Audio-only telehealth remains an important option for healthcare providers serving patients who cannot tolerate or prefer telephone visits. However, practices must follow the correct billing rules for each applicable payer to receive reimbursement for these services. A misplaced or misapplied modifier, inappropriate documentation, or a procedure code that does not match the delivered service can result in denied claims and delayed payments.
One major change is on the horizon for healthcare providers in Rhode Island. Effective January 1, 2027, Neighborhood Health Plan of Rhode Island (Neighborhood) will require the proper modifier to be reported on claims for audio-only telemedicine services provided to its members. As currently proposed, modifier 93 would be reported on all lines of business, with the exception of Federally Qualified Health Center (FQHC) Medicare claims. Additionally, modifier FQ would be required for audio-only telemedicine services rendered by FQHCs to INTEGRITY for Duals and Dual CONNECT members.
Medical practices, community health centers and billing teams should study this modification and impact on their operations closely prior to this effective date.
For healthcare providers looking for medical billing services in Rhode Island, understanding the difference between modifier 93 and FQ is a critical step toward higher-quality claims, fewer denials, and more predictable income. Practices providing primary care can also benefit from specialized family practice billing services to manage payer-specific coding and claim submission requirements.
What Is the January 2027 Audio-Only Telemedicine Billing Update?
Neighborhood’s new policy reflects a broader shift toward Medicare-like rules for audio-only telemedicine claims. Practices should be aware of and follow instructions related to a specific payer, plan, and setting in order to identify the appropriate modifier for a telemedicine claim.
This change is effective for dates of service on or after January 1, 2027. When reviewing this policy, billing teams should focus on the date of service rather than the date of claim submission as a criterion for determining modifier requirements.
The requirements can be summarized as follows:
- Modifier 93: Required for audio-only telemedicine claims across all of Neighborhood’s lines of business, except for FQHC Medicare claims.
- Modifier FQ: Required for audio-only telemedicine services provided by FQHCs to INTEGRITY for Duals and Dual CONNECT members.
- FQHC Medicare claims: Exception to the general modifier 93 requirement. Providers should carefully follow Medicare and payer instructions related to these services before submitting claims to Neighborhood.
Neighborhood has also released an updated Telemedicine/Telephone Services Payment Policy, reflecting this change. This document should be reviewed carefully, rather than applying older billing instructions.
This update does not suggest that any telephone visit is reimbursable. Practices need to make sure that services meet all applicable coverage, coding, documentation and medical necessity standards before they submit a claim.
Modifier 93 Vs. FQ: What Is the Difference?
Which modification to choose for a specific claim is rarely a binary issue. Clinicians should address the individual needs of each encounter, as well as follow guidelines from the relevant payer, before submitting a modifier on a claim.
Modifier 93: Audio-Only Telemedicine Services
Modifier 93 identifies a synchronous audio-only telemedicine service delivered via telephone or real-time audio-only telecommunications system.
As outlined in this billing update, this modifier will generally be reported on audio-only telemedicine claims for all of Neighborhood’s lines of business, with the exception of FQHC Medicare claims.
Before reporting this modifier, billing teams should ensure that:
- The service was delivered using a qualifying real-time audio-only communications system.
- The underlying CPT or HCPCS code accurately describes the service.
- The service and reported modifier are both allowed by the payer.
- Documents support the reported service, including the medical necessity of the encounter.
- The claim meets all applicable provider, place-of-service, and coverage criteria.
Reporting modifier 93 identifies the method of communication used for a synchronous telemedicine service, but it does not independently identify medical necessity or ensure reimbursement.
Modifier FQ: Audio-Only Services for Eligible FQHC Claims
Modifier FQ is generally associated with qualifying audio-only services reported by FQHCs under specific payer instructions.
The instruction for this update is straightforward: FQHCs should report modifier FQ for audio-only telemedicine services provided to INTEGRITY for Duals and Dual CONNECT members.
This requirement is not a blanket rule for all FQHC claims or for all Medicare enrollees. The member plan and program instructions define the proper technique to take in a given circumstance.
FQHC billing teams should identify members who are qualified for this benefit prior to producing claims, ensure that services meet the standards of this modifier, and modify their practice to report the appropriate modifier in compliance with this change.
