2027 Medicare Telehealth Modifiers BB and BC: When Should Physicians Use Them?
Starting January 1, 2027, Medicare telehealth claims will need to carry two new modifiers where they apply: BB and BC. Congress told CMS to create them in the Consolidated Appropriations Act, 2026, and CMS is putting them in place through the CY 2027 Physician Fee Schedule final rule. CMS has said they don't affect payment. They do affect what your claim says, and guessing wrong can mean rework and claim questions you didn't need.
The tricky part: BB and BC aren't about video or audio. One points to your relationship with the platform owner. The other points to whether the service was furnished incident to someone else's professional service. This guide covers each, what's confirmed, and what still needs official guidance.
At a glance Effective: dates of service on or after January 1, 2027. Source: Public Law 119-75 (Consolidated Appropriations Act, 2026) and the CY 2027 PFS final rule (CMS-1848-F). Payment effect: none, per CMS. Telehealth flexibilities: run through December 31, 2027 under current law. |
Key dates. The final rule was released November 4, 2026.
What Are Medicare Telehealth Modifiers BB and BC?
Modifiers add context to a claim line. CMS wants Medicare telehealth claims to show how certain services were delivered, specifically platform arrangements and incident-to services, without changing coverage or payment. CMS has said it will post further guidance on its website, so treat this as a living topic.
Modifier BB Definition: telehealth furnished through a virtual platform where the practitioner contracts with, or has a payment arrangement with, the entity that owns the platform. Applies when: the platform relationship fits CMS's definition. In plain English: it flags how you're connected to the platform owner. Effective: January 1, 2027. Payment effect: none. |
| Modifier BC Definition: telehealth furnished incident to a physician's or practitioner's professional service. Applies when: the service is actually furnished incident to. In plain English: it flags the incident-to arrangement. Effective: January 1, 2027. Payment effect: none. |
Reporting a modifier is separate from whether the underlying telehealth service is covered and payable. A claim can still fail on coverage rules even if BB or BC is correct, and correct coverage doesn't excuse a missing modifier.
Modifier BB: When Should Physicians Use It?
Think of BB as a relationship flag. It applies where the practitioner contracts with an entity that owns the virtual platform, or has a payment arrangement with that entity for using it. Using video software isn't the test.
Two illustrative examples
• Example 1: A physician group signs a services agreement with a company that owns a telehealth platform. The contract is with the platform owner, so the billing team should evaluate BB.
• Example 2: A physician pays a company a recurring fee to use its platform. That's a payment arrangement with the entity, so the team should evaluate BB.
These examples illustrate the definition. They don't replace your actual agreements or CMS's current instructions.
Questions to ask when reviewing a platform agreement
• Who actually owns the platform: the vendor, a reseller, or your own organization?
• Is your contract or payment arrangement with that owner?
• Does money flow for platform use, and in which direction?
• Who is the billing practitioner, and who keeps the agreement on file?
Key takeaway The key question is not simply whether a physician uses video technology. It is whether the platform relationship meets CMS's definition for modifier BB. |
Modifier BC: When Does Incident-to Billing Apply?
Incident-to is an existing Medicare concept (42 CFR 410.26): services furnished as an integral part of a physician's or practitioner's professional service, subject to supervision and other requirements. Law-firm summaries of the CY 2026 rule note that CMS now allows direct supervision through real-time audio/video for most incident-to services, excluding certain global-surgery services. Confirm the current text before relying on it.
BC doesn't create incident-to eligibility. It reports that a telehealth service was furnished that way. If the service doesn't meet the incident-to rules, adding BC doesn't fix it. Before reporting BC, confirm:
• Who furnished the service, and whose professional service it's incident to.
• Who supervised, how, and whether that meets current requirements.
• Who bills, and that the service and billing practitioner line up.
• That your documentation supports the arrangement (a practical recommendation, not a stated CMS requirement).
