The answer first: CMS has proposed adding five codes to the Medicare Telehealth List and creating two brand-new claim modifiers, BB and BC. If the proposal is finalized, BB and BC become required on Medicare telehealth claims where the billing practitioner contracts with certain entities, beginning January 1, 2027. The proposal appears in the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), announced in a CMS fact sheet on July 14, 2026 and published in the Federal Register on July 16, 2026. Comments close September 14, 2026.
Today vs. January 1, 2027: the comparison matrix
For coding and edits teams, this rule is not a policy abstraction, it is a systems change with a hard date. Here is the operational delta between the current state and the CY 2027 proposal, dimension by dimension.
BB vs. BC: what we know and what to watch
The proposed rule creates both modifiers for the same problem space: identifying telehealth claims where the billing practitioner contracts with certain entities. What coding teams should not do is guess at the final definitions before the final rule lands.
Modifier BB
- One of two new modifiers proposed in CMS-1848-P for telehealth claims tied to contracted entity arrangements.
- Required, as proposed, beginning January 1, 2027 where the arrangement criteria are met.
- Watch the final rule for the exact arrangement definition CMS assigns to BB before hard-coding append logic.
Modifier BC
- The companion modifier in the same proposal, covering the other side of the contracted-arrangement distinction.
- Same January 1, 2027 effective date as proposed, same claim population at risk if it is missing.
- Build your scrubber rule as a configurable pair, BB/BC, so the final-rule definitions drop into place without rework.
The regulatory clock
Why this breaks claims if you wait
New modifiers are a front-end problem long before they are a coding problem. Charge capture templates decide which modifiers a claim line even offers, and claim scrubbers decide which combinations pass. A modifier that did not exist when your rules were written is invisible to both. If BB/BC logic is not built, tested, and promoted before the effective date, every telehealth line in the affected population goes out the door non-compliant, and denials arrive weeks later as a batch, not a trickle.
The teaching physician change cuts the other way: it is a loosening, and loosenings get missed too. Once either the teaching physician or the resident with the patient satisfies the requirement, encounters that academic groups previously wrote off or restructured become billable. Teams that do not update their internal edit logic will keep suppressing revenue the rule now allows.
The operator to-do list
- Inventory your Medicare telehealth volume and flag every billing practitioner who contracts with an outside entity, so you know which claims BB/BC will touch.
- Pull the five proposed telehealth code additions from CMS-1848-P and map them against your current telehealth service list and fee schedules.
- Draft the BB/BC append rule in your claim scrubber now, as a disabled configurable pair, ready to activate the moment the final rule confirms definitions.
- Update charge capture templates and EHR order sets so the new modifiers are selectable, with edits preventing use before January 1, 2027.
- Rework teaching physician telehealth edits to recognize that either the teaching physician or the resident with the patient satisfies the requirement, as proposed.
- Submit comments to CMS before September 14, 2026 if the arrangement definitions create ambiguity for your organization.
- Schedule end-to-end test claims in December 2026 so day-one 2027 telehealth billing is verified, not assumed.
Sources
Get BB/BC-ready before January 1, 2027
ASP-RCM Solutions builds and maintains payer and CMS modifier logic inside charge capture and claim-scrubber workflows for medical groups, telehealth platforms, and academic practices, sustaining 95%+ coding accuracy across our engagements. We track proposed rules like CMS-1848-P from fact sheet to final rule, translate them into tested edit logic, and prove the claims flow before the effective date, so your telehealth revenue never waits on a denial batch to find out something changed.
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