The FQHC/RHC Mental Health Telehealth Confusion: When Policy and Guidance Don’t Align 

By Elizaveta Bannova, WCH Billing Department 

On October 31, 2025, the Centers for Medicare and Medicaid Services released the final rule for the 2026 Physician Fee Schedule. Buried in the 3,000-plus pages of policy updates was a change that has created significant confusion for Federally Qualified Health Centers and Rural Health Clinics: the reinstatement of in-person visit requirements for mental health services delivered via telehealth. 

The confusion stems not from the policy itself, but from conflicting guidance about when it actually takes effect. And for FQHCs and RHCs trying to maintain access to behavioral health services for Medicare beneficiaries in underserved communities, the ambiguity isn’t academic—it affects whether they can bill for services provided starting October 1, 2025. 

Read more: The FQHC/RHC Mental Health Telehealth Confusion: When Policy and Guidance Don’t Align