Quick Comparison of Modifier 93 and FQ
| Billing consideration | Modifier 93 | Modifier FQ |
| Purpose | Identifies qualifying synchronous audio-only telemedicine | Identifies qualifying audio-only services under applicable FQHC billing rules |
| Neighborhood requirement effective January 1, 2027 | Applies across lines of business, except FQHC Medicare claims | Required for specified FQHC services to INTEGRITY for Duals and Dual CONNECT members |
| Primary billing check | Confirm service, payer, and code eligibility | Confirm FQHC status, member plan, and applicable program requirements |
| Denial prevention | Verify modifier placement and supporting documentation | Verify member eligibility and payer-specific modifier requirements |
Please note that these two modifiers are not interchangeable. The proper modifier to use would be based on the instructions for the billing attached to a claim, which are based on the nature of service and the payer.
Medicare Telehealth Billing Rules Providers Should Understand in 2027
There are a number of special issues to consider about the Medicare guidelines on telehealth billing. The compensation for these services is determined based on the kind of service, the provider that rendered the service, the delivery method, and the modifier that applies.
For current Medicare telehealth coverage requirements and related billing guidance, review the Centers for Medicare & Medicaid Services (CMS) telehealth resources.
But these restrictions differ based on the service and setting, and practitioners should not assume that all telephone encounters will be reimbursable by Medicare. Instead, providers should evaluate the particular requirements for a given service and setting when determining whether these services meet Medicare’s eligibility criteria.
Medicare Modifier 93 Requirements
Modifier 93 is used to identify a synchronous, audio-only telemedicine service, although use of this modifier does not guarantee payment. This modifier must be appended to a qualifying service in line with the applicable Medicare guidance for the service type and environment.
For example, CMS advice for Rural Health Clinics (RHCs) and FQHCs distinguishes between audio-only and audio-video services. Modifier 93 is used to identify the latter, while modifier 95 is used to identify qualifying synchronous audio-video telemedicine services.
These examples indicate that modifiers specify how a service was delivered but do not negate the need to record an eligible service code or to meet Medicare’s coverage requirements for a service.
Medicare Rules for FQHCs and RHCs
FQHC billing teams and RHCs should take note of this recent update and its impact on distant-site telehealth claims in 2027. Effective October 1, 2026, CMS guidance states that, instead of the HCPCS code G2025, these providers should bill the individual CPT or HCPCS code descriptions of the eligible distant-site telehealth services and a suitable modifier.
Billing instructions may vary by service category. However, teams can continue to bill non-behavioral health distant-site telehealth services under HCPCS code G2025 through December 31, 2027, unless CMS guidance specifies otherwise.
In other words, providers are not able to use identical billing guidance to bill FQHC and RHC claims for telehealth services. Teams should determine the type of service, date of service, applicable eligible code, and instructions from Medicare.
They can find more information in the CMS Medicare telehealth resources and Medicare Telehealth Services List.
CPT and HCPCS Coding Considerations for Audio-Only Telehealth
Correct modifier selection is only one element of the larger task of submitting a properly coded claim. Billing teams then need to select the appropriate process code, corresponding to the encounter type, payer guidelines, and other factors.
CPT and HCPCS codes identify the services provided, while modifiers describe additional aspects of an encounter, such as how the service was delivered. Professional medical coding services can help practices select appropriate codes and modifiers based on the encounter and applicable payer policies.
Such as, where the service is eligible for a code, according to the criteria required for that code, then a code associated with an E/M code can be utilized to code for the evaluation and management (E/M) service. Behavioral health service rules may vary.
Practices should not pick a code only because a service was provided over the telephone. Providers can consult the official Medicare telehealth billing and coding guidance to review eligible services, coding requirements, and common billing mistakes.
Rather, the team needs to check that the code represents the work involved in the encounter, the documentation requirements for that code, and the rules of the applicable payer.
Prior to submitting an audio-only telehealth claim, a practice should confirm the following:
- The CPT or HCPCS code accurately identifies the service.
- The code is an eligible service for the applicable telehealth benefit.
- Modifier 93, FQ, or another required modifier identifies the service in accordance with the instructions of the payer.
