Telehealth Modifiers BB and BC: What Urgent Care Virtual Visits Need for 2027

What Are Telehealth Modifiers BB and BC?

Telehealth modifiers BB and BC are new Medicare claim modifiers that identify how a telehealth service was delivered. As of November 2026, CMS has finalized that BB is required when a clinician furnishes telehealth through a virtual platform owned by an entity they contract with or pay, and BC is required for telehealth furnished incident to a physician’s service, starting January 1, 2027.

• No payment change: CMS says the modifiers do not affect payment, but they are required on claims beginning January 1, 2027.
• Who is affected: Urgent care groups that run virtual visits through third-party platforms or bill telehealth incident to a physician.
• What to do now: Map every virtual visit workflow to the right modifier and update claim edits before January.

What CMS Finalized on November 4

On November 4, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule final rule, CMS-1848-F, published in the Federal Register on November 9, 2026. Among its telehealth provisions, CMS created two new modifiers required by section 6209(g) of the Consolidated Appropriations Act, 2026.

According to the final rule, the modifiers are required for claims for telehealth services in two situations:

Modifier BB. Telehealth services furnished through a virtual telehealth platform by a physician or practitioner who contracts with an entity that owns the platform, or who has a payment arrangement with an entity for use of the platform.

Modifier BC. Telehealth services furnished incident to a physician’s or practitioner’s professional service.

CMS stated that the modifiers do not have payment implications and are required beginning January 1, 2027. CMS did not ask for comments on creating them, but in response to requests for clarification it pointed providers to its Medicare telehealth page, where guidance will be posted. The law also lets CMS issue further instructions through subregulatory guidance rather than formal rulemaking, so details can change between now and January.

The same rule implemented other telehealth extensions from the Consolidated Appropriations Act, 2026. The geographic restrictions, expanded originating sites, and expanded list of eligible practitioners are extended through December 31, 2027. Audio-only telehealth flexibilities and the delay of in-person requirements for mental health telehealth are extended to January 1, 2028. Separately, the CY 2026 Physician Fee Schedule made virtual direct supervision through real-time audio and video permanent for many services, which is why incident-to telehealth, and now modifier BC, matters for urgent care groups.

Which Urgent Care Practices Need Modifiers BB and BC?

Urgent care practices need modifier BB when clinicians deliver Medicare telehealth through a platform owned by another company they contract with or pay, and modifier BC when telehealth is billed incident to a physician. Practices that only see patients in person, or do not bill Medicare for telehealth, are not affected by the new requirement.

One question we hear constantly from urgent care operators is whether a simple video visit vendor counts as a platform arrangement. As written, the BB language covers both contracting with the entity that owns the platform and having a payment arrangement for its use, which could reach many common setups. Until CMS publishes detailed guidance, practices should assume their arrangement may qualify and plan accordingly.

Groups using a virtual urgent care vendor. Practices that send patients to a branded virtual visit platform owned by a technology company are the clearest BB case.

Clinicians contracted through telehealth companies. Physicians, nurse practitioners, and physician assistants who furnish visits through a telehealth company’s platform under contract are also likely BB claims.

Incident-to telehealth. Practices that bill telehealth services furnished by clinical staff incident to a supervising physician need BC on those claims.

Practices with their own platform. Groups that own their telehealth technology outright may not need BB, but should confirm against CMS guidance before assuming so.

Multi-location and multi-state groups. Chains often use different platforms or staffing arrangements by market. Each arrangement needs its own modifier decision, so a single rule for the whole organization may be wrong for some locations.

Why Congress Required These Modifiers

Telehealth has changed shape since the pandemic. Many Medicare telehealth visits now run through technology platforms that recruit, contract with, or charge the clinicians who use them, and some visits are billed incident to a physician who never sees the patient. From a claim alone, Medicare could not tell those arrangements apart from a practice seeing its own patients on its own system.

Section 6209(g) of the Consolidated Appropriations Act, 2026 closes that gap by requiring claims to flag both situations. CMS describes the modifiers as having no payment effect, which means their purpose is visibility. Once January claims start carrying BB and BC, Medicare will have data on how much telehealth runs through third-party platforms and how much is billed incident to physicians.

That data is likely to matter in the debate over what happens after December 31, 2027, when the current telehealth extensions are set to end. It also gives auditors and contractors a simple way to sort telehealth claims for review.

In our experience matching urgent care groups with billing partners, informational modifiers rarely stay purely informational. Claims missing a required modifier can be rejected by payer edits, and data that starts as a reporting requirement often becomes the basis for future payment or review policy. CMS has not said how it will treat claims that omit BB or BC, so practices should not wait to find out.

For other 2027 changes affecting urgent care E/M payment, see our post on the 2027 Medicare conversion factor cut for urgent care.

How Do BB and BC Change an Urgent Care Telehealth Claim?

