Modifier FQ
A practical medical billing guide to Modifier FQ, including its meaning, Medicare application, RHC/FQHC billing, audio-only versus audio-video services, Modifier 93, documentation, claim review and denial management.
Modifier FQ at a Glance
The essential facts before using FQ on a claim.
Audio-Only
FQ identifies services furnished using audio-only communication technology in applicable Medicare billing situations.
RHC
CMS materials specifically include FQ among the modifiers used for applicable RHC telecommunications services.
FQHC
FQ is also identified in CMS guidance for applicable FQHC telecommunications services.
Do Not Confuse
Modifier 93 also identifies synchronous audio-only telecommunications in applicable CPT reporting.
What Is Modifier FQ?
Understand the modifier before adding it to a claim.
Simple Definition
Modifier FQ identifies a service provided using audio-only communication technology when the applicable billing rules require or permit the modifier.
In other words, the patient and practitioner communicate through audio-only technology rather than using a real-time audio-video connection.
FQ should not be treated as a universal modifier for every telephone call or every audio-only Medicare service.
Audio-Only Does Not Automatically Mean FQ
The correct modifier depends on the payer, provider type, service, code set and applicable telehealth policy.
For example, CMS has used FQ in specific RHC/FQHC telecommunications billing guidance, while Modifier 93 is used to identify synchronous audio-only telecommunications in applicable CPT reporting.
Therefore, always verify the specific billing context before selecting FQ.
Modifier FQ and Medicare
Why provider type and service context matter.
RHC Services
CMS guidance identifies FQ among the modifiers that can identify audio-only telecommunications for applicable RHC services.
FQHC Services
CMS also identifies FQ in applicable FQHC telecommunications billing examples.
Professional PFS Claims
Do not automatically transfer the FQ rule to every physician office claim. The applicable service and payer rules must be reviewed.
CPT Modifier 93
Modifier 93 represents synchronous telemedicine services rendered through real-time interactive audio-only telecommunications in applicable CPT reporting.
Service-Specific Rules
A telephone-based service may have its own CPT or HCPCS code and reporting rules.
Current Policy
Telehealth policies change through legislation and annual CMS rulemaking, so older modifier charts should not be followed without verification.
2026 Billing Reminder
CMS’s 2026 materials continue to distinguish audio-only services from audio-video telehealth. Certain audio-only services are permitted under current law and specific program rules, but the correct billing code and modifier depend on the setting and service.
Audio-Only vs Audio-Video Telehealth
The technology used during the encounter changes the billing analysis.
Audio-Only
- No video component.
- Communication occurs through audio-only technology.
- FQ may apply in specific Medicare/RHC/FQHC billing circumstances.
- Modifier 93 may apply in other applicable CPT reporting situations.
- Verify the payer and service-specific requirements.
Audio-Video
- Real-time audio and video communication.
- Patient and practitioner can interact visually and audibly.
- Different modifier and POS rules may apply.
- Modifier 95 may be applicable under certain payer policies.
- Verify current CMS or payer requirements.
Modifier FQ vs Modifier 93
One of the most important distinctions for billers.
| Feature | Modifier FQ | Modifier 93 |
|---|---|---|
| Basic Concept | Audio-only communication technology in applicable Medicare billing contexts | Synchronous telemedicine service using real-time interactive audio-only telecommunications |
| Common Medicare Context | Particularly identified in RHC/FQHC telecommunications guidance | Used for applicable CPT reporting |
| Video | No video | No video |
| Real-Time Audio | Depends on the specific service/reporting context | Yes |
| RHC/FQHC | Specifically identified in CMS telecommunications guidance | May also be reported where applicable |
| Main Billing Risk | Using FQ automatically for every audio-only service | Using 93 without confirming the applicable code/payer requirements |
Easy Memory Trick
FQ = audio-only modifier used in specific Medicare
telecommunications contexts, especially RHC/FQHC guidance.
93 = synchronous real-time audio-only telemedicine in
applicable CPT reporting.
Modifier FQ vs Modifier 95
Audio-only and audio-video should never be treated as the same technology.
