The 2026 MPFS Final Rule: A Pivot Point for Digital Health in RHCs and FQHCs
If you are a digital health company selling into Rural Health Clinics (RHCs) or Federally Qualified Health Centers (FQHCs), your product roadmap may need some changes for 2026.
On October 31, 2025, CMS released the CY 2026 Medicare Physician Fee Schedule (MPFS) Final Rule. With this Rule, CMS has quietly, but fundamentally, rewired how safety net providers get paid for care between office visits.
For innovators powering virtual check-ins, chronic care management (CCM), and behavioral health integration, this is a structural shift from "bundled" codes and payments to granular billing.
Here is what digital health companies need to know when serving FQHC and RHC clinics in 2026.
1. No more "Catch-All" codes: G0071 and G0512 are Going Away
For years, RHCs and FQHCs used simplified "catch-all" G-codes to bill for virtual and collaborative care services. As of January 1, 2026, CMS is retiring these bundles in favor of specific CPT/HCPCS coding.
What Changed?
G0071 is discontinued. You can no longer use this single code for Virtual Communication Services.
G0512 is discontinued. You can no longer use this bundle for Psychiatric Collaborative Care (CoCM).
Instead of a single code, your software must now capture and bill the individual underlying codes. This requires your platform to support more granular data capture to justify the specific services rendered.
2. Virtual Check-Ins: Hard Code CPT 98016
If your platform supports asynchronous messaging, image evaluation, or brief virtual check-ins, you likely relied on G2012 (bundled into G0071).
The Change: CMS has replaced G2012 with CPT 98016 (Brief communication technology-based service).
The Action Item: Re-map G2012 to CPT 98016 (and G2010 to G2250 for remote evaluation of images/video) to ensure RHC/FQHCs get paid.
3. "Care Management" = "Care Coordination"
This change may be the biggest win for digital health adoption in the safety net. CMS has effectively removed the ambiguity around which care management services are reimbursable for RHCs/FQHCs.
Now, any service designated as a "Care Management" service under the standard MPFS is now automatically treated as a reimbursable Care Coordination service for RHCs and FQHCs.
Reimbursement is now standardized and paid separately for:
Chronic Care Management (CCM)
Remote Patient Monitoring (RPM) & Remote Therapeutic Monitoring (RTM)
Behavioral Health Integration (BHI)
Community Health Integration (CHI) & Principal Illness Navigation (PIN)
Advanced Primary Care Management (APCM)
This means you no longer have to explain if your service is covered; you just need to demonstrate that it meets the standard MPFS care management requirements (time spent, clinical supervision, device used etc.).
4. Behavioral Health: The New APCM Add-Ons
CMS is doubling down on Advanced Primary Care Management (APCM) by integrating behavioral health directly into the model.
If your platform supports integrated care, you need to map these three new add-on codes effective Jan 1, 2026:
G0568: Initial Collaborative Care Model (CoCM) month for APCM patients.
G0569: Subsequent CoCM months for APCM patients.
G0570: General BHI services for APCM patients.
Key Takeaway
The shift from bundled G-codes to granular CPT codes will mean changes for digital health platforms and their FQHC/RHC customers who provide these services. Digital health vendors will need to audit their code logic, map the new codes, and educate their customers on these important changes.
Please contact Nixon Law Group for help restructuring your contracts or compliance workflows for 2026.