That's why BC shouldn't be added to every telehealth encounter automatically.
Modifier BB vs. BC: Key Differences
Comparison factor | Modifier BB | Modifier BC |
Main focus | Qualifying virtual platform relationship | Incident-to professional service arrangement |
Applies when | A CMS-defined platform contract or payment arrangement exists | Telehealth is furnished incident to a professional service |
Effective date | January 1, 2027 | January 1, 2027 |
Payment implications | None | None |
Key billing check | Verify the platform relationship | Verify incident-to circumstances |
They answer different questions, so don't treat them as interchangeable. We also haven't seen CMS state that they're mutually exclusive, so don't assume that either way.
How BB and BC Compare With Modifiers 93, 95 and FQ
Modifier | General purpose |
BB | Qualifying virtual telehealth platform relationship |
BC | Telehealth service furnished incident to a professional service |
95 | Synchronous telemedicine using real-time audio and video |
93 | Synchronous telemedicine using real-time audio-only communication |
FQ | Audio-only telehealth in certain RHC/FQHC billing situations (verify current applicability) |
Different modifiers communicate different things. BB and BC don't replace 93 or 95, and they don't tell Medicare whether a visit was audio-video or audio-only.
POS 02 vs. POS 10: What Physicians Should Know
POS 02 Telehealth when the patient is not in their home. Describes where the patient is. |
| POS 10 Telehealth when the patient is in their home. Describes where the patient is. |
Place of service describes the patient's location. BB and BC describe the platform arrangement and incident-to status. Choosing one never answers the other. Check current CMS payment guidance before describing any reimbursement difference between the two.
Practical 2027 Billing Scenarios (Illustrative Only)
These are screening examples, not universal coding instructions.
Scenario | Billing consideration |
Physician uses a platform under a qualifying contract | Evaluate modifier BB |
Physician uses a platform under a qualifying payment arrangement | Evaluate modifier BB |
Telehealth service is furnished incident to a professional service | Evaluate modifier BC |
Standard independent telehealth encounter | Don't automatically assume BB or BC |
Audio-only service | Evaluate audio-only billing rules separately |
Audio-video service | Evaluate audio-video billing rules separately |
Which Modifier Should Your Billing Team Evaluate?
Answer two questions for each service type or arrangement. Q1: Is there a qualifying contract or payment arrangement with the platform-owning entity? Q2: Is the service furnished incident to a professional service?
This guide is an educational screening aid, not an official CMS coding determination.
10 Medicare Telehealth Billing Mistakes to Avoid in 2027
Mistake | How to prevent it |
1. Confusing BB with BC | Keep a one-page definition sheet at every biller's desk. |
2. Reporting without checking the arrangement | Verify the contract or incident-to setup before reporting. |
3. Assuming every virtual visit needs BB | Tie BB to the platform agreement, not to video use. |
4. Applying BC without confirming incident-to | Review supervision and billing roles first. |
5. Confusing BB/BC with 93 and 95 | Train staff that they carry different information. |
6. Selecting POS codes incorrectly | Audit POS 02 and 10 against documented patient location. |
7. Ignoring CMS updates | Assign one person to monitor CMS and MAC notices. |
8. Not telling staff | Hold a short briefing before January 1. |
9. Incomplete platform agreement records | Keep current agreements in one searchable place. |
10. Assuming modifiers decide payment | Remember CMS says they have no payment effect. |
Is Your Practice Ready for January 1, 2027?
☐ Review virtual platform contracts.
☐ Identify platform ownership arrangements.
☐ Review payment arrangements involving telehealth platforms.
☐ Identify services furnished incident to professional services.
☐ Educate billing specialists on BB and BC.
☐ Review current CMS telehealth guidance.
☐ Review existing 93 and 95 workflows.
☐ Verify POS 02 and POS 10 reporting.
☐ Update billing system workflows where necessary.
☐ Review claim edits and internal procedures.
