CMS Deadline for FQHC and RHC Billing Changes in 2025
By September 30, 2025, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) must stop billing care coordination services under HCPCS code G0511. After this deadline, only the new individual CPT and HCPCS codes for each service will be accepted. For organizations ready sooner, the new reporting requirements take effect on January 1, 2025. Transitioning early can help health centers capture reimbursement opportunities right away.
2025 CMS Care Coordination Services Covered for FQHCs and RHCs
The 2025 update expands the range of reimbursable care coordination services for FQHCs and RHCs. Health centers will now report individual codes and receive payment for:
- Advanced Primary Care Management (APCM)
- Transitional Care Management (TCM)
- Chronic Care Management (CCM)
- Principal Care Management (PCM)
- Chronic Pain Management (CPM)
- Behavioral Health Integration (BHI)
- Remote Physiologic Monitoring (RPM)
- Remote Therapeutic Monitoring (RTM)
- Community Health Integration (CHI)
- Principal Illness Navigation (PIN)
- Principal Illness Navigation Peer-Support (PIN-PS)
Each of these services will be reimbursed at the national non-facility Physician Fee Schedule (PFS) rate, aligning FQHC and RHC reimbursement with broader Medicare billing standards.
When FQHCs and RHCs Must Stop Using G0511
- January 1, 2025 – New CPT and HCPCS codes become available for billing.
- Through September 30, 2025 – Facilities may continue billing with G0511 if they need more time to update systems.
- After October 1, 2025 – Only individual CPT and HCPCS codes will be accepted, and G0511 will no longer be valid.
Revenue Cycle Impact of Replacing G0511 for FQHCs and RHCs
This policy change has direct implications for both reimbursement strategy and revenue cycle operations. Key impacts include:
- More accurate reimbursement because services are tied to individual CPT or HCPCS codes.
- Expanded billing opportunities through services such as APCM, CHI, and PIN.
- Operational changes required as billing systems and staff workflows are updated.
- Compliance risks for organizations that fail to fully transition by the September 30, 2025 deadline.
How FQHCs and RHCs Can Prepare for the 2025 CMS Billing Deadline
To ensure compliance and protect reimbursement, FQHC and RHC leaders should:
- Update billing and EHR systems to support the new CPT and HCPCS codes.
- Train billing and clinical staff on accurate coding and documentation requirements.
- Review care coordination programs to identify where new services can generate additional revenue.
- Set a transition timeline to either adopt the new codes on January 1 or use the grace period before the September 30 deadline.
The September 30, 2025 CMS billing deadline requires health centers to act now. Updating billing systems, preparing staff, and taking advantage of new care coordination opportunities will safeguard revenue and strengthen financial sustainability.
FAQs on the 2025 CMS Billing Update for FQHCs and RHCs
What replaces G0511 for FQHCs and RHCs in 2025?
Starting January 1, 2025, G0511 will be replaced by reporting individual CPT and HCPCS codes for care coordination services such as CCM, TCM, RPM, and more.
What is the deadline to stop using G0511?
The final date to bill under G0511 is September 30, 2025. After that, only individual codes will be accepted.
How will the G0511 change affect FQHC and RHC revenue cycle management?
The update allows for more precise reimbursement and expands billable services, but requires system updates and staff training to avoid claim denials.