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Rural Georgia has lost more than nine community hospitals since 2010 and the majority of counties outside metro Atlanta meet federal designations for primary care shortage. In this landscape, Rural Health Clinics (RHCs) are often the only available source of Medicare primary care. Section 1861(aa)(2) of the Social Security Act, added by the Rural Health Clinic Services Act of 1977 (Public Law 95-210) signed by President Carter on December 13, 1977, established Medicare coverage of services furnished by RHCs and authorized payment for nurse practitioner, physician assistant, and certified nurse midwife services in rural shortage areas. RHCs are paid under a unique All-Inclusive Rate (AIR) per-visit methodology rather than the Physician Fee Schedule. The Consolidated Appropriations Act of 2021 (Public Law 116-260) Section 130 phased increases to the independent RHC payment cap and imposed the cap on newly designated provider-based RHCs after December 31, 2020, while grandfathering existing provider-based RHCs at their cost-based rates. CAA 2021 Section 132 made permanent the RHC telehealth distant-site authority that the CARES Act 2020 Section 3704 had temporarily authorized during the COVID-19 public health emergency. This guide explains the statutory framework, the 42 CFR Part 491 certification conditions, the AIR payment methodology, the CAA 2021 payment cap reforms, the productivity standards, care management services, and how rural Georgia beneficiaries access primary care. :::

::: callout Key takeaways

  • Section 1861(aa)(2) of the Social Security Act, added by the Rural Health Clinic Services Act of 1977 (Public Law 95-210), established Medicare coverage of RHC services. The original policy goal was to expand rural primary care by enabling payment for nurse practitioner, physician assistant, and certified nurse midwife services.
  • 42 CFR Part 491 Subpart A establishes RHC certification conditions: location in a non-urbanized area, location in a HRSA shortage area (HPSA primary care, MUA, or Governor-designated), staffing requirements including at least 50% midlevel coverage of operating hours, and core clinical service requirements.
  • 42 CFR Part 405 Subpart X establishes payment: each RHC visit is paid the All-Inclusive Rate (AIR), a bundled per-visit payment covering professional service, ancillary services, supplies, and overhead.
  • Independent RHCs are paid the lesser of the actual AIR (cost-based) or the statutory cap. CAA 2021 Section 130 increased the cap from $87.52 in 2020 to a target of $190 by 2028 with annual MEI updates.
  • Provider-based RHCs (in hospitals with fewer than 50 beds) historically received uncapped cost-based payment. CAA 2021 Section 130 imposed the cap on RHCs newly designated after December 31, 2020, but grandfathered existing provider-based RHCs at their cost-based rates.
  • CARES Act 2020 Section 3704 temporarily authorized RHCs as telehealth distant sites during the COVID-19 PHE. CAA 2021 Section 132 made this authority PERMANENT under new Section 1834(o) of the Social Security Act.
  • Care management services in RHCs are billed under HCPCS G0511 (CCM/BHI), G0512 (Psychiatric Collaborative Care Model), and related codes, in addition to the regular AIR visit payment.
  • Beneficiary cost-sharing: standard Part B deductible ($257 in 2026) and 20% coinsurance after deductible. Preventive services with zero cost-sharing under Section 1861(ddd) are exempt from these charges when furnished at the RHC.
  • Georgia has approximately 70-100 Medicare-certified RHCs, mostly provider-based (hospital-affiliated) and concentrated in southern, southwest, and middle Georgia counties with HRSA shortage designations. :::

Why Rural Health Clinics matter in Georgia

Rural Georgia faces a primary care provider shortage that has worsened over the past two decades. Approximately 90 of Georgia's 159 counties meet federal Health Professional Shortage Area (HPSA) designations for primary care. Approximately 70 counties qualify as Medically Underserved Areas (MUAs). Nine or more rural hospitals have closed since 2010, including facilities in Glenwood, Fort Oglethorpe, Richland, Camilla, and elsewhere. The remaining rural hospital footprint, anchored by Critical Access Hospitals and small community hospitals, struggles financially while serving as the primary source of Medicare and Medicaid revenue for entire counties.

In this environment, Rural Health Clinics (RHCs) are often the only available source of primary care for Medicare beneficiaries in rural Georgia counties. Many rural counties have no full-time physician practice but have one or more RHCs staffed primarily by nurse practitioners or physician assistants working under physician supervision. The RHC model has been the federal government's answer to rural primary care shortage since 1977, when President Carter signed the Rural Health Clinic Services Act into law.

This guide explains how the RHC benefit works for Medicare beneficiaries in Georgia: the federal statutory framework, the unique All-Inclusive Rate (AIR) payment methodology, the major reforms enacted in the Consolidated Appropriations Act of 2021, the certification conditions under 42 CFR Part 491, the productivity standards, the care management services that fill gaps in chronic disease coordination, and the dramatic expansion of telehealth that has reshaped rural primary care since 2020.