FQ — Audio-Only
- No video.
- Used in specific applicable Medicare billing contexts.
- CMS identifies FQ in RHC/FQHC telecommunications guidance.
- Verify service-specific reporting rules.
95 — Audio-Video
- Real-time audio and video.
- Patient and practitioner interact through audiovisual technology.
- Payer-specific rules determine whether 95 is required or accepted.
- Do not use 95 when the service was audio-only.
Audio-Only Telehealth Workflow
A simple workflow from scheduling through claim submission.
Modifier FQ for RHCs and FQHCs
This is one of the most important applications to understand.
Rural Health Clinics
CMS educational guidance provides examples of RHC telecommunications claims using audio-only reporting.
In the CMS example, applicable mental health services furnished through telecommunications may use 95 for audio-video or FQ/93 for audio-only, along with the applicable RHC billing requirements.
Always verify the current CMS instructions for the exact service and date of service.
Federally Qualified Health Centers
CMS guidance also provides FQHC examples involving telecommunications and audio-only services.
Depending on the service and payment methodology, the claim may involve the applicable FQHC payment code and telecommunications reporting requirements.
Do not copy a modifier from a professional PFS claim onto an FQHC claim without checking the FQHC-specific rules.
RHC/FQHC Billing Tip
Provider type matters. A physician office, RHC and FQHC may have different billing methodologies even when the underlying service is delivered through the same audio-only technology.
Audio-Only Telehealth in 2026
Current CMS policy requires careful distinction between service types.
Audio-Only Is Permitted in Some Situations
CMS’s current telehealth guidance recognizes audio-only telehealth for certain services and circumstances.
Behavioral Health
Current law permits certain audio-only behavioral health services furnished to patients in their homes, subject to applicable requirements.
RHC/FQHC
CMS continues to address telecommunications services for RHCs and FQHCs separately from ordinary PFS professional billing.
Modifier Selection
The technology alone does not determine the modifier. The payer, provider type and service must also be checked.
Legislation Matters
Temporary telehealth extensions can change the rules for specific services and settings.
Verify the DOS
Always apply the rule that was effective for the actual date of service.
Should I Use Modifier FQ?
Use this decision process before submitting a claim.
Audio-Only?
Was the encounter furnished without video?
Which Payer?
Medicare, Medicaid, MA or commercial?
Provider Type?
RHC, FQHC, physician or other provider?
Which Code?
Identify the CPT/HCPCS service first.
Which Modifier?
Verify whether FQ, 93, 95 or another rule applies.
Best Practice
Never select the modifier first. Identify the payer, provider type, service code and communication method first. Then select the modifier supported by the current policy.
Modifier FQ Practical Examples
Simplified examples for billing and AR training.
An RHC furnishes an applicable mental health service through audio-only telecommunications.
CMS educational guidance identifies FQ and 93 as audio-only modifier options in the applicable RHC example, subject to the service and current rules.
An FQHC provides a qualifying telecommunications service using audio-only communication.
CMS guidance provides FQHC-specific examples involving FQ and audio-only telecommunications.
A practitioner furnishes a service through a real-time, synchronous telephone interaction.
Modifier 93 may be the appropriate CPT reporting modifier when applicable. Do not automatically use FQ.
The patient and practitioner communicate through real-time audio and video.
FQ should not be selected simply because the service is telehealth.
A staff member calls the patient only to confirm an appointment.
Administrative telephone activity is not automatically a billable telehealth service.
A billing team adds FQ to every audio-only Medicare claim without reviewing provider type or service code.
Modifier selection must be based on the actual billing context.
Common Modifier FQ Billing Mistakes
Errors that can lead to denials and unnecessary AR work.
Using FQ on Every Audio-Only Claim
Audio-only technology alone does not determine the correct modifier.
Ignoring Provider Type
RHC/FQHC and PFS billing methodologies are not identical.
Confusing FQ and 93
Modifier 93 has a specific CPT definition for synchronous audio-only telemedicine.
