Modifier FQ is a HCPCS Level II telehealth modifier that identifies a healthcare service furnished using real-time audio-only communication technology.

Unlike Modifier 95, which represents live audio-video telehealth, Modifier FQ indicates that the provider and patient communicated only by telephone or another real-time audio-only communication system.

CMS introduced Modifier FQ in 2022 to identify specific Medicare audio-only telehealth services. Today, its use is limited primarily to certain Medicare settings such as Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and specific Opioid Treatment Program (OTP) services, while many other eligible practitioners report Modifier 93 for audio-only telehealth services.

Modifier

Modifier Name

Service Furnished Using Audio-Only Communication Technology

Plain English Explanation

Modifier FQ tells the payer:

“This telehealth service was provided using live, two-way audio-only communication instead of audio and video technology.”

The patient and provider communicate in real time using voice communication only.

Purpose of Modifier FQ

Modifier FQ is used to:

Identify Medicare audio-only telehealth services.
Distinguish audio-only encounters from audio-video telehealth.
Support Medicare payment for eligible audio-only services.
Identify services furnished when video technology cannot or will not be used.
Comply with CMS telehealth reporting requirements.

Understanding Modifier FQ

Modifier FQ represents:

Real-time communication
Audio only
Two-way interaction
No live video

Examples include:

Behavioral health counseling
Mental health follow-up
Substance use counseling
Opioid Treatment Program counseling
Eligible Rural Health Clinic or Federally Qualified Health Center mental health visits

Unlike Modifier GQ, which represents asynchronous communication, Modifier FQ represents live synchronous communication without video.

When to Use Modifier FQ

Append Modifier FQ when:

Medicare specifically instructs use of Modifier FQ.
The service qualifies as an audio-only telehealth service.
The patient cannot access, cannot use, or declines audio-video technology.
The provider has the capability to furnish the service using audio-video technology but instead provides it using audio only because video is unavailable or unsuitable.
Billing eligible RHC, FQHC, or OTP services under CMS rules.

Common services include:

HCPCS/CPT Code	Description
G2080	Additional OTP counseling and therapy services (when applicable)
Mental health visit codes	Eligible RHC/FQHC audio-only mental health services
Payer-approved behavioral health CPT codes	Audio-only telehealth when permitted

When NOT to Use Modifier FQ

Do not use Modifier FQ when:

The visit uses live audio and video (use Modifier 95 if applicable).
The service is performed in person.
The payer requires Modifier 93 instead.
The service is not eligible for audio-only telehealth.
Audio-only communication does not meet payer requirements.

Medicare Rules

Current Medicare policy provides:

Modifier FQ identifies services furnished using real-time audio-only communication technology.
It is primarily used for eligible RHC, FQHC, and certain OTP services.
The provider must be capable of furnishing the service using audio-video technology, but audio-only is used because the beneficiary cannot access, cannot use, or declines video communication.
Many other Medicare practitioners now use Modifier 93 for eligible audio-only telehealth services under current CMS policy.

Commercial Insurance Rules

Commercial payer requirements vary.

Some commercial insurers:

Accept Modifier FQ.
Require Modifier 93 instead.
Require no modifier.
Require payer-specific telehealth modifiers.
Require prior authorization.

Always verify payer-specific telehealth billing guidelines.

Documentation Requirements

Documentation should include:

Patient consent when required.
Reason audio-only communication was used.
Confirmation that the provider had audio-video capability.
Patient was unable, unwilling, or lacked access to video technology.
Medical necessity.
Date and duration of the encounter.
Assessment and treatment plan.
Provider signature and credentials.

Real Billing Examples

Example 1 – Rural Health Clinic

An RHC furnishes an audio-only mental health follow-up visit because the patient does not have video capability.

Billing

Appropriate mental health visit code
Modifier FQ

Example 2 – Federally Qualified Health Center

An FQHC psychologist provides an audio-only psychotherapy session.

Billing

Appropriate visit code
Modifier FQ

Example 3 – Opioid Treatment Program

An OTP furnishes counseling using real-time audio-only communication because the patient cannot participate in a video visit.

Billing

HCPCS G2080
Modifier FQ

Example 4 – Commercial Insurance

A commercial payer specifically instructs providers to report Modifier FQ for eligible audio-only behavioral health visits.

Billing

Appropriate CPT code
Modifier FQ

Example 5 – Incorrect Use

A physician performs a live video telehealth visit and reports:

CPT 99214
Modifier FQ

This is incorrect because the encounter included audio and video. Modifier 95 (or another payer-required telehealth modifier) would generally be appropriate instead.

CMS-1500 Claim Example

Field	Example
HCPCS/CPT	G2080
Modifier	FQ
POS	Appropriate payer-required POS
Diagnosis Pointer	F11.20 (Example)
Units	1

Common Denial Reasons

Modifier FQ billed by an ineligible provider type.
Audio-video technology was available and used.
Missing documentation supporting audio-only communication.
Incorrect telehealth modifier.
Service not eligible for audio-only billing.
Payer requires Modifier 93 instead.
Missing medical necessity documentation.

How to Correct the Denial

Verify payer-specific audio-only billing rules.
Confirm that Modifier FQ is appropriate for the provider type.
Review documentation supporting the use of audio-only technology.
Correct the modifier if another telehealth modifier is required.
Submit a corrected claim.
Appeal with supporting documentation when appropriate.

Coding Tips

Do not confuse Modifier FQ with Modifier 93.
Verify whether the payer requires FQ or 93.
Document why video communication was not used.
Confirm the provider had the capability to furnish audio-video services.
Maintain complete telehealth documentation.