The Rural Health Clinic Services Act of 1977: a deliberate policy choice

Background of the 1977 Act

In the mid-1970s, rural America was experiencing the same primary care shortage that persists today. Many rural counties had nurse practitioners and physician assistants ready to provide primary care, but the existing Medicare and Medicaid payment systems would not pay for their services. Medicare recognized only physician services as billable in primary care; NPs and PAs were viewed as physician extenders whose work could be billed only if "incident to" a physician's service, which required the physician's physical presence.

The Rural Health Clinic Services Act of 1977 (Public Law 95-210) was a deliberate policy intervention to address this gap. The legislation was signed by President Jimmy Carter on December 13, 1977. The Act:

  1. Recognized RHCs as a unique Medicare provider type
  2. Established Medicare coverage of services furnished by RHCs
  3. Authorized payment for services rendered by NPs, PAs, and CNMs in RHCs (without requiring physician presence)
  4. Used cost-based reimbursement to encourage clinic establishment
  5. Required RHCs to be located in rural shortage areas (HPSA, MUA, or Governor-designated)

The original 1977 statute used a cost-based reimbursement methodology that paid RHCs their actual reasonable costs with no cap. Independent RHCs (standalone clinics) became subject to a per-visit payment cap starting in 1988 under OBRA 1987. Provider-based RHCs (hospital-affiliated, in hospitals with fewer than 50 beds) remained generally uncapped under cost-based payment. This payment differential created an incentive for hospitals to acquire independent RHCs and convert them to provider-based status, an arbitrage that persisted for decades.

Section 1861(aa)(2) defines RHC services

Section 1861(aa)(2) of the Social Security Act defines RHC services for Medicare. The definition includes:

Component Description
Physician services Furnished by a physician at the RHC
Incident-to physician services Services and supplies incident to physician services
Midlevel services NP, PA, or CNM services at the RHC
Incident-to midlevel services Services and supplies incident to midlevel services
Visiting nurse services Qualified RN/LPN furnishing services in beneficiary's residence in an HPSA
Behavioral health services Clinical psychologist and clinical social worker services
Other services As specified by the Secretary

The visiting nurse service under Section 1861(aa)(2)(B) is an unusual benefit. RHCs in HPSA areas may furnish visiting nurse services to homebound beneficiaries in their residences, separate from the regular Medicare home health benefit. This authority allows RHCs to extend primary care services beyond the four walls of the clinic, important in rural counties where transportation barriers limit access.

42 CFR Part 491 Subpart A: certification conditions

42 CFR Part 491 Subpart A sets the conditions for RHC certification. Key provisions:

Location requirements (42 CFR 491.2)

The RHC must be located in BOTH:

  1. A non-urbanized area as designated by the Bureau of the Census
  2. A shortage area qualifying under one of the following:
    • HRSA Health Professional Shortage Area (HPSA) designation for primary care
    • HRSA Medically Underserved Area (MUA) designation
    • Governor-designated shortage area under the Public Health Service Act

The shortage designation must be active or have been active within the prior 4 years. RHCs in counties that lose shortage designation can continue operating under the 4-year grace period; if the designation is not reinstated, the RHC must close or relocate.

The dual location requirement (non-urbanized AND shortage area) is restrictive: a clinic in a rural but non-shortage area cannot be an RHC, and a clinic in a shortage area within an urbanized area also cannot be an RHC. This restriction has been the subject of policy debate, with rural advocates arguing the dual requirement is unnecessarily limiting.

Staffing requirements (42 CFR 491.5)

Position Requirement
Physician Available to provide medical direction, supervision, and consultation. Onsite at least every two weeks (with telecommunication exceptions). Available by phone/telecommunication during operating hours.
Midlevel (NP, PA, or CNM) At least one present at least 50% of operating hours. Furnishes patient care as authorized by state law.
Nurse One or more RN/LPN for clinical support
Behavioral health (optional) Clinical psychologist or CSW may be added

This staffing structure was a deliberate 1977 policy choice. By allowing midlevels to be the primary providers (with physician supervision rather than physical presence), Congress enabled clinics in areas where full-time physicians were unavailable. The 50% midlevel coverage requirement was the operational floor: an RHC must have a midlevel available at least half the time it is open.

The Trump-era CMS rules and subsequent Biden-era updates have modernized the supervision requirements to recognize telecommunication-based physician supervision, particularly important post-COVID. Many rural RHCs operate with a physician medical director who provides oversight via secure messaging and periodic in-person visits while NPs or PAs furnish day-to-day care.