Confusing FQ and 95
Modifier 95 is associated with real-time audio-video telemedicine under applicable payer rules.
Ignoring the CPT/HCPCS Code
The underlying service must independently meet the applicable billing requirements.
Copying Old COVID-Era Rules
Historical temporary telehealth policies should not be assumed to remain active.
Wrong POS
Telehealth POS reporting must be verified separately from modifier selection.
No Documentation
The record should support the service, medical necessity and communication method.
Ignoring Payer Rules
Medicaid, Medicare Advantage and commercial payers can have different requirements.
Modifier FQ Claim Review Workflow
Use this workflow before rebilling or appealing a denial.
AR Caller Script for an FQ Denial
Practical questions for the payer or Medicare contractor.
Common FQ Denial Root Causes
Find the actual reason before changing the modifier.
Modifier Not Applicable
FQ was reported even though the claim did not meet the applicable reporting requirements.
Wrong Provider Type
The billing rules for the provider do not support the submitted configuration.
Wrong CPT/HCPCS
The underlying service is not eligible under the applicable telehealth rule.
Audio-Video Service
The encounter was actually performed using audio-video technology.
Wrong Audio-Only Modifier
The payer or CPT reporting rules require a different modifier such as 93.
POS Issue
The Place of Service does not match the payer’s telehealth billing requirements.
Documentation Issue
The medical record does not adequately support the service or communication method.
Policy Change
The billing team used a rule that was no longer effective for the date of service.
Payer-Specific Rule
The payer has a telehealth requirement different from Medicare FFS.
Modifier FQ Documentation Checklist
Documentation should support both the service and the reporting method.
Clinical Documentation
- Patient identification.
- Date of service.
- Reason for encounter.
- Relevant history and clinical information.
- Assessment.
- Plan of care.
- Medical necessity.
- Provider identity.
Audio-Only Documentation
- Audio-only communication documented when applicable.
- No video connection used.
- Applicable patient location documented.
- Provider location documented when required.
- Communication technology documented.
- Consent documented when required.
- Applicable RHC/FQHC requirements satisfied.
- Modifier selection supported by current policy.
CMS RHC/FQHC Modifier Example
Understand how CMS illustrates audio-only reporting.
| Setting | Service | Audio-Video | Audio-Only |
|---|---|---|---|
| RHC | Applicable mental health visit | Modifier 95 | FQ or 93, as applicable |
| FQHC | Applicable mental health visit | Modifier 95 | FQ or 93, as applicable |
Important
This table summarizes CMS educational examples; it is not a substitute for verifying the current code, provider type, date of service and payer instructions for a specific claim.
Modifier FQ Quick Cheat Sheet
Save this section for quick RCM reference.
- FQ identifies audio-only communication technology in applicable Medicare billing contexts.
- FQ is specifically identified in CMS guidance for applicable RHC/FQHC telecommunications services.
- FQ is not a universal modifier for every Medicare audio-only service.
- Modifier 93 identifies synchronous real-time audio-only telemedicine in applicable CPT reporting.
- Modifier 95 is associated with synchronous audio-video telemedicine under applicable payer rules.
- Provider type matters.
- CPT/HCPCS eligibility must be verified separately.
- POS requirements must be reviewed separately.
- Current policy should be checked for the actual date of service.
- Medicaid, Medicare Advantage and commercial payer rules may differ.
- Never select FQ solely because the encounter was conducted by telephone.
- Keep documentation supporting the service and modifier selection.
Modifier FQ Claim Audit Table
Use this before submitting or correcting an audio-only claim.
| Audit Item | Question | Verify | Risk |
|---|---|---|---|
| Payer | Who is paying? | Medicare / MA / Medicaid / Commercial | High |
| Provider Type | What type of provider submitted the claim? | RHC / FQHC / PFS practitioner / Other | High |
| Technology | Audio-only or audio-video? | Actual encounter documentation | High |
| CPT/HCPCS | Is the service payable? | Current CMS/payer policy | High |
| Modifier | Is FQ actually required? | Current payer/program instructions | High |
| POS | Is the POS correct? | Current telehealth billing rules | High |
| Documentation | Does the record support the claim? | Medical record and telehealth documentation | High |
How to Prevent FQ Denials
Build modifier verification into your RCM process.