☐ Set up a process to monitor CMS updates.
☐ Conduct periodic telehealth claim audits.
Progress: ____ of 12 complete.
How Billing Teams Should Prepare
Start with a workflow assessment: map where telehealth claims get built and who decides modifiers. Then review platform contracts, identify incident-to services, and train staff. Test claims before January, validate modifiers, and run internal audits after go-live. Track results in your revenue cycle reporting and keep watching CMS and your Medicare Administrative Contractor. Correct modifier reporting is one piece of a broader compliance-focused revenue cycle.
Preparing Your Practice With Sirius Solutions Global
Sirius Solutions Global is a medical billing and revenue cycle management partner supporting healthcare providers across the United States. For telehealth changes like these, our teams can help with medical billing and coding, claims review, advanced eligibility verification, denial management, prior authorization, credentialing and re-credentialing, A/R management, billing audits, and revenue leakage assessments. We use technology-assisted workflows with human verification.
We can help you spot workflow gaps and organize your review. We don't hold any special CMS certification or authority over modifier rules, and we can't guarantee claim approval or reimbursement. Learn more at
How Prepared Is Your Practice? A 2-Minute Self-Check
Score each answer: Yes = 2, Unsure = 1, No = 0.
Question | Your score |
1. Have you reviewed your telehealth platform agreements? |
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2. Can your billing team distinguish BB from BC? |
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3. Have you identified incident-to telehealth services? |
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4. Are your telehealth modifier workflows documented? |
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5. Do you regularly review Medicare billing updates? |
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Total | Result |
8 to 10 | Ready for further validation |
5 to 7 | Some workflow gaps to review |
0 to 4 | Additional billing preparation recommended |
This is an internal readiness check, not a CMS compliance score.
Still waiting on official guidance In what we reviewed, these points weren't settled. Check CMS transmittals and your MAC before deciding: claim-line placement and modifier sequencing; whether BB and BC may appear together on one claim; how edge cases such as resellers or EHR-embedded platforms are treated; and MAC edit timing. |
Frequently Asked Questions
What is Medicare modifier BB for 2027?
A modifier for telehealth furnished through a virtual platform where the practitioner contracts with, or has a payment arrangement with, the platform-owning entity. It's required from January 1, 2027.
What is Medicare modifier BC?
A modifier for telehealth furnished incident to a physician's or practitioner's professional service, also required from January 1, 2027.
When do BB and BC take effect?
For dates of service on or after January 1, 2027.
Does BB affect reimbursement?
CMS has said no. It's a reporting requirement, separate from coverage and payment.
Does BC affect reimbursement?
CMS has said no, for the same reason.
Can both be used on the same claim?
We haven't found CMS guidance saying they're exclusive or that they're required together. Review CMS instructions before deciding.
What's the difference between BB and BC?
BB reflects the platform relationship. BC reflects incident-to status.
Does BB or BC replace modifier 95?
No. Modifier 95 describes real-time audio and video.
Does BB or BC replace modifier 93?
No. Modifier 93 describes real-time audio-only communication.
Are they required for every Medicare telehealth visit?
No. They apply where the described circumstances exist. Don't append them automatically.
How do POS 02 and 10 relate?
POS describes patient location (02 not at home, 10 at home). It's separate from BB and BC.
How should billing teams prepare?
Review platform contracts, identify incident-to services, train staff, test claims, audit, and monitor CMS updates.
Disclaimer
This article is for general educational purposes only. It isn't legal, coding, billing, or compliance advice, and it isn't an official CMS determination. Medicare rules change, and requirements may differ by Medicare Administrative Contractor and situation. Examples are hypothetical. Verify current requirements with CMS and your MAC, and consult qualified counsel or a certified coder before acting. Sirius Solutions Global isn't affiliated with CMS and doesn't guarantee claim approval, reimbursement, or compliance outcomes. CPT is a registered trademark of the AMA.