Patient services (42 CFR 491.7)

RHCs must provide a minimum set of services:

  • Diagnostic and therapeutic services and supplies commonly furnished in a physician's office
  • Drugs and biologicals routinely furnished in primary care
  • Basic laboratory services (CLIA-waived tests at minimum)
  • Emergency services and protocols

Many RHCs offer more services than the minimum, including point-of-care blood work, basic radiology, suture and minor procedure care, immunizations, and chronic disease monitoring.

Quality assurance and records (42 CFR 491.8, 491.9)

RHCs must maintain comprehensive medical records meeting standard professional requirements and operate a written quality assurance program. Periodic review of patient records and care, continuing professional education, and remediation of identified deficiencies are required.

Productivity standards (42 CFR 491.10)

42 CFR 491.10 establishes productivity standards:

  • Physician: 4,200 visits per full-time equivalent (FTE) per year
  • Midlevel (NP/PA/CNM): 2,100 visits per FTE per year

These standards inform cost-report calculations. RHCs that exceed productivity standards generate lower per-visit costs and produce higher reasonable AIR calculations.

In practice, productivity standards primarily affect cost-report calculations for grandfathered provider-based RHCs (whose payment is cost-based). Independent RHCs and post-2020 provider-based RHCs receive the capped AIR regardless of actual cost, so productivity standards have less practical payment impact on them.

42 CFR Part 405 Subpart X: the All-Inclusive Rate

What is the AIR?

The All-Inclusive Rate (AIR) is the bundled per-visit payment for RHC services. Each Medicare-billable visit (one face-to-face encounter with a qualifying provider during which the provider furnishes at least one medically necessary service) is paid at the AIR. The AIR includes:

  • Professional service of the qualifying provider (physician, NP, PA, CNM, clinical psychologist, or clinical social worker)
  • All ancillary services and supplies typically provided during a primary care visit
  • Overhead (rent, utilities, administrative costs)
  • Reasonable costs not separately reimbursed

The AIR replaces the fragmented fee-for-service billing under the Medicare Physician Fee Schedule. Instead of separate codes for E/M, immunizations, blood pressure checks, ECGs, and basic procedures, the RHC bills a single visit code (e.g., HCPCS G0466 for new patient visit, G0467 for established patient visit, G0468 for IPPE/AWV, G0469 for behavioral health visit, G0470 for diabetes self-management) and is paid the AIR.

Independent RHC payment cap

Independent RHCs are paid the lesser of:

  • Their actual AIR based on annual cost report, OR
  • The statutory cap

The statutory cap has been modified by Consolidated Appropriations Act 2021 (Public Law 116-260) Section 130:

Year Approximate cap
2020 $87.52
2021 $100
2022 $113
2023 $126
2024 $139
2025 $152
2026 ~$155-165 (after MEI adjustments)
2028 $190 (statutory cap)

These phased increases were intended to bring independent RHC payment closer to provider-based RHC cost-based payment, reducing the long-standing payment differential.

Provider-based RHC payment

Provider-based RHCs (in hospitals with fewer than 50 beds) historically received cost-based reimbursement with NO cap. The hospital cost report calculated the RHC's reasonable costs, and Medicare paid that amount per visit (subject to reasonableness tests).

CAA 2021 Section 130 imposed major reforms:

RHC Type Pre-CAA 2021 Post-CAA 2021
Independent RHC Capped at ~$87.52 Capped at $190 by 2028 (phased increases)
Provider-based RHC designated BEFORE Dec 31, 2020 Cost-based, no cap GRANDFATHERED at existing cost-based rate with annual MEI updates
Provider-based RHC designated AFTER Dec 31, 2020 N/A Same capped AIR as independent RHCs

The Section 130 reforms closed the loophole that had previously allowed hospitals to acquire independent RHCs and convert them to provider-based status purely for payment arbitrage. New conversions after December 31, 2020 do not gain the cap exemption. Existing provider-based RHCs retain their grandfathered cost-based rates.

What counts as a Medicare-billable RHC visit

A Medicare-billable visit (an "encounter") is a face-to-face interaction between the beneficiary and a qualifying RHC provider during which at least one medically necessary service is furnished. Multiple services during the same encounter generally bundle into one visit payment.

Exceptions to the one-visit-per-day rule:

  • Medical + behavioral health on same day: Two qualifying provider encounters (e.g., NP visit + clinical psychologist visit) bill as two visits
  • Medical + IPPE/AWV on same day: Separate IPPE/AWV billing using G0468
  • Subsequent illness on same day: If the beneficiary returns with a separate medically necessary issue, separated by time, a second visit may be billed

Beneficiary cost-sharing

RHC services have standard Part B cost-sharing:

Component 2026 amount
Part B annual deductible $257
Beneficiary coinsurance after deductible 20% of AIR
Medicare pays 80% of AIR

Important exception: certain preventive services furnished at RHCs (Annual Wellness Visit, USPSTF Grade A and B preventive services) have ZERO cost-sharing per Section 1861(ddd) and applicable exemptions. The deductible and 20% coinsurance do not apply to these services.

