Why Telehealth Modifiers Matter for Every Specialty
Since the Public Health Emergency (PHE), telehealth has evolved from an emergency measure to an integral part of U.S. healthcare delivery. Medicare continues to cover a broad range of telehealth services, making it essential for every provider, from primary care and mental health to cardiology and dermatology, to understand how to bill correctly. For telehealth claims, modifiers are not optional; they are the key to:
- Ensuring Medicare processes the claim as telehealth
- Avoiding denials and underpayments
- Remaining compliant with CMS rules
Understanding Modifiers and Copyright Limitations
In billing, a modifier is a short code appended to a CPT® or HCPCS code that signals a special circumstance, such as telehealth delivery.
Important Notice on Copyright: The American Medical Association (AMA) holds the copyright to CPT® codes and full modifier descriptions. This article does not reproduce full copyrighted text. Instead, we summarize the intended use of each modifier as permitted under CMS public guidelines. For complete and official definitions, you should refer to the AMA CPT Professional Edition.
The Key Medicare Telehealth Modifiers in 2025
While different specialties use different CPT/HCPCS codes, these core telehealth modifiers apply nationally to Medicare billing:
- 95: For live, interactive audio-video telehealth visits.
- 93: For audio-only telehealth visits, when video is unavailable or declined.
- FQ: For audio-only visits billed by Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs).
- GT: For telehealth claims from certain institutional settings (e.g., Critical Access Hospitals).
- GQ: For “store-and-forward” telehealth, limited to specific Alaska and Hawaii demonstration projects.
- G0: For tele-stroke evaluations via telehealth.
These are used in addition to your CPT/HCPCS service code, not instead of it.
Correct Place of Service (POS) Codes
CMS requires telehealth claims to also include the correct Place of Service:
- POS 02 – Telehealth provided outside the patient’s home
- POS 10 – Telehealth provided in the patient’s home
Example: If you perform a 15-minute established patient visit via live video while the patient is at home: CPT E/M Code + Modifier 95 + POS 10.
When to Use Which Modifier
- Modifier 95: Use for any real-time audio-video service where both patient and provider are present virtually. This is the most common telehealth modifier.
- Modifier 93: Use for audio-only visits if:
- Video technology is not available, or
- The patient declines video
- Document the reason in the patient’s record.
- Modifier FQ: Only for FQHC or RHC services delivered audio-only.
- Modifier GT: Mostly used on institutional claims from Critical Access Hospitals.
- Modifier GQ: Rare; limited to federal demonstration programs in Alaska and Hawaii.
- Modifier G0: Only for stroke-related telehealth evaluations.
Temporary Medicare Flexibilities (Through September 30, 2025)
Until September 30, 2025, Medicare will:
- Cover non-behavioral telehealth from any location, including the patient’s home.
- Continue to allow audio-only for certain non-behavioral services if criteria are met.
- Permit FQHCs and RHCs to serve as distant site providers for non-behavioral telehealth
Behavioral/mental health telehealth coverage, including audio-only, is permanent and not subject to these dates.
Documentation Requirements for All Specialties
- Modality: Clearly indicate if the service was audio-video or audio-only.
- Location: Document the location of both patient and provider.
- Duration: For audio-only, document the total minutes spent.
- Reason for Audio-Only: State if video was unavailable or declined.
- Modifier & POS: Apply both correctly for every telehealth claim.
Common Errors to Avoid
- Wrong POS Code: POS 02 and POS 10 mix-ups cause denials.
- Missing Modifier: Leads to the claim being processed as in-person.
- Improper Audio-Only Use: Modifier 93 should not be used for services that could be done via video without a valid reason.
- Facility Mismatch: Do not use FQ or GT unless you meet the facility type requirement.
New Codes in 2025: What to Know
CMS has introduced telehealth-specific CPT codes in the 98000 – 98015 range for audio-video and audio-only visits. However:
- Medicare still primarily relies on existing E/M codes plus the correct modifier (95 or 93).
- Private payers may adopt the new 980xx codes sooner; check your contracts.
Practical Steps for Providers
- Update Billing Templates: Include modifiers and POS codes as defaults for telehealth.
- Train Staff: Ensure schedulers and billers know when to use 95, 93, FQ, etc.
- Verify Annually: CMS updates the telehealth list every January; rules can change.
- Review MAC Guidance: Local Medicare Administrative Contractors may have slight claim submission differences.
Limitations of This Article
This article does not provide or reproduce full CPT code/modifier descriptions; refer to AMA CPT® resources for official language. The guidance here is based on Medicare rules; other payers may differ. Information is accurate to the best of our knowledge as of August 2025; always confirm before submission.
Conclusion
Telehealth modifiers are the key to Medicare compliance and reimbursement for virtual care. Regardless of your specialty or state:
- Use the correct modifier for the service type.
- Pair it with the correct POS code.
- Document thoroughly to support the claim.
How Medisys Can Help
As a nationwide medical billing and coding partner, Medisys helps healthcare providers across all specialties and all states navigate the complexity of telehealth billing. We monitor CMS updates, train staff, and audit claims to ensure:
- Accurate use of telehealth modifiers
- Clean claim submission
- Faster reimbursement with fewer denials
Telehealth billing can be complex, but with the right expertise, it doesn’t have to be. Contact us today for our telehealth billing services.
