The Upcoming 2026 FQHC / RHC Programs Transition to Physician Fee Schedule (PFS)-Based Codes

At 4:45 p.m., the front desk is closing out walk-ins and the schedule is already spilling into tomorrow. A behavioral health care manager pulls up a patient who has been slipping quietly: missed PHQ-9 follow-ups, a recent gap in medication fills, and two “no answer” outreach attempts logged in different places. Today, the patient finally picks up. The conversation is short but decisive: side effects, a new job schedule, worsening sleep, and a growing sense that “nothing is working.” The care manager coordinates a same-week primary care check-in, flags the case for psychiatric consultation, and resets the follow-up cadence so the next touchpoint is a plan, not a hope.

Clinically, this is the kind of between-visit work that prevents deterioration. Operationally, it is also the kind of work that can become vulnerable when billing “plumbing” changes, especially in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), where integrated care and virtual services have historically been represented through clinic-specific HCPCS “wrapper” codes rather than reported as the underlying Physician Fee Schedule (PFS) code families.

That is why the CY 2026 transition matters. CMS states that clinics must report the individual codes that make up both Psychiatric Collaborative Care Model (CoCM) services and certain Communications Technology-Based Services (CTBS) and Remote Evaluation Services previously reported under HCPCS G0512 and HCPCS G0071, and that G0512 and G0071 are no longer reportable beginning January 1, 2026.

If your organization isn’t ready (billing systems, charge master mappings, claim edits, templates, and staff workflows) you risk a preventable disruption in reimbursement continuity for services many clinics now consider essential. This is not only a revenue risk. It is a staffing sustainability risk: integrated behavioral health and care coordination capacity depends on predictable reimbursement, and unpredictable reimbursement is how programs shrink precisely when need rises.

This post is written for FQHC and RHC executives, clinical leaders, and revenue cycle teams. It clarifies what is changing (and what is not), then lays out an implementation strategy that protects continuity, reduces denial risk, and keeps documentation realistic for busy care teams. Throughout, it also highlights how Lara Health supports program-centric documentation and month-level artifacts so that the work your team delivers is easier to bill and easier to defend.

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What is changing beginning January 1, 2026

Here is the operational statement to align your internal messaging around: starting January 1, 2026, clinics should stop reporting the bundled clinic codes G0512 and G0071 for the services those codes represented, and instead report the individual component codes established under the PFS. CMS describes this as moving RHC/FQHC reporting toward the “individual codes” that make up (a) CoCM services previously reported under G0512 and (b) CTBS and remote evaluation services previously reported under G0071.

This change is best understood as a continuation of an arc CMS has been on for years: making longitudinal, between-visit care more standardized, more measurable, and easier to compare across settings. The CY 2026 PFS final rule is broadly effective on or after January 1, 2026, which is why waiting for mid-year “breathing room” is risky unless CMS explicitly publishes it.

It is also important to understand what this is not. CMS is not saying that psychiatric collaborative care or virtual check-ins are going away. The clinical work is still clinically valuable and, when furnished consistent with coverage and documentation requirements, still billable. What changes is the way clinics must represent that work on claims: less bundling, more component-code reporting, and therefore more explicit alignment between workflow and documentation.

That explicitness is the source of both opportunity and friction. When you report component codes, claims become more transparent. But your documentation and attribution logic must be clearer. A clinic can do the work well and still see denials if the “proof” is scattered across inboxes, phone logs, and unstructured notes in a way that does not map cleanly to the expected service elements.

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Scope: what G0512 and G0071 represent (and what they do not)

One reason these transitions are messy is that teams use “behavioral health billing” as a catch-all. But G0512 is not a general behavioral health visit code. CMS describes G0512 as the RHC/FQHC code used for psychiatric CoCM, and CMS’s RHC/FQHC care management FAQs emphasize that services furnished as part of psychiatric CoCM are included in the psychiatric CoCM payment and are not separately billable under the bundled construct.