Medigap covers the 20% coinsurance for all Medicare-covered RHC services.

The CAA 2021 reforms in detail

Section 130: Payment cap convergence

Section 130 of CAA 2021 (Public Law 116-260, signed December 27, 2020) made several major changes:

  1. Increased independent RHC cap: Phased from approximately $87.52 in 2020 to $190 in 2028, with annual Medicare Economic Index (MEI) adjustments
  2. Provider-based RHC cap on new designations: Provider-based RHCs designated after December 31, 2020 are subject to the same capped AIR as independent RHCs
  3. Grandfathering of existing provider-based RHCs: Provider-based RHCs with cost-based rates higher than the cap retain their cost-based rates with annual MEI updates
  4. Annual MEI updates: All RHCs (capped and grandfathered) receive annual updates based on the Medicare Economic Index

The combined effect: independent RHCs now receive substantially higher payment (closing approximately 70% of the historical gap with grandfathered provider-based RHCs), while new provider-based RHCs are paid the same as independent RHCs.

Section 132: Permanent RHC telehealth distant-site authority

Before COVID-19, RHCs could not serve as telehealth DISTANT sites under Section 1834(m). RHCs could be ORIGINATING sites (where the patient is) for some telehealth visits, but they could not bill for furnishing telehealth services from the RHC to a patient elsewhere.

CARES Act 2020 Section 3704 (Public Law 116-136) temporarily authorized RHCs as telehealth distant sites during the COVID-19 PHE. Section 132 of CAA 2021 made this authority PERMANENT, codifying it as Section 1834(o) of the Social Security Act.

Permanent RHC telehealth distant-site authority:

  • RHCs may furnish telehealth services to beneficiaries via audio-video
  • For behavioral health, audio-only is permitted (under CAA 2022 Section 4113)
  • Payment uses HCPCS G2025 (RHC telehealth visit), paid at the RHC AIR
  • Geographic and originating-site restrictions waived (RHCs can serve patients in their homes)
  • Effective date: January 1, 2022 (with PHE flexibilities continuing in the interim)

This authority has been transformative for rural primary care. An RHC in Tifton can now provide telehealth visits to beneficiaries in Albany, Macon, or Atlanta. The combination of the AIR payment methodology, the permanent telehealth authority, and the modernized supervision rules has enabled RHC networks to extend their reach far beyond walk-in patients.

Care management services in RHCs

CMS introduced specific RHC care management G-codes to support chronic care coordination outside the face-to-face visit framework. These services are billed in addition to the regular AIR visit and represent non-face-to-face care coordination:

Code Description Approximate monthly payment
G0511 General care management (CCM or BHI) in RHC/FQHC; 20+ minutes per month $77 (2024-2025)
G0512 Psychiatric Collaborative Care Model (CoCM) in RHC/FQHC $145 (2024-2025)

The G0511 service covers chronic care management (CCM) and behavioral health integration (BHI) at a flat monthly rate. The G0512 service covers the more intensive Psychiatric Collaborative Care Model with consulting psychiatrist support.

Care management services are particularly important for the high-complexity Medicare patient population typical of rural Georgia. Beneficiaries with multiple chronic conditions, polypharmacy, and behavioral health needs benefit from structured care coordination that the regular AIR visit framework does not adequately support.

The Psychiatric Collaborative Care Model has emerged as a particularly effective intervention for rural mental health. Under CoCM:

  • A behavioral health care manager (typically LCSW or LPC) at the RHC coordinates care
  • The RHC primary care provider prescribes psychiatric medications and conducts follow-ups
  • A consulting psychiatrist (remote, contracted) reviews cases weekly and advises on medication adjustments
  • The RHC bills G0512 monthly

This model brings psychiatric expertise to RHCs that cannot recruit on-site psychiatrists, which is most rural Georgia RHCs.

RHC versus FQHC: how they differ

Rural Health Clinics and Federally Qualified Health Centers are both safety-net primary care providers but operate under different federal statutes and payment frameworks:

Feature RHC FQHC
Federal statute Section 1861(aa)(2) Section 1861(aa)(3)
Establishing legislation RHC Services Act 1977 OBRA 1989 / OBRA 1990 (Section 4161/4704)
Implementing regulation 42 CFR Part 491 42 CFR Part 405 Subpart X
Location requirement Non-urbanized + shortage area HRSA Section 330 grant area
HRSA grant required NO YES (Section 330 grant or look-alike)
Sliding fee scale Not required (some have voluntarily) REQUIRED (sliding scale based on income)
Governance No specific federal requirement Patient-majority governing board required
Payment methodology All-Inclusive Rate (AIR) Prospective Payment System (PPS)
340B Drug Pricing Not eligible by default Eligible (substantial drug savings)

For Medicare beneficiaries, the visible differences are generally modest: both provide comprehensive primary care, both serve Medicare under bundled per-visit payment, both have similar quality requirements. The differences become more apparent in business operations, grant funding, and patient population mix. FQHCs are more common in metro areas and urban underserved communities; RHCs are more common in rural areas.

