - creating new revenue capture that the bundled code did not support.
For FQHCs building or rebuilding CCM workflows under the individual code structure, understanding what CCM services include and how monthly billing is structured under each CPT code is the foundational step in reconfiguring billing operations post-G0511.
Update 2: G0071 Retired - CTBS and Remote Evaluation Now Reported Separately
G0071 is no longer reportable beginning January 1, 2026. FQHCs must now report the individual codes that make up Communications Technology-Based Services (CTBS) and Remote Evaluation Services separately.
Individual codes replacing G0071:
- G2012 – Brief communication technology-based service (5–10 minutes)
- G2010 – Remote evaluation of recorded video/images
- G2252 – Virtual check-in, 11–20 minutes
- G2010 / G2252 - now billed independently, not bundled
Billing compliance note: Each code has its own documentation, time, and consent requirements. FQHCs transitioning from G0071 must ensure clinical workflows capture the specific service type and duration for each patient contact - not aggregate them under the former bundled code.
Update 3: New APCM Add-On Codes for BHI and CoCM
CMS finalised, allowing RHCs and FQHCs to use optional add-on codes for APCM to bill for BHI and CoCM services when providing advanced primary care. Effective January 1, 2026, RHCs and FQHCs are required to report HCPCS codes G0512 and G0071 individually for both CoCM and Communications Technology-Based Services.
Three APCM add-on codes available:
- G0558 – BHI add-on to APCM (general behavioural health integration)
- G0559 – CoCM add-on to APCM (psychiatric collaborative care, first 70 minutes)
- G0560 – CoCM add-on to APCM (each additional 30 minutes)
FQHCs should evaluate whether to bill APCM with add-on codes, continue billing separate care management and behavioural health services, or use a combination - based on patient mix and operational capacity. CMS did not classify APCM or behavioural health services as preventive, which has implications for cost-sharing and patient eligibility.
For FQHCs integrating behavioural health alongside chronic care management programs, the APCM add-on structure reduces the time-tracking burden for concurrent BHI documentation - a meaningful operational improvement over separate program billing.
Update 4: RPM and RTM Now Billable Concurrent With APCM
FQHCs and RHCs can now report Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) codes separately during the same month they report APCM, when a patient receives both services. This is a new concurrent billing pathway - previously, bundled code structures limited how FQHCs could layer monitoring services with care management.
2026 RPM codes now available to FQHCs:
Per CMS FQHC PPS guidance, care coordination services may be billed alone or alongside other payable services - and face-to-face encounters are not required for care coordination billing. Understanding how the 2026 CMS RPM and CCM code changes apply to FQHCs is essential before configuring concurrent billing workflows for monitoring alongside APCM.
Update 5: PPS Base Rate and IOP Rate Updates
CMS annually updates the FQHC PPS base payment rate using the FQHC market basket. The rate is increased by 34.16% when a patient is new to the FQHC, or when an Initial Preventive Physical Exam (IPPE) or Annual Wellness Visit (AWV) is furnished.
Effective January 1, 2026, CMS updated the FQHC PPS base payment rate, Geographic Adjustment Factors (GAFs), and payment rates for Intensive Outpatient Program (IOP) services for FQHCs.
What FQHCs must verify with their MAC:
- Updated PPS base rate applied correctly from January 1, 2026
- Geographic Adjustment Factors reflecting 2026 locality pricing
- IOP service rates updated per the December 2025 Change Request (CR 14309)
- Tribal FQHC PPS rate updated per CR 14349 (effective March 6, 2026)
For the most current FQHC PPS rate and payment methodology, visit the CMS FQHC Centre page - the authoritative source for annual rate tables and billing instructions, updated with each rule cycle.
Update 6: Telehealth Extensions for FQHCs
For non-behavioural health services provided via telecommunications technology, RHCs and FQHCs may report HCPCS code G2025 on claims through December 31, 2026. This extends the telehealth billing pathway for non-behavioural health virtual services for one additional year - but FQHCs should note this is a temporary extension, not a permanent policy.