If you run a true collaborative care workflow, you already know why that detail matters. CoCM is a program, not a visit. The care manager’s registry work, proactive outreach, symptom tracking, care plan updates, and coordination with the treating practitioner and psychiatric consultant are the clinical engine. CMS’s MLN Behavioral Health Integration Services booklet frames CoCM as a structured, team-based model delivered over a monthly service period, with defined roles and service components.

G0071 is similarly easy to overgeneralize. In CMS materials, G0071 is tied to certain CTBS and remote evaluation services in the RHC/FQHC setting. The transition does not mean “virtual services are going away.” It means the clinic must represent the work using the underlying PFS-established codes rather than the clinic wrapper.

A practical training move is to define “in scope” and “out of scope” language in one page. In scope: CoCM program activity and the specific CTBS/remote evaluation services that were wrapped into G0071. Out of scope: psychotherapy sessions, psychiatric E/M visits, and other behavioral health encounters that are billed using their usual pathways. Precision here prevents both underbilling (missed charges) and overbilling (claims that do not match service elements).

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Where to find the official replacement code lists and requirements

In operational terms, the transition away from G0512 and G0071 is not a scavenger hunt for PDFs - it’s an unbundling exercise. Starting in 2026, your clinic should think of each retired “wrapper” code as a shorthand for a small, specific set of component services that already exist under the Physician Fee Schedule (PFS). The implementation work is therefore about two things: (1) deciding which component service your team actually delivered in a given month or service period, and (2) ensuring your workflow produces the evidence those component codes expect (time thresholds where applicable, required care team roles, registry/care plan activity, and clear attribution). If you frame it this way, the transition becomes a manageable build: a short list of codes, paired with a clear “what counts” playbook and a month-end close process.

Below are the component-code families most clinics will want at the center of their transition planning. Each item is written the way an operator needs to understand it: what it captures, how it functions, and what you should make visible in documentation.

Psychiatric collaborative care (CoCM) replacing the G0512 wrapper

• CPT 99492 (initial psychiatric CoCM, first month) captures the first month of a collaborative care episode when the behavioral health care manager’s time meets the initial-month threshold, with structured registry-based follow-up and psychiatric consultant involvement, all directed by the treating clinician.
• CPT 99493 (subsequent months psychiatric CoCM) captures ongoing monthly collaborative care work after the first month when the care manager’s time meets the subsequent-month threshold, with continued registry tracking and psychiatric case review.
• CPT 99494 (CoCM add-on time) is used when collaborative care time exceeds the base month threshold and additional time needs to be reported in the same calendar month, with the same program elements intact.
• HCPCS G2214 (psychiatric CoCM “short month” option) is used when the clinic delivers meaningful collaborative care work in a month, but the care manager time doesn’t reach the larger base thresholds—this code is often the difference between “we did the work” and “we can support the claim” in lighter-touch months.
  

Virtual communication, CTBS, and remote evaluation replacing the G0071 wrapper

• HCPCS G2012 (virtual check-in) captures a brief patient-initiated communication intended to decide whether an in-person/telehealth visit or other service is needed; operationally, your documentation should show that the communication occurred and why it was clinically necessary.
• HCPCS G2010 (remote evaluation) captures clinician review of patient-submitted recorded video/images with follow-up to the patient; operationally, your documentation should show what was reviewed and what guidance or next step resulted.
• CPT 99421 / 99422 / 99423 (online digital E/M) capture cumulative clinician time over a defined short service period (commonly framed as “over up to 7 days”) with escalating time thresholds; operationally, your documentation should support the time total and the clinical nature of the digital interaction (not just administrative messaging).
  

One practical insight that prevents denials: build the transition as two separate playbooks: one for CoCM (monthly, programmatic, registry-driven care with psychiatric consultation workflows), and one for CTBS/remote evaluation (short interactions with clear clinical intent and traceable documentation). When those workflows are separated cleanly, your staff training becomes simpler, your month-end close becomes faster, and your claims become far more defensible, because each reported code is supported by a narrative that matches what the code is designed to represent.

