Medicare Telehealth Claims Need Two New Modifiers on January 1. The Answer Is in Your Platform Contract.

Starting January 1, 2027, Medicare requires two new modifiers on certain telehealth claims. CMS confirmed this in the Calendar Year (CY) 2027 Physician Fee Schedule final rule, published in the Federal Register on November 9, 2026. Modifier BB and modifier BC do not change what Medicare pays. That is exactly why they are easy to miss.

Congress required them in section 6209(g) of the Consolidated Appropriations Act, 2026. The question they answer is not clinical. It is how the visit was delivered and who has a contract with whom. Your billing team cannot answer that from the chart.

What each modifier means

CMS gives one definition for each:

• Modifier BB: the telehealth service was furnished through a virtual platform, and the physician or practitioner either contracts with the entity that owns the platform or has a payment arrangement with an entity for use of the platform.
• Modifier BC: the telehealth service was furnished incident to a physician's or practitioner's professional service.

CMS states that these modifiers have no payment implications. They report something about the visit. CMS's telehealth FAQ still tells practices to use place of service 02 or 10 for telehealth, and nothing in the rule changes that.

What CMS has not answered yet

The final rule says guidance on the modifiers will be on the CMS website. When we checked CMS's telehealth page on November 9, 2026, it had no modifier instructions. The only CMS wording we found is the definition in the final rule and two answers in its telehealth FAQ. That leaves practical questions open:

• Does a flat monthly subscription to a video tool count as a payment arrangement? On a plain reading of the words it may, but CMS has not said.
• Does video built into your electronic health record, paid for as part of that system, count?
• If a visit is furnished incident to and also runs on a contracted platform, are both modifiers reported?
• Will a Medicare claim without the modifier be returned, or paid and reviewed later?

Do not settle these from a vendor's sales page. Watch for CMS guidance and notices from your Medicare contractor, and keep your own decision in writing until they arrive.

Why a modifier with no payment effect still matters

CMS uses the word required. A modifier is a statement on a claim, so a wrong one is an inaccurate claim even if the payment is the same.

The wider telehealth rules also have a date to keep in view. Through December 31, 2027, Medicare patients can receive telehealth anywhere in the United States. From January 1, 2028, except for behavioral health services, they will generally need to be in a medical facility in a rural area. If telehealth is a large part of your schedule, that is the bigger planning date.

What to do before January

This is general information, not legal advice. Six checks:

• List every way your practice delivers telehealth: the platform, who owns it and who pays for it. Include video built into your electronic health record.
• Pull the contract or subscription for each one. Note whether a physician, the group or a third party holds it.
• Identify telehealth visits billed incident to, and who supervises them. Those are the visits to review for modifier BC.
• Ask your practice management vendor when BB and BC will be available in charge entry, and whether they can be set by platform instead of by hand.
• Add a claim scrubber rule for Medicare telehealth claims with dates of service on or after January 1, 2027, so that each one shows a decision on BB and BC. These are Medicare rules, so check each Medicare Advantage or commercial plan's own instructions before adding them there.
• Check CMS's telehealth page and your Medicare contractor's news page again in December, and change your rule if the guidance differs.

Then read your first January telehealth remittances closely. Returned claims or unfamiliar remark codes will show up there first, while the problem is still small.

Why it matters

The billing change here is one modifier. The work is finding out which contracts you have. If you want a second pair of eyes before January, a revenue review can look at one payer's denials over the last 90 days and show where your claims are most exposed.