Modifier 95, 93: Telemedicine

CPT® has two modifiers for telemedicine. CMS and private payers regularly change their instructions about using these modifiers and what place of service to use.  As of 2024, CMS no longer requires modifier 95 on claims but rather hopes to capture modality plus place of service by use of either POS 02 or POS 10.[1] (POS codes in the footnote.)

• Modifier 95 is for use with real-time, audio/visual visits.
• Modifier 93 is for audio-only telehealth services

Modifier 93: Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-only Telecommunication System

• The services that the AMA feels can be performed via audio-only are listed in Appendix T of the CPT® book.

Modifier 95: Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunication System

• Again, the services that the AMA feels that can be performed by audio-video are listed in Appendix P of the CPT® book.

What about those non-AMA modifiers that CMS sometime requires?

*Modifier GT is used by distant site practitioners billing telehealth under the CAH Optional Payment Method II, on institutional claims.

*Modifier GQ (audio only) is for FQHCs and RHCs to use for Audio-Only.

*Modifier FQ is for behavioral health telemedicine services

Of course, CMS has a list of services that may be performed via telehealth and all of them can be done via audio-video and via audio only. There was a column that indicated if the service could be performed via audio-only but that was deleted, for Calendar Year 2025. With the deletion of 99441, 99442 and 99443 (E/M telephone CPT® codes), any service that a patient prefers to be done via audio only, or does not have the technology for audio/visual may  be done via audio only, as long as the provider has the capability for audio-video. [NOTE: this is only through September 30, 2025 for medical services, but is permanent for behavioral health services.] The remaining column indicates if the service is permanently added to the telehealth list or is provisional or in plain language – under consideration by CMS.

• You can download the CMS telehealth list from their site: https://www.cms.gov/medicare/coverage/telehealth/list-services

Private payers have continuously updated their telehealth rules, and each must be researched separately. (But for the most part, they follow Medicare guidelines.)

Also, starting on January 1, 2025, CMS paid and continues to pay for telehealth services provided to patients in their homes at the non-facility PFS rate.

CPT® Telehealth Codes:

CPT® added 17 new CPT® codes for audio only, audio/visual visits. These are divided into new and established patient visits and my be selected by either time or MDM definitions. CMS has given 16 of the 17 a status indicator of invalid, that is, they don’t pay them. CMS does pay for 99016, which replaced G2012, brief telecommunications service. And looking at the AMA’s May 2025 CPT panel’s agenda, it seems they are considering deleting 16 of the 17 codes, 98000–98015 and designating office visit codes as telehealth in 2026.  According to a recent DecisionHealth/Part B Survey, not many payers are recognizing the telehealth codes.

Appendix P in the CPT® books lists codes that may be performed via telehealth using synchronous, real-time, interactive audio-video services.  These are also indicated with a star in the main body of CPT®.  Office visits were removed from this list in the 2025 CPT book, because CPT® added specific telehealth codes.

Appendix T in the CPT® book lists codes that may be performed via audio-only technology. There is a symbol that looks like a speaker to indicate those in the main body of CPT®.

The new CPT® telehealth codes (which may be deleted in 2026) don’t have either the star or speaker symbol next to them, presumably because they are already defined as telehealth.

Some Medicaid plans have adopted the CPT® codes and others have not. You must check with your individual states’ plans to determine what CPT® codes to use for these services (either the new codes or 99202-99215, largely).

And once again, what modifier should you use?

Despite CPT® removing office visit codes from the telehealth list, if you are performing office visits (or other E/M services), use modifier 93 for audio-only services and modifier 95 for real-time audio/visual telehealth services.  Even though CMS doesn’t require modifier 95, but does want the correct POS, I suggest using it.

Note that Medicaid plans may or may not support use of 93, 95 but also prefer GT and GQ. It just depends. As for commercial payers, use the CPT® modifiers 93 or 95, unless they specifically tell you differently.

[1] Recall the following, per the CMS POS List (https://www.cms.gov/medicare/coding-billing/place-of-service-codes/code-sets):

• 02: Telehealth Provided Other than in Patient’s Home: The location where health services and health related services are provided or received, through telecommunication technology. Patient is not located in their home when receiving health services or health related services through telecommunication technology.
• 10: Telehealth Provided in Patient’s Home: The location where health services and health related services are provided or received, through telecommunication technology. Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence) when receiving health services or health related services through telecommunication technology.