Telehealth billing rules for FQHCs in 2026:
- Behavioural health telehealth: permanently extended; patient's home is an eligible originating site
- Non-behavioural health telehealth: G2025 available through December 31, 2026
- Virtual direct supervision: permanently allowed for services furnished virtually
- Audio-only mental health: reimbursable under specific eligibility conditions with documented patient consent
What FQHCs Should Do Before Mid-Year
The billing and compliance actions required by these changes should not wait until the next annual review cycle. FQHCs that have not completed these transitions are currently at risk of claim denials, underpayment, and audit exposure:
- Confirm G0511 and G0071 are deactivated in billing systems - continued use generates automatic rejections
- Map each G0511 component to its individual CPT code and confirm that each code's documentation requirements are met independently
- Evaluate APCM vs. separate program billing for the BHI and CoCM patient populations
- Configure RPM concurrent billing alongside APCM for eligible chronic disease patients - this is new revenue available immediately
- Verify the 2026 PPS base rate with your Medicare Administrative Contractor and audit any claims processed at the 2025 rates
- Review telehealth G2025 expiry and plan for December 31, 2026, sunset
For FQHCs scaling care coordination programs across multiple sites, how multi-facility RPM and CCM operations handle concurrent billing compliance is directly relevant - billing consistency across locations is the single most common compliance gap in multi-site FQHC operations.
Conclusion
2026 brought the most consequential set of FQHC-specific policy changes in several years - not incremental adjustments, but structural billing transitions that require active operational response. The G0511 sunset, individual CTBS code reporting, APCM add-on availability, and new RPM concurrent billing pathways together create both compliance obligations and new revenue opportunities. FQHCs that act on both sides of that equation - eliminating legacy code exposure while capturing new program revenue - will be better positioned financially and operationally as CMS continues shifting reimbursement toward value-based, coordinated care models.
Frequently Asked Questions
Q1. Can FQHCs still use G0511 for services delivered before January 1, 2026?
Yes. FQHCs can still bill G0511 for services provided before January 1, 2026, as long as claims are submitted within the allowed filing period. For services delivered on or after that date, G0511 is no longer valid, and claims must use the appropriate replacement billing codes.
Q2. Is APCM mandatory for FQHCs, or can they continue billing individual CCM codes?
APCM is optional. FQHCs may continue billing CCM, PCM, and BHI services separately if that approach better fits their workflow. Some organisations may prefer APCM because it simplifies care management, billing and administration.
Q3. Do FQHCs need separate patient consent for RPM when already enrolled in APCM?
Yes. RPM requires its own patient consent, even if the patient is already enrolled in APCM or another care management program. Consent must be documented separately in the patient's medical record before RPM services begin.
Q4. How does the 34.16% new patient rate increase work under the FQHC PPS?
FQHCs receive a 34.16% increase to the PPS base rate for qualifying new patient visits, IPPEs, and Annual Wellness Visits. This increase applies to each eligible encounter and can help improve reimbursement when coded correctly.
Q5. What happens if an FQHC submits G0071 on a 2026 claim?
Claims containing G0071 for dates of service in 2026 will be rejected. FQHCs must bill the individual service codes that replaced G0071 and resubmit the claim within the timely filing period to receive payment.
Q6. Can FQHCs bill both APCM add-on codes and separate RPM codes for the same patient in the same month?
Yes. CMS allows RPM and APCM services to be billed together when documentation and clinical time are tracked separately. Proper recordkeeping is essential to avoid duplicate billing and maintain compliance.
Q7. Where can FQHCs access the most current PPS rate tables and billing instructions?
The CMS FQHC Centre page is the authoritative source for current PPS base rates, Geographic Adjustment Factors, billing instructions, and claim submission guidance. The CMS FQHC MLN fact sheet (updated March 2026) provides the most current billing rules in a single reference document.