- Applicable place-of-service requirements for this code are met.
- All provider, diagnosis, and claim information is included and accurate.
- Eligibility requirements for this service are met, including documentation and medical necessity.
No procedure code is appropriate for every audio-only encounter, and modifier 93 or FQ should not be used as a substitute for an accurate description of the service delivered.
Documentation Requirements for Audio-Only Telehealth Claims
Correct documentation supports the delivery of relevant patient care and the submission of correct claims. Although documentation guidelines are different for every service and payer, every practice should create an accurate record of each patient visit to support a claim.
The medical record should include the information relevant to the service provided and the requirements of the payer.
Essential Information to Document
The medical record should include the following information when relevant and according to the instructions of the payer:
- Date and Time: The date and time of the encounter.
- Communication Method: The synchronous audio-only method of this encounter.
- Purpose: The presenting concern, history, assessment, and treatment plan for the patient.
- Provider Information: Rendering practitioner and applicable credentials.
- Time and Service Details: Time or other service details, when applicable and according to the code.
- Medical Necessity: The justification for this service in terms of the patient’s health needs.
- Follow-Up Plan: Recommendations, treatment adjustments, referrals, and another follow-up, when applicable.
Document the service actually provided. Record a telephone encounter as audio-only, not audio-video, unless the provider used both audio and video. Likewise, report a brief conversation as a billable service only when it meets the applicable requirements.
Practices should follow any additional documentation requirements for behavioral health treatments or other specialty visits.
Common Audio-Only Telehealth Claim Denials
Incorrect modifier reporting can lead to delayed reimbursements, denied claims, and unnecessary rework. Understanding how medical claim adjudication works can help billing teams interpret payer decisions, investigate claim issues, and determine whether corrections or appeals are appropriate.
Missing Modifier 93
A qualifying Neighborhood audio-only telehealth claim may be denied if modifier 93 is missing for dates of service on or after January 1, 2027.
Prevention: Update claim rules before the effective date. Apply modifier 93 to qualifying services, except FQHC Medicare claims, and follow the applicable payer requirements.
Wrong Use of Modifier FQ
Reporting of modifier FQ without verifying applicable FQHC and member-plan requirements may result in a mismatch with Neighborhood’s policies.
Prevention: Use eligibility and billing policy checks to identify claims for INTEGRITY for Duals and Dual CONNECT members that involve FQHC providers.
Incorrect CPT or HCPCS Code
The reported procedure code may not indicate the service provided or the applicable telehealth billing edit.
Prevention: Double-check the code description, service documentation, and payer requirements before submission.
Incomplete Clinical Documentation
The documentation may lack details required to establish the purpose of the encounter, the service provided, and the mode of communication.
Prevention: Set standard documentation requirements and ensure that all services get properly recorded.
Use of Outdated Payer Policies
A billing team may rely on a modifier policy that was appropriate prior to the change but no longer applies to a specific date of service.
Prevention: Store the latest version of all payer policy documents and ensure that all providers and claim submitters understand the updates.
Incorrect Application of Medicare Rules
Medicare rules may differ depending on a provider’s setting, type of service, and date of service. A general telehealth modifier rule may be incorrectly applied to all FQHC or RHC claims, resulting in errors.
Prevention: Separate claims based on payers’ requirements and consult CMS guidelines for services and settings.
How Medical Billing Teams Can Prepare for January 1, 2027
To avoid disruptions to the revenue cycle, healthcare providers need to prepare for the coming changes early. The sooner the practice starts analyzing the new regulations, the more time it has to rectify errors and avoid claim rejections.
Review Payer Policies
Download the updated Neighborhood Telemedicine/Telephone Services Payment Policy and confirm how the modifier requirements affect your services, members, and care settings. Alongside this review, verification of benefits VOB. can help staff identify relevant coverage limitations and benefit requirements before submitting claims.
Update Billing Software
Set your claim edit rules so that qualifying audio-only services are correctly identified and that the appropriate modifier is applied based on a payer’s rules and provider categories. Avoid a universal application of a single modifier (e.g., 93) or a blanket exception for FQHC practices.