A subsequent guide in the Brevy library covers FQHC services specifically.

Georgia RHC landscape

Distribution

Georgia has approximately 70-100 Medicare-certified RHCs (with the count varying as facilities open, close, change ownership, or convert between independent and provider-based status). Distribution:

Region Approximate RHCs
South Georgia (below Macon) Majority of state RHCs, particularly southwest
Southeast Georgia Concentrations around Brunswick, Waycross, Vidalia
North Georgia mountains Smaller number in Habersham, Towns, Union, Rabun
Middle Georgia Wilcox, Crisp, Telfair, Bleckley, Pulaski
Western Georgia (Chattahoochee Valley) Troup, Heard, Carroll, Meriwether

Most Georgia RHCs are provider-based (affiliated with rural hospitals or Critical Access Hospitals). Examples of hospitals with provider-based RHCs include Emanuel County Memorial Hospital (Swainsboro), Crisp Regional Hospital (Cordele), Phoebe Sumter Medical Center (Americus), Effingham Health System (Springfield), and many others.

State oversight and support

Federal certification is administered by CMS through the Survey & Certification process via Palmetto GBA Jurisdiction J Medicare Administrative Contractor. State coordination is handled by the Georgia State Office of Rural Health within the Department of Community Health (DCH). Phone: 229-401-3090.

The Georgia Rural Health Association (706-247-6320) is the state professional society for rural healthcare providers including RHCs.

Georgia provides supplemental support for rural healthcare through several mechanisms:

  • Rural Hospital Tax Credit: State income tax credits for donations to qualifying rural hospitals (some of which operate provider-based RHCs)
  • Hospital Provider Payment Program (HPPP): Medicaid supplemental payments to rural facilities
  • Rural workforce programs: GME slots, loan repayment, training grants

Telehealth and rural Georgia

The post-CAA 2021 permanent RHC telehealth distant-site authority has been particularly impactful in Georgia:

  1. Geographic dispersion: Rural Georgia counties are large; beneficiaries often live far from the RHC
  2. Provider shortage: RHCs can now reach the homebound and elderly via telehealth
  3. Behavioral health access: Audio-only telehealth (CAA 2022 Section 4113) has expanded mental health access where in-person psychiatry is unavailable
  4. Chronic care management: Monthly care coordination via telehealth supports the high-complexity rural Medicare population

Common RHC telehealth scenarios in Georgia:

  • Routine follow-up for stable chronic conditions
  • Behavioral health counseling (audio-only or audio-video)
  • Tele-specialty consultations
  • Care management check-ins
  • Post-discharge follow-up after hospital stays
  • Medication management visits

Six worked examples for Georgia beneficiaries

Example one: Margaret 75 Jeff Davis County

Margaret is a 75-year-old retired schoolteacher in rural Jeff Davis County (Hazlehurst). She has diabetes, hypertension, and chronic kidney disease. The nearest physician's office is 35 miles away. The local RHC, provider-based affiliated with the Jeff Davis Hospital, provides her primary care.

She visits the RHC for routine diabetes/hypertension management. The visit includes vital signs by an LPN, examination by a nurse practitioner under physician supervision, HbA1c point-of-care test (CLIA-waived, included in the AIR), blood pressure check, medication reconciliation, and counseling on diet and exercise.

Because the RHC is grandfathered provider-based (designated 2015), its cost-based AIR is approximately $185 per visit (above the statutory cap but within its grandfathered rate after CAA 2021).

Cost calculation:

  • Medicare-approved AIR: $185
  • Margaret has met her $257 2026 Part B deductible
  • Medicare pays 80% = $148
  • Margaret's 20% coinsurance = $37
  • Margaret's Medigap Plan G pays the $37
  • Margaret pays $0 out of pocket

Example two: Robert 80 Treutlen County

Robert is an 80-year-old in Treutlen County (Soperton). He visits the RHC affiliated with the local hospital (provider-based, grandfathered under CAA 2021 with a cost-based AIR of approximately $200).

Robert's visit treats an acute respiratory infection. Medicare pays $200, Robert's coinsurance is $40, Medigap covers it. Robert pays $0.

