Schedule (PFS) Proposed Rule, outlining numerous proposed payment and policy changes that could affect healthcare providers beginning January 1, 2027. The proposed rule is currently open for public comment and is not yet final.
For Rural Health Clinics (RHCs), several proposals stand out.
Proposed: Diabetes Self-Management Training (DSMT) & Medical Nutrition Therapy (MNT) Become Stand-Alone RHC Visits
One of the most significant proposals would allow Diabetes Self-Management Training (DSMT) and Medical Nutrition Therapy (MNT) services to be paid through the RHC All-Inclusive Rate (AIR) as stand-alone billable visits. CMS says the goal is to improve access to preventive diabetes services in rural communities while aligning RHC payment policy more closely with other care settings.
If finalized:
- DSMT and MNT services would qualify as stand-alone RHC encounters.
- Services could be furnished by professionals such as Registered Dietitians, provided they are furnished under the direct supervision of an RHC practitioner.
- If DSMT or MNT is provided on the same day as another qualified RHC visit, only one AIR payment would be made.
This proposal could create additional opportunities for RHCs to expand diabetes education and nutrition services while simplifying reimbursement.
Telehealth Flexibilities Continue
CMS is also proposing regulatory updates to reflect legislation that extends several important telehealth flexibilities through December 31, 2027, including payment for non-behavioral health telehealth services furnished by RHCs and FQHCs.
Remember, a separate billing change still takes effect October 1, 2026, requiring RHCs to bill the individual CPT or HCPCS code for distant-site telehealth services instead of HCPCS code G2025. We recently covered that change in a previous blog.
Mental Health In-Person Requirement Extension
The proposed rule also reflects Congressional action extending the delay of the in-person visit requirement for mental health services furnished via telecommunications through December 31, 2027.
Remember: This Is Still a Proposed Rule
Nothing in the Physician Fee Schedule is final yet.
CMS is accepting comments through September 14, 2026, before publishing the Final Rule later this year. Some proposals may change, while others may be finalized as written.
Our team is carefully reviewing the complete rule and evaluating what it means specifically for RHCs.
As additional analysis becomes available, we’ll continue sharing the updates that matter most to your clinic.
Resources:
CMS 2027 Physician Fee Schedule Proposed Rule Fact Sheet
CMS Proposed Rule (CMS-1848-P)
Federal Register Public Inspection Copy (PDF)
|
|