Train Providers and Billing Teams
Educate your staff on audio-only and audio-video billing requirements. Emphasize accurate coding, documentation, and claim submission. Practices handling complex patient encounters can also benefit from specialized internal medicine billing services to improve coding accuracy, meet payer requirements, and follow up on claims.
Audit Sample Claims
Before test claims go live, audit to make sure there is no missing modifier on a service, inaccurate procedure code, missing documentation, or incorrect payer information.
Monitor Denials and Reimbursements
After January 1, 2027, monitor the reasons for claim denials, delayed reimbursements, and claim corrections related to the new modifier edits. Use this information to update your billing processes.
Medical practices that lack the resources to update their billing processes can turn to professional medical billing services to ensure smooth claim submission and payment.
How Professional Medical Billing Services Help Rhode Island Providers
After making telehealth-related modifications, medical practices need to update their billing processes. Monitoring payer policy changes, coding requirements, and denied claims can overwhelm in-house staff. This is especially true for small practices working with multiple payers.
Third-party medical billing services can handle these tasks and reduce administrative work. They also help staff manage documentation and focus more on patient care.
Such companies usually provide the following services:
- Medical coding: Reviewing medical records to ensure that all procedure codes, modifiers, and documentation requirements are met;
- Claim submission: Eliminating errors due to payer-specific billing guidelines;
- Denial management: Addressing claim rejections and preventing future errors;
- Eligibility verification: Ensuring that services are covered and appropriate modifiers are used;
- Accounts receivable management: Following up on outstanding balances and tracking denied claims;
- Revenue cycle management: Covering the end-to-end claims lifecycle, from pre-claim submission checks to coding, billing, payment posting, and denial follow-up.
Healthcare providers in primary care, behavioral health, and community health can benefit from comprehensive billing support. These services can help streamline telehealth reimbursements and reduce administrative work.
An experienced billing partner can also help practices adapt to changing telehealth policies. However, reimbursement still depends on coverage terms, medical necessity, accurate coding, complete documentation, and compliance with payer requirements.
Final Thoughts
The January 1, 2027, Neighborhood audio-only telemedicine service modifier update requires RI healthcare providers to make several adjustments to their medical billing processes. Modifier 93 will be applicable to all qualifying audio-only telemedicine claims, with the exception of FQHC Medicare claims. In addition, audio-only telemedicine services provided to INTEGRITY for Duals and Dual CONNECT members through FQHC facilities must include modifier FQ.
Prior to the effective date, medical practices should update their billing processes and familiarize their staff with the new policies. In addition, it is essential to ensure that a practice’s telehealth-related claims meet all relevant requirements, including those specific to Medicare. Understanding the scope of a provider’s services and settings may also help in determining the applicability of a specific modifier.
For practices seeking expert support, partnering with a professional medical billing company in Rhode Island can help providers improve claim submission accuracy, manage denials, and follow up on outstanding payments. Reviewing payer requirements before submitting claims can also help practices maintain more efficient billing workflows.
Frequently Asked Questions
Does every Neighborhood audio-only telehealth claim require modifier 93 beginning January 1, 2027?
Neighborhood’s new policy applies the modifier to all lines of business, with the exception of FQHC Medicare claims. You should follow the updated modifier reporting rules for your services and members.
When should an FQHC use modifier FQ?
Per Neighborhood’s new modifier policy, FQHCs should report modifier FQ for audio-only telemedicine services rendered to INTEGRITY for Duals and Dual CONNECT members. You should verify the requirements for your members and payers prior to claim submission.
Can modifiers 93 and FQ be used interchangeably?
No, a billing team should consider each modifier’s application scope and specific payer requirements prior to its use. These two modifiers are not interchangeable.
Does the addition of modifier 93 guarantee reimbursement from Medicare?
No, the modifier only indicates that a service was provided via an appropriate method of communication. Additional considerations should be made to ensure that a service’s nature and clinical documentation meet all Medicare requirements.
How can I prevent audio-only telehealth claim rejections and denials?
To reduce billing errors, review all requirements before submitting claims. Check the payer policy and verify member eligibility. Confirm the service code and document each telehealth encounter properly. Apply the correct modifier and monitor denial trends.