Comparison: a nearby independent RHC newly designated in 2023 has a capped AIR of approximately $155. Medicare would pay $155 and the coinsurance would be $31. The grandfathered provider-based RHC receives higher payment but produces identical $0 out-of-pocket to Robert.

Example three: Linda 73 Wilcox County Medicare Advantage

Linda is a 73-year-old in Wilcox County (Abbeville). She is enrolled in a Humana Medicare Advantage plan. The local RHC is in Humana's network with a $20 copay per visit.

Linda visits for chronic disease management. She pays $20 copay. The MA plan pays the RHC its contracted rate.

If Linda were on Original Medicare with Medigap, her cost would also be effectively $0. The MA structure trades small copays for supplemental benefits (dental, vision, hearing) that Original Medicare does not cover. Linda chose MA because of those supplemental benefits.

Example four: Charles 78 Heard County telehealth visit

Charles is a 78-year-old in Heard County (Franklin), near the Alabama border. He has limited mobility and limited transportation. His local RHC is 15 miles away in the next county.

Since CAA 2021 Section 132 made RHC telehealth distant-site authority permanent, Charles's RHC offers telehealth visits. Charles uses his daughter's tablet for an audio-video visit with a nurse practitioner.

The RHC bills HCPCS G2025 (RHC telehealth visit) and is paid the AIR. Charles's cost-sharing is the same as for an in-person visit: 20% coinsurance after the deductible. Medigap covers it. Charles pays $0.

The telehealth option eliminated a 30-mile round trip that had previously taken half a day with transportation arrangements.

Example five: Patricia 70 Brantley County chronic care management

Patricia is a 70-year-old in Brantley County (Nahunta) with diabetes, COPD, congestive heart failure, and depression. Her RHC enrolls her in chronic care management under HCPCS G0511.

Each month:

  • The RHC care manager (an RN) provides at least 20 minutes of non-face-to-face care coordination
  • Coordination includes medication reviews, follow-up on specialist appointments, communication with the cardiologist managing her CHF, lab result review, and check-ins on social determinants
  • The RHC bills G0511 at approximately $77 per month
  • Patricia's coinsurance applies (Medigap covers it)

This service is in addition to her quarterly RHC face-to-face visits. The CCM service has significantly reduced her ED visits and hospitalizations.

Example six: Henry 82 Crisp County behavioral health integration

Henry is an 82-year-old in Crisp County (Cordele). He has chronic depression but the nearest psychiatrist is in Macon, 75 miles away. The RHC at Crisp Regional Hospital uses the Psychiatric Collaborative Care Model (CoCM) to manage Henry's depression.

Under CoCM:

  • A behavioral health care manager (LCSW) at the RHC coordinates Henry's depression care
  • The RHC NP/physician prescribes antidepressants and conducts in-person follow-ups
  • A consulting psychiatrist (remote, contracted) reviews Henry's case weekly and advises on medication adjustments
  • The RHC bills G0512 (CoCM monthly add-on) at approximately $145 per month

Henry receives high-quality psychiatric care within his primary care home without traveling to Macon. The CoCM model has substantially improved depression remission rates in rural areas.

Common beneficiary issues

Issue one: confusion about visit billing

Beneficiaries sometimes receive bills they don't expect. The AIR includes most services typically provided during a primary care visit, but some services (laboratory tests sent to outside labs, specialty consultations, radiology beyond CLIA-waived tests) are billed separately. The 20% coinsurance applies to the AIR; separate services have their own cost-sharing.

Issue two: limited specialty availability

RHCs provide primary care. Specialist services (cardiology, oncology, gastroenterology) generally require referral to providers outside the RHC. Beneficiaries should understand that the RHC is a primary care home, not a comprehensive specialty center.

Issue three: Medicare Advantage network status

Some Medicare Advantage plans have RHCs in network; some do not. Beneficiaries enrolled in MA plans should verify the RHC is in-network before treatment. Out-of-network RHC visits may have higher cost-sharing or be denied.

Issue four: telehealth eligibility

Although CAA 2021 made RHC telehealth distant-site authority permanent, certain rules apply:

  • Audio-video required for most visits
  • Audio-only permitted for behavioral health under CAA 2022 Section 4113
  • Telehealth visits use HCPCS G2025 (paid at RHC AIR)
  • Some MA plans may have additional restrictions

Issue five: transportation to RHCs

Many rural Georgia beneficiaries lack transportation. Medicare does not generally cover non-emergency transportation. Options:

  • Medicaid non-emergency transportation (if dual-eligible)
  • Local volunteer driver programs
  • Telehealth (when appropriate for the visit type)
  • Area Agency on Aging transportation programs

Issue six: behavioral health integration

Many rural Georgia beneficiaries have behavioral health needs but limited access to specialty mental health providers. RHCs increasingly use the Psychiatric Collaborative Care Model (G0512) and Behavioral Health Integration (G0511) to provide structured mental health support within the primary care home.