Starting January 1, 2027, an urgent care telehealth claim still uses the usual E/M code, telehealth place of service, and existing modifiers, then adds BB when a third-party platform arrangement applies or BC when the service is billed incident to a physician. Payment amounts stay the same, but missing modifiers could trigger rejections.

Place of service still matters. Telehealth visits use POS 02 or POS 10 depending on the patient’s location, while in-person visits at the center use POS 20, as our POS 20 guide explains.

Here is a simple illustration. Suppose an urgent care group handles 300 Medicare virtual visits a month through a vendor platform at an average payment of $90, a hypothetical figure. That is $27,000 a month. If payer edits begin rejecting claims without BB, the group would carry that amount in delayed revenue until corrected claims go out. The visits would still be payable, but the cash would arrive weeks later, during the same months when respiratory volume is highest.

What Should Urgent Care Groups Do Before January 1, 2027?

These steps prepare an urgent care group for the BB and BC requirement before the first January claims go out:

1. Inventory every telehealth workflow. List each platform, vendor, and contracting arrangement used for Medicare virtual visits.
2. Classify each arrangement. Decide whether the platform is owned by the practice or by an entity the clinician contracts with or pays.
3. Identify incident-to telehealth. Flag any telehealth billed under a supervising physician so BC can be added.
4. Update charge capture and claim edits. Build rules that add BB or BC automatically based on the visit type and platform.
5. Train providers and coders. Make sure everyone knows the modifiers start January 1, 2027, and how to document the platform used.
6. Watch CMS guidance. Check the CMS telehealth page for instructions on applying the modifiers before January claims go out.
7. Review January remittances closely. Track rejections on telehealth claims during the first weeks of 2027 and fix patterns quickly.

Providers often come to us after a new modifier requirement has already caused rejected claims, usually because nobody owned the setup change. Billing companies in our network that work with urgent care groups build modifier logic into their claim edits ahead of effective dates, and they test it on a sample of claims before go-live so January surprises are caught early.

Common Mistakes With the New Telehealth Modifiers

The most common issue we see providers run into is assuming that a modifier with no payment effect does not matter. A required modifier that is missing can still stop a claim. These mistakes are the most likely in January.

Assuming owned software means no BB. A practice that pays a vendor to use a telehealth platform may still have a payment arrangement for use of that platform. Check CMS guidance.

Using BB and BC interchangeably. BB describes the platform arrangement and BC describes incident-to billing. A claim can involve one, both, or neither.

Changing place of service. The new modifiers do not replace POS 02 or POS 10. Keep using the correct telehealth place of service.

Adding telehealth modifiers to in-person visits. BB and BC apply only to telehealth claims. A patient seen in the center on POS 20 should never carry them.

Leaving the platform out of the note. If documentation does not show how the visit was delivered, it will be hard to support BB on review. A short template line naming the platform solves this.

Forgetting commercial and Medicare Advantage payers. The requirement comes from Medicare, but some payers follow Medicare coding. Check each payer’s telehealth policy before applying the modifiers broadly.

Ignoring the 2027 deadline for the extensions. The current Medicare telehealth flexibilities run through December 31, 2027. Practices building virtual programs should plan for that date as well.

Mixing up visit codes. Virtual visits still require accurate E/M and diagnosis coding. Our CPT 99213 billing guide and our page on ICD-10 code J06.9 cover two of the most common urgent care combinations.

In-House Billing vs. an Urgent Care Billing Partner

Urgent care billing teams already manage high volume, tight turnaround times, and seasonal surges. Adding telehealth modifiers that depend on contract arrangements, not just clinical documentation, means the billing team needs information that often sits with operations or the vendor contract, not in the chart. Somebody has to read the vendor agreements, decide which arrangements trigger BB, and turn that decision into a claim rule.

That is where in-house teams often struggle. A coder can see that a visit was virtual, but not necessarily who owns the platform or whether the clinician has a contract with the vendor. Without a clear rule built into the claim workflow, BB and BC will be applied inconsistently, especially during respiratory season when volume peaks, as we covered in our post on flu season billing for urgent care in 2026.

Urgentcare Bill Co, part of Billing Service Quotes, matches urgent care practices with billing companies in our network that handle urgent care and telehealth billing. We have matched more than 2,000 providers across all 50 states, the service is free to providers, and most practices are connected within 30 minutes. Our process includes a human review of each request, so a group running virtual visits is matched with billing companies that understand telehealth claim setup.

Billing companies in our network offer credentialing, contracting, compliance, and full revenue cycle support, and many are software agnostic. Rates start as low as 2.95%. For a broader overview of urgent care billing, see our urgent care billing guide.

Frequently Asked Questions

Next Steps

• Tracking 2027 payment changes? Read about the modifier 25 payment cut for urgent care.
• Checking recent Medicare updates? See the October 2026 Medicare Part B payment update.
• Billing after-hours care? Review our CPT 99051 guide.
• Ready for help? Explore Urgentcare Bill Co and get matched with a billing partner.