Since 2018, federally qualified health centers (FQHCs) and rural health clinics (RHCs) have used HCPCS G0511 to bill for a host of care management services. More recently, the list of care management services covered under this code was expanded for 2024, but then the 2025 physician fee schedule (PFS) final rule brought a surprise announcement about the future of the G0511 code.
Read on to learn all about the past and future of G0511.
What Is HCPCS Code G0511?
G0511 is a HCPCS code that covers general care management services for FQHCs and RHCs. Its official long descriptor is as follows: "Rural health clinic or federally qualified health center (RHC or FQHC) only, general care management, 20 minutes or more of clinical staff time for chronic care management services or behavioral health integration services directed by an RHC or FQHC practitioner (physician, NP, PA, or CNM), per calendar month."
Prior to 2024, G0511 included services like chronic care management (CCM), principal care management (PCM), and behavioral health integration. In the 2024 PFS final rule, the Centers for Medicare & Medicaid Services (CMS) added remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) as services billable by FQHCs and RHCs under HCPCS G0511. CMS also added community health integration (CHI) and principal illness navigation (PIN) as care management services covered by G0511.
To bill for HCPCS G0511, an FQHC or RHC must at least capture 16 readings from qualified care management devices or provide patients with 20 minutes or more — or 30 minutes or more for principal care management (PCM) — of one of these services directed by a practitioner (e.g., physician, nurse practitioner, physician assistant, or certified nurse-midwife) per calendar month. Under CMS's 2024 rules, G0511 could be billed multiple times per patient, per month based on the mix of services provided.
What Is Happening With HCPCS G0511?
In the 2025 PFS final rule, CMS included some significant changes concerning its G0511 code that FQHCs and RHCs must understand to ensure proper coding and billing of care management services going forward. The most significant announcement was that CMS was unbundling G0511.
What does this mean? Rather than requiring FQHCs and RHCs to use a single code (G0511) to bill for all covered care management services, these organizations will need to use the existing care management CPT codes. Let's look at a few examples.
For remote patient monitoring, the core RPM CPT codes are as follows:
- 99453 — Initial patient setup and enrollment into RPM program
- 99454 — Remote monitoring and management of device readings
- 99457 — 20 mins of clinical staff time communicating with patient or caregiver
- 99458 — Each additional 20 mins of clinical staff communication with patient or caregiver
For chronic care management, the core CCM CPT codes are as follows:
- 99490 — Initial 20 mins of clinical staff time providing care management services
- 99491 — Initial 30 mins of physician/QHCP providing care management services
- 99437 — Each additional 30 mins of physician/QHCP providing care management services
- 99439 — Each additional 20 mins of clinical staff providing care management services
As of this article's publication, CMS has granted FQHCs and RHCs at least a six-month transition period — through June 2025 — during which they can still bill G0511. FQHCs and RHCs are expected to fully transition the coding of their care management services to CPT codes by the end of June 2025, but it's possible that CMS will choose to extend this transition deadline.
FQHCs and RHCs: The Case for CPT Codes
With that said, FQHCs and RHCs may not want to wait to make the HCPCS-to-CPT switch. Why?
As MedPAC notes, FQHCs can be located in both urban and rural areas and must serve a medically underserved area (MUA) or a medically underserved population, such as migrant farmworkers or homeless individuals. RHCs must initially be located in a non-urbanized area that qualifies as a primary care health professional shortage area (HPSA), MUA, or governor-designated shortage area.
Given these location requirements, the patients served by FQHCs and RHCs often have complex health and social challenges that can raise their risk for chronic diseases, like heart disease and diabetes. When these individuals receive care management services, they are more likely to need increased clinician time and attention. The G0511-based coding scheme incentivized providers to limit care management services to 20 minutes as services that extended beyond this threshold would not generate additional reimbursement, even if that additional time was in the interest of a patient's health.
Enabling FQHCs and RHCs to now use care management CPT codes removes what one could argue is a care deterrent and places the emphasis on providing patients with the appropriate levels and lengths of services they need, essentially regardless of the time required to do so. Thus, the transition from HCPCS G0511 to CPT coding brings greater precision in the delivery of care management services and the potential for increased revenue.
FQHC and RHC Care Management Coding and Reimbursement: HCPCS vs. CPT
How does this play out from a coding and billing perspective? Payments for FQHC and RHC care management services are at the national non-facility Medicare payment rates. FQHCs and RHCs using G0511 and billing RPM and CCM are paid about $110 per patient per month in 2025 — a significant decline from 2024 (~$146).
On the other hand, non-FQHCs/RHCs using CPT codes for these same services can bill up to $195 per patient per month in 2025.
While the revised coding and billing rules lower the reimbursement floor, with 20 minutes of care management paying less with the unbundling, they raise the FQHC and RHC payment ceiling.
FQHCs and RHCs: Finding Success With Remote Patient Monitoring
Decisions by CMS over these past few years have made it the perfect time for federally qualified health centers and rural health clinics to add remote patient monitoring. RPM is a service proven to enable timely health interventions, reduce admissions, improve patient care, and increase scalable revenue.
If you are interested in learning more about RPM, get our popular — and updated for 2025 — guide on "10 Things Every RHC and FQHC Should Know About Remote Patient Monitoring."