Resources Brevy connects you with

At Brevy, we maintain comprehensive resources at brevy.com to help Georgia families understand Medicare coverage of rural primary care, locate Rural Health Clinics in their communities, and navigate the AIR payment structure that makes RHC visits feel different from traditional physician office encounters. The Rural Health Clinic Services Act of 1977 was a deliberate federal investment in rural primary care that continues to anchor access in counties where independent physician practices are scarce. The CAA 2021 reforms have strengthened RHC payment and enabled telehealth in ways that fundamentally expand the geographic reach of rural primary care, which matters enormously to Georgia beneficiaries spread across the state's 159 counties.

::: accordion

What is a Rural Health Clinic?

A Rural Health Clinic (RHC) is a Medicare-certified primary care facility that operates in a non-urbanized area meeting a federal shortage designation. RHCs were established by the Rural Health Clinic Services Act of 1977 and provide primary care services with a unique bundled All-Inclusive Rate per-visit payment from Medicare.

Section 1861(aa)(2) of the Social Security Act, added by the Rural Health Clinic Services Act of 1977 (Public Law 95-210) signed December 13, 1977.

What is the All-Inclusive Rate?

The All-Inclusive Rate (AIR) is the bundled per-visit payment for RHC services. Each Medicare-billable visit is paid the AIR, which covers the professional service, ancillary services, supplies, and overhead typically associated with a primary care visit.

What is the difference between independent and provider-based RHCs?

Independent RHCs are standalone clinics. Provider-based RHCs are affiliated with hospitals having fewer than 50 beds. Historically, provider-based RHCs received uncapped cost-based payment while independent RHCs were capped. CAA 2021 Section 130 imposed the cap on newly designated provider-based RHCs after December 31, 2020, while grandfathering existing provider-based RHCs.

What is the 2026 independent RHC payment cap?

The statutory cap is approximately $155-165 after Medicare Economic Index adjustments, on the way to the target $190 by 2028 under CAA 2021 Section 130 phased increases. The exact 2026 amount is published annually by CMS.

What is CAA 2021 Section 130?

Consolidated Appropriations Act 2021 (Public Law 116-260) Section 130 reformed RHC payment by phasing increases in the independent RHC cap and imposing the cap on newly designated provider-based RHCs after December 31, 2020.

What is CAA 2021 Section 132?

CAA 2021 Section 132 made permanent the RHC telehealth distant-site authority that the CARES Act 2020 Section 3704 had temporarily authorized. Now codified as Section 1834(o) of the Social Security Act.

Can RHCs furnish telehealth?

Yes. Since CAA 2021 Section 132, RHCs can serve as telehealth distant sites permanently. RHC telehealth visits are billed under HCPCS G2025 and paid at the RHC AIR. Audio-video is required for most visits; audio-only is permitted for behavioral health under CAA 2022 Section 4113.

What is the beneficiary cost-sharing for RHC services?

Standard Part B cost-sharing: $257 annual deductible (2026), then 20% beneficiary coinsurance after deductible. Medicare pays 80% of the AIR. Medigap covers the 20% for covered services.

Are preventive services at an RHC subject to cost-sharing?

USPSTF Grade A and B preventive services and the Annual Wellness Visit have zero beneficiary cost-sharing per Section 1861(ddd) and applicable exemptions, even when furnished at an RHC.

What is HCPCS G0511?

G0511 is the general care management (CCM/BHI) monthly code for RHCs and FQHCs. It pays a monthly fee (approximately $77 in 2024-2025) for at least 20 minutes of non-face-to-face care coordination.

What is HCPCS G0512?

G0512 is the Psychiatric Collaborative Care Model (CoCM) monthly code for RHCs and FQHCs. It pays approximately $145 per month for structured psychiatric care management with consulting psychiatrist support.

Who can be the primary clinical provider at an RHC?

Physicians, nurse practitioners, physician assistants, certified nurse midwives, clinical psychologists, and clinical social workers all qualify as RHC clinical providers under Section 1861(aa)(2) and 42 CFR 491.5.

What are the staffing requirements for RHCs?

42 CFR 491.5 requires: a physician available for medical direction and consultation; at least one NP, PA, or CNM present at least 50% of operating hours; one or more RN/LPN for clinical support.

Where must an RHC be located?

42 CFR 491.2: in a non-urbanized area (Bureau of the Census) AND in a HRSA-designated shortage area (HPSA primary care, MUA, or Governor-designated).

What are the RHC productivity standards?

