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2025 Medicare Physician Fee Schedule Final Rule: Key Changes for Rural Health Clinics (RHC) and Federally Qualified Health Centers (FQHC)

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2025 Medicare Physician Fee Schedule Final Rule: Key Changes for Rural Health Clinics (RHC) and Federally Qualified Health Centers (FQHC)

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Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) are vital to our healthcare system, providing essential services to underserved, rural, and low-income populations. Recent updates from the Centers for Medicare & Medicaid Services (CMS) aim to enhance their role as frontline care providers, particularly for uninsured individuals. Here are the main changes set to take effect in 2025.

Care Management Services

CMS will transition from requiring RHCs and FQHCs to report the single HCPCS code G0511 for general care management to utilizing individual CPT and HCPCS codes that more accurately reflect the services provided. This change will allow the billing of add-on codes related to care management and will introduce Advanced Primary Care Management (APCM) services, enabling RHCs and FQHCs to receive payments based on the national non-facility Medicare Physician Fee Schedule (MPFS). Payments will be issued in addition to the All-Inclusive Rate (AIR) for RHCs and the Prospective Payment System (PPS) for FQHCs.

Telecommunication Services

CMS is finalizing the allowance for direct supervision through interactive audio and video telecommunications, with the definition of “immediate availability” expanded to include real-time communication through December 31, 2025. Additionally, RHCs and FQHCs can temporarily report services delivered via telecommunication technology, including audio-only methods, using HCPCS code G2025 through the end of 2025. The in-person visit requirement for mental health services provided through communication technology will remain suspended throughout 2025.

Intensive Outpatient Programs (IOP) 

A new payment rate will be established for RHCs and FQHCs providing four or more services per day, expanding the current rate that applies only when three services are provided. This adjustment aims to align payments more closely with those in hospital outpatient departments.

Preventive Vaccines 

Effective July 1, 2025, RHCs and FQHCs will be able to bill for Part B preventive vaccines and their administration fees at the time of service rather than through the annual cost report. This change enhances the timeliness of payments, reflecting rates from other healthcare settings.

Dental Services 

Dental services that are inextricably linked to covered medical services will now be recognized as RHC and FQHC services, eligible for payment under the AIR and PPS. Additionally, dental services can be billed separately when they are inextricably linked to a medical visit on the same day. New operational requirements for claims to allow submitting the KX modifier will be effective July 1, 2025.

RHC Productivity Standards 

The outdated RHC productivity standards, last updated in 1982 and impacting AIR, will be removed for cost reporting periods starting on or after January 1, 2025.

FQHC Market Basket Revision 

The final update for the FQHC market basket in CY 2025 is set at 3.4%, reflecting a 4.0% increase from the 2022-based market basket, adjusted by 0.6 percentage points for productivity.

RHC Conditions for Certification 

Changes to RHC Conditions for Certification will clarify the requirement for primary care services rather than focus on being “primarily engaged” in such services. Additionally, the list of mandatory lab services will be updated to remove outdated tests and reflect modern lab techniques.
 


 

Published: 12/17/2024

Readers should not act upon information presented without individual professional consultation.

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

 

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Thomas B. Zetlmeisl, CPA, CFE, CFF, CGMA Nashville Managing Partner thomas.zetlmeisl@rubinbrown.com 314-290-3395

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