Modifier FQ vs Modifier 93

Modifier	Description
FQ	Service furnished using audio-only communication technology; primarily used in specific Medicare settings such as RHCs, FQHCs, and certain OTP services
93	Synchronous telemedicine service rendered via real-time interactive audio-only telecommunications system; used more broadly by eligible practitioners

Modifier FQ vs Modifier 95

Modifier	Description
FQ	Audio-only communication
95	Audio and video communication

Modifier FQ vs Modifier GT

Modifier	Description
FQ	Audio-only communication
GT	Audio and video communication

Modifier FQ vs Modifier GQ

Modifier	Description
FQ	Live audio-only communication
GQ	Asynchronous (store-and-forward) communication

Frequently Asked Questions (FAQs)

Q1. What does Modifier FQ mean?

Answer: It identifies a service furnished using real-time audio-only communication technology.

Q2. Is Modifier FQ used for all Medicare audio-only telehealth services?

Answer: No. Modifier FQ is primarily used in specific Medicare settings such as RHCs, FQHCs, and certain OTP services. Many other Medicare practitioners now report Modifier 93 for eligible audio-only telehealth services.

Q3. What is the difference between Modifier FQ and Modifier 95?

Answer: Modifier FQ identifies audio-only communication, while Modifier 95 identifies real-time audio-video telehealth.

Q4. Can Modifier FQ be used if video technology is available?

Answer: Generally, it is used when audio-video technology is not available to the beneficiary, cannot be used, or the beneficiary declines its use, provided CMS or payer requirements are met.

Q5. Does every commercial payer recognize Modifier FQ?

Answer: No. Commercial payer requirements vary. Some require FQ, some require Modifier 93, and others have different telehealth billing policies.

AR Caller Tips

When following up on claims billed with Modifier FQ:

Verify that the payer accepts Modifier FQ.
Confirm whether Modifier 93 should have been used instead.
Review documentation explaining why audio-only communication was used.
Verify provider eligibility.
Record payer representative names, reference numbers, and appeal instructions.

Interview Questions

Question 1

What does Modifier FQ represent?

Answer: A service furnished using real-time audio-only communication technology.

Question 2

Is Modifier FQ the same as Modifier 95?

Answer: No. FQ identifies audio-only communication, while 95 identifies audio-video telehealth.

Question 3

Who primarily uses Modifier FQ under Medicare?

Answer: It is primarily associated with eligible RHCs, FQHCs, and certain OTP services.

Question 4

When should Modifier FQ not be used?

Answer: It should not be used for live audio-video telehealth visits or when the payer requires a different modifier, such as Modifier 93.

Practice Scenario

Scenario

A Federally Qualified Health Center provides an audio-only behavioral health follow-up visit because the patient does not have access to video technology. The provider is capable of conducting a video visit but documents why audio-only communication was necessary.

Question

Which modifier should be appended?

Answer

Report the appropriate mental health service with Modifier FQ, following current Medicare billing guidance for eligible FQHC audio-only services.

Related Telehealth Modifiers

95 – Synchronous Telemedicine Service Rendered via Real-Time Interactive Audio and Video Telecommunications System
93 – Synchronous Telemedicine Service Rendered via Audio-Only Telecommunications System
GT – Via Interactive Audio and Video Telecommunications System
GQ – Via Asynchronous Telecommunications System
FR – Supervising Practitioner Present Through Real-Time Audio and Video Communication Technology

Common Billing Mistakes

Using FQ for audio-video telehealth.
Billing FQ when the payer requires Modifier 93.
Missing documentation supporting audio-only communication.
Reporting FQ for services not eligible for audio-only billing.
Failing to document why video was not used.
Assuming all Medicare providers use FQ.

Key Takeaways

Modifier FQ identifies services furnished using real-time audio-only communication technology.
It is primarily used in specific Medicare settings, including RHCs, FQHCs, and certain OTP services.
Audio-only communication must meet CMS or payer requirements.
Documentation should explain why audio-video technology was not used.
Always verify whether the payer requires Modifier FQ or Modifier 93 before billing.

References

CMS Change Request 12545 – Audio-Only Services and Modifier FQ.
CMS MLN: Mental Health Visits via Telecommunications for RHCs & FQHCs.
Noridian Medicare – Modifier FQ Guidance.
HCPCS Level II Code Book.
CPT® Professional Edition (American Medical Association).

Conclusion

Modifier FQ is an important Medicare telehealth modifier used to identify real-time audio-only communication technology in specific healthcare settings. It differs from Modifier 95 because it applies to audio-only services rather than audio-video encounters. Proper use requires understanding Medicare provider eligibility, documenting why video technology was not used, and following payer-specific telehealth billing rules. Correct reporting of Modifier FQ helps providers maintain compliance, reduce denials, and ensure appropriate reimbursement for eligible audio-only telehealth services.

Educational Disclaimer

This article was prepared with the assistance of artificial intelligence (AI) for educational and informational purposes. It is based on publicly available CMS guidance, Medicare telehealth policies, HCPCS Level II guidance, and general medical coding principles. It is not an official publication of CMS or the American Medical Association (AMA). Always consult the latest CMS Medicare Claims Processing Manual, Medicare Benefit Policy Manual, Medicare Physician Fee Schedule, HCPCS Level II Code Book, CPT® Professional Edition, applicable Local Coverage Determinations (LCDs), National Coverage Determinations (NCDs), and payer-specific telehealth billing policies before coding, billing, or submitting claims.