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Implementation strategy that protects reimbursement continuity

The clinics that transition smoothly treat this as an operational rollout, not a billing toggle. They assign owners, develop a playbook, train staff with realistic scenarios, and establish a month-end “close” process that makes completeness visible.

Before you touch templates, start with an inventory. Identify which patients and months were previously captured under G0512 and G0071, which team members performed the work, and where the supporting documentation lives today. This step is dull, but it is how you prevent surprises when remittances start returning with denials or partial payments.

Next, build a mapping document that connects (a) the work you actually do to (b) the component-code families you will report going forward and (c) the documentation elements you will standardize. For CoCM, that mapping should be program-centric: registry evidence, structured follow-up, symptom measurement where applicable, care plan updates, psychiatric consultation pathways, and clear documentation of team roles, aligned to CMS’s description of CoCM service components and roles. For CTBS and remote evaluation services, map the patient-facing events and the documentation trail (what was initiated, what was reviewed, what was communicated, and what follow-up occurred) so that reporting does not depend on memory.

Only then should you update systems. Charge masters, claim scrubbers, clearinghouse edits, and payer mappings must accept the component codes you will report. This is why clinics that begin late often miss the true bottleneck: not policy interpretation, but systems readiness. Even if Medicare policy is clear, internal and payer-side systems can lag.

Finally, run a structured stabilization period. Expect that the first 30-90 days will surface gaps, template friction, training needs, payer-specific idiosyncrasies, and edge cases where program work does not map cleanly. Treat those as normal rollout signals and build a feedback loop between billing, clinical leads, and the care management team so the playbook hardens quickly.

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How the transition changes documentation and day-to-day workflow

The highest-impact change most clinics feel is not selecting a code. It is shifting from encounter-centric documentation to program-centric documentation. Program-centric documentation means the record tells a coherent monthly story: the clinical need, the care plan, what follow-up occurred, what registry work happened, what coordination with the treating practitioner and psychiatric consultant occurred (where applicable), and how the plan changed over time.

When the record is encounter-centric, the story is scattered. When it is program-centric, the story is legible. And legibility is what makes component-code reporting sustainable because it reduces “we did the work but can’t prove it cleanly” months, the months that create rework and denials.

This transition is also an opportunity to clarify roles. If your behavioral health care manager, primary care clinician, and psychiatric consultant roles are informally defined, documentation will remain inconsistent even after your billing system is updated. CMS’s MLN guidance describes distinct care team roles in CoCM and the core service components. Use that as a staffing and training scaffold, not merely as a billing reference.

Technology can either amplify or reduce burden. If work is distributed across EHR tasks, phone systems, and spreadsheets, you will struggle to create consistent month-level artifacts. If tasks, registry logic, and documentation prompts are unified, month-end close becomes a routine process rather than a scramble.

How Lara Health supports this: Lara Health is designed to make program-centric care management documentation natural. It prompts required elements in context, tracks month completeness, and produces month-level summaries that connect integrated care activities to clinical decision-making and follow-up. The goal is not more documentation; it is documentation that reflects the work you already do and supports clean claims.

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Financial impact: continuity, leakage, and staffing sustainability

It is tempting to describe this transition purely as “lost billing risk.” That is the urgent risk, but the deeper financial impact is program stability. Integrated behavioral health programs and care coordination workflows are staffing-intensive. If reimbursement becomes unpredictable, clinics often pull back capacity, which then increases medical utilization and worsens chronic disease control, exactly the downstream outcomes these programs are meant to prevent.

A practical way to model impact is to focus on capture rate. Define eligible patient-months as the months where your team delivered CoCM or qualifying CTBS/remote evaluation work. Your capture rate is the proportion of those months you successfully bill and get paid for, net of denials. During a messy transition, capture rate often falls, not because the work stops, but because documentation and claim representation lag behind the new reporting structure.