Front-End Prevention
- Verify payer before scheduling.
- Confirm whether audio-only is covered.
- Identify provider type.
- Identify the CPT/HCPCS code.
- Verify the current telehealth policy.
- Confirm the correct modifier.
- Verify POS.
- Capture required documentation.
Back-End Prevention
- Trend FQ-related denials.
- Track CARC/RARC combinations.
- Audit FQ claims by provider type.
- Separate FQ and 93 denial trends.
- Review POS-related denials.
- Monitor CMS telehealth changes.
- Update internal modifier matrices.
- Train billing staff after policy changes.
Official CMS References
Use primary CMS sources when verifying Modifier FQ.
Educational Disclaimer
This page is for US medical billing, coding and Revenue Cycle Management education. Telehealth requirements can vary by payer, provider type, service, claim type and date of service. Always verify the current CMS, MAC, Medicaid, Medicare Advantage or commercial payer instructions before submitting or appealing a claim.
Modifier FQ FAQs
Common questions for medical billers, coders and AR callers.
What does Modifier FQ mean?
Modifier FQ identifies an applicable service furnished using audio-only communication technology.
Is Modifier FQ only for audio-only services?
Yes, FQ is associated with audio-only communication technology. However, whether FQ is the correct modifier depends on the payer, provider type and service.
Is FQ used by RHCs?
CMS guidance identifies FQ as an audio-only modifier in applicable RHC telecommunications billing.
Is FQ used by FQHCs?
Yes. CMS educational materials include FQ in applicable FQHC telecommunications billing examples.
Is FQ the same as Modifier 93?
No. Modifier 93 represents synchronous telemedicine services rendered through real-time interactive audio-only telecommunications in applicable CPT reporting. FQ has specific Medicare applications, including RHC/FQHC telecommunications guidance.
Is FQ the same as Modifier 95?
No. Modifier 95 is associated with synchronous audio-video telemedicine under applicable payer requirements.
Can I use FQ for every telephone visit?
No. A telephone visit must first be evaluated for the applicable CPT/HCPCS code, payer policy, provider type and modifier requirements.
Can I use FQ on a physician office claim?
Do not automatically do so. Verify the specific service, payer and current Medicare or commercial policy. FQ is especially identified in CMS RHC/FQHC telecommunications guidance.
Does FQ mean the service was asynchronous?
No. FQ should not be confused with GQ. GQ identifies asynchronous telecommunications in a specific Medicare telehealth context. FQ is associated with audio-only communication.
Can FQ be used with mental health services?
FQ can be reported in applicable Medicare RHC/FQHC telecommunications contexts, including CMS examples involving mental health visits. The exact service and current requirements must be verified.
Does FQ guarantee Medicare payment?
No. The underlying service, provider eligibility, coverage requirements, documentation, POS and all other applicable billing rules must be satisfied.
Can Medicaid require Modifier FQ?
Medicaid programs and Medicaid managed care organizations may establish their own telehealth requirements. Verify the applicable state Medicaid or MCO policy.
Can commercial insurance require FQ?
A commercial payer may establish its own modifier and telehealth requirements. Do not assume Medicare’s FQ rules apply.
What should an AR caller check for an FQ denial?
Review the ERA/EOB, CARC/RARC, payer, provider type, CPT/HCPCS, communication method, modifier, POS, documentation and date of service.
Can an old paid FQ claim prove FQ is correct today?
No. Historical claim processing does not establish the current rule. Always verify the policy applicable to the date of service.
Is audio-only telehealth still allowed in 2026?
Yes, audio-only telehealth remains permitted in certain Medicare circumstances, subject to applicable law, service and provider requirements. CMS’s 2026 guidance specifically addresses audio-only services.
What is the biggest mistake with Modifier FQ?
The biggest mistake is treating FQ as a universal audio-only modifier without first checking the payer, provider type and CPT/HCPCS service.
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