42 CFR 491.10: 4,200 visits per FTE physician per year; 2,100 visits per FTE midlevel per year. These standards inform cost-report calculations primarily for grandfathered provider-based RHCs.

How is an RHC different from a Federally Qualified Health Center (FQHC)?

RHCs are authorized under Section 1861(aa)(2); FQHCs under Section 1861(aa)(3). RHCs require non-urbanized location and shortage designation but no HRSA grant. FQHCs require HRSA Section 330 grant funding (or look-alike status), sliding fee scale, and patient-majority governing board. FQHCs are eligible for 340B drug pricing; RHCs are not.

How many RHCs are in Georgia?

Approximately 70-100 Medicare-certified RHCs as of 2026, with most being provider-based (hospital-affiliated). Distribution is concentrated in southern, southwest, and middle Georgia counties with HRSA shortage designations.

How do I find an RHC near me in Georgia?

Use the CMS Care Compare tool at medicare.gov/care-compare. Call Medicare 1-800-MEDICARE. Contact the Georgia State Office of Rural Health at 229-401-3090. Contact the Georgia Rural Health Association at 706-247-6320.

Can RHCs provide visiting nurse services?

Yes, under Section 1861(aa)(2)(B). RHCs in HPSA areas may furnish visiting nurse services to homebound beneficiaries in their residences, separate from the regular Medicare home health benefit.

Are RHC services covered by Medicare Advantage?

Yes. MA plans must cover RHC services at parity with Original Medicare. However, MA plans may have network restrictions. Beneficiaries should verify the RHC is in the MA plan's network before treatment.

Are RHC services covered by Medigap?

Medigap policies cover the 20% Part B coinsurance for RHC services. Plan G covers the 20% after the beneficiary pays the $257 annual deductible. Plan F (grandfathered for those enrolled before 2020) covers both the deductible and coinsurance.

Can I be seen at an RHC if I live in an urban area?

You can be seen at an RHC for healthcare regardless of where you live. However, the RHC itself must be located in a non-urbanized shortage area. Many rural RHCs serve patients from urban or non-shortage areas who visit family in the rural community.

What happens if a county loses its HPSA designation?

RHCs in counties that lose shortage designation can continue operating under a 4-year grace period. If the designation is not reinstated within 4 years, the RHC must close or relocate to a qualifying area.

Who oversees Georgia RHCs?

Federal oversight: CMS through the Survey & Certification process via Palmetto GBA Jurisdiction J Medicare Administrative Contractor. State coordination: Georgia State Office of Rural Health within DCH (229-401-3090). State professional society: Georgia Rural Health Association (706-247-6320). :::

Disclaimers

This guide is provided for educational purposes by Brevy. It is not legal, medical, or billing advice. Federal regulations at 42 CFR Part 491 and 42 CFR Part 405 Subpart X are authoritative for RHC certification and payment. Section 1861(aa)(2) of the Social Security Act is the statutory authority. CAA 2021 Sections 130 and 132 are the most significant recent reforms. For specific coverage questions, contact Medicare 1-800-MEDICARE or Palmetto GBA 1-877-567-9230.

RHC payment amounts described in this guide reflect federal policy in effect as of May 2026 and may change through annual CMS rulemaking. The independent RHC cap continues to increase under CAA 2021 Section 130 phased schedule. Beneficiaries should verify current amounts at the time of service.

State licensure and oversight of clinics in Georgia involve multiple agencies including the Georgia Department of Community Health, Georgia Composite Medical Board (physician supervision), Georgia Board of Nursing (NP scope of practice), and Georgia Composite Board (PA practice).

::: cta Contacts for Georgia Medicare Rural Health Clinic Services

  • DCH Medicaid Member Services: 1-866-211-0950
  • Medicare: 1-800-MEDICARE (1-800-633-4227)
  • Palmetto GBA Jurisdiction J: 1-877-567-9230
  • GeorgiaCares SHIP: 1-866-552-4464
  • Georgia State Office of Rural Health: 229-401-3090
  • HRSA Bureau of Primary Health Care: 301-594-4300
  • Georgia Hospital Association: 770-249-4500
  • Georgia Rural Health Association: 706-247-6320
  • National Rural Health Association: 816-756-3140
  • Kepro QIO: 1-844-455-8708
  • Atlanta Legal Aid: 404-377-0701
  • Georgia Legal Services Program: 1-800-498-9469
  • 211 Georgia: 211
  • Eldercare Locator: 1-800-677-1116
  • VA Benefits: 1-800-827-1000
  • HHS OCR: 1-800-368-1019
  • Medicare Rights Center: 1-800-333-4114
  • Center for Medicare Advocacy: 1-860-456-7790
  • Georgia Department of Public Health: 404-657-2700
  • Social Security: 1-800-772-1213 :::
BC

Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.