This is also why month-end operations matter. When a clinic has a defined close process, it catches gaps early: missing elements, unclear attribution, staff uncertainty about “what counts,” and payer-specific denial patterns. Over time, that close process becomes the operational muscle that keeps reimbursement predictable.

How Lara Health supports this: Lara Health reduces leakage by making requirements visible during workflow and assembling month-end artifacts automatically. In practice, that often means fewer denials, less rework, and greater confidence in staffing decisions, because leadership can trust the program’s reimbursement patterns.

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Common pitfalls and how to avoid them

The first pitfall is assuming a payer will “figure it out” because CMS policy is finalized. Claims processing lives in systems, edits, and payer configurations. If your charge master and clearinghouse rules are not updated, correct care can still yield incorrect claims.

The second pitfall is treating the change as a revenue cycle project only. The people who will make or break your transition are the care managers and clinical staff who document the work. If templates do not match real workflows, staff will work around them, and your claims will become inconsistent.

The third pitfall is failing to define time and attribution rules for monthly program work. CoCM is built around a monthly service period with explicit roles and activities. Training must be scenario-based, built around what staff actually do, so that documentation becomes consistent without turning the team into coders.

The fourth pitfall is underinvesting in audit readiness. Component-code reporting increases specificity, which means your documentation is easier to evaluate. Audit readiness is not defensive charting; it is operational clarity: a coherent monthly narrative, supported by registry evidence and clear team role documentation, aligned with CMS’s program framing.

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The shift away from G0512 and G0071 is a solvable transition - if you treat it like a real operational change with owners, a playbook, and a month-end close process that makes completeness visible. Done well, component-code reporting can make collaborative care and related services more standardized, more measurable, and more sustainable across your sites. Done late, it can create denials, staff frustration, and avoidable disruption to a program your patients rely on. Ready to protect continuity of reimbursement while strengthening your integrated care workflows? Lara Health helps FQHCs and RHCs translate policy changes into audit-ready operations with structured documentation, program tracking, and month-end artifacts built into everyday care delivery. Book a demo with Lara Health

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FAQs

When do G0512 and G0071 stop being reportable for RHCs and FQHCs?

CMS states G0512 and G0071 are no longer reportable beginning January 1, 2026, and clinics should report the underlying individual codes for the services those bundled codes represented.

Is this “all behavioral health billing,” or a specific subset of services?

It is a specific subset. G0512 is tied to psychiatric CoCM in the RHC/FQHC setting, not to psychotherapy visits or psychiatric E/M encounters.

How do we find the exact component codes we should report?

Start with CMS’s clinic program pages (FQHC Center and RHC Center) for the policy statement and then use CY 2026 PFS supporting documents and CMS MLN guidance to confirm the relevant code families and service components.

Should we assume there will be a mid-year grace period like there was for G0511?

Do not assume a grace period unless CMS explicitly publishes one. CMS did extend timing for the G0511 transition in 2025, but CMS’s CY 2026 clinic guidance states G0512 and G0071 are no longer reportable beginning January 1, 2026.

What is the single most important operational move to make first?

Build a mapping document that translates your real workflow into standardized documentation and a month-end close process. In most clinics, capture rate is protected by clarity: clear roles, clear templates, and clear “what counts” rules.

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Sources

CMS. Federally Qualified Health Centers (FQHC) Center: “G0512 and G0071 Changes.”

CMS. Rural Health Clinics Center (contains the same “G0512 and G0071 Changes” statement).

CMS. Calendar Year (CY) 2026 Medicare Physician Fee Schedule Final Rule Fact Sheet (CMS-1832-F). Oct 31, 2025.

CMS. Care Management Services in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) FAQs. 2019.

CMS Medicare Learning Network. Behavioral Health Integration Services (MLN909432). Apr 2025.

CMS. Medicare Claims Processing Manual, Chapter 9 (RHC/FQHC billing).

CMS Medicare Learning Network. MLN Matters Newsletter (June 5, 2025)