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CMS Proposes to Expand the Medicare Telehealth List and Add New Telehealth Modifiers in the CY2027 Fee Schedule

In the proposed CY2027 Medicare Physician Fee Schedule (CMS-1848-P, released July 14, 2026), CMS proposes adding five services to the Medicare Telehealth Services List, creating two informational telehealth modifiers (BB and BC) to flag third-party platform and incident-to arrangements, raising the originating site facility fee to $32.65, and implementing the Consolidated Appropriations Act, 2026 telehealth flexibilities through the end of 2027. Nothing is final. Public comments are due September 14, 2026.

The TeleRanked Editors·Updated August 7, 2026·7 min read

Quick answer

On July 14, 2026, CMS released its proposed CY2027 Medicare Physician Fee Schedule (CMS-1848-P), which includes several telehealth proposals. It would add five services to the Medicare Telehealth Services List, create two new informational modifiers (BB and BC) to identify telehealth furnished through certain third-party virtual platform arrangements or incident to a practitioner's service, raise the telehealth originating site facility fee to $32.65, and carry out the Consolidated Appropriations Act, 2026 telehealth flexibilities (geographic and originating site waivers, audio-only, and a delayed in-person requirement for mental health) through the end of 2027. The rule is a proposal, not final, and CMS is taking public comments through September 14, 2026.

Key takeaways

  • The CY2027 Physician Fee Schedule proposed rule (CMS-1848-P) was released July 14, 2026. It is a proposal, not final law, and the public comment period runs through September 14, 2026.
  • CMS proposes adding five services to the Medicare Telehealth Services List using new HCPCS G-codes: GACP1 and GACP2 (advance care planning), GSMAS (a group medical session for 2 to 10 patients), GSLPP (pediatric speech, language, voice, and communication treatment), and GADV1 (an evaluation and management service for vaccine adverse effects).
  • Two new informational modifiers, BB and BC, would identify telehealth services furnished through certain third-party virtual platform arrangements, or incident to a practitioner's professional service. CMS describes them as informational, meaning they flag the arrangement without changing the payment amount.
  • CMS proposes to implement the telehealth flexibilities extended by the Consolidated Appropriations Act, 2026, including continued waivers of geographic and originating site restrictions and audio-only coverage through the end of 2027, and a delay of the in-person visit requirement for mental health telehealth so that it does not apply through December 31, 2027.
  • The proposed rule would raise the telehealth originating site facility fee (HCPCS Q3014) to $32.65 for CY2027, reflecting a Medicare Economic Index update.

Every summer, CMS proposes the rules that will govern how Medicare pays clinicians the following year, and the telehealth provisions inside that proposal set the tone for the whole sector. On July 14, 2026, CMS released the proposed CY2027 Physician Fee Schedule. Alongside a separate and more restrictive proposal on outsourced remote monitoring, the rule carries a set of telehealth-specific changes: new services on the Medicare telehealth list, new claim modifiers for platform-based care, a higher originating site fee, and the mechanics of the telehealth flexibilities Congress extended through 2027. This piece walks through those telehealth elements, based on the CMS fact sheet and published analyses of the proposal. None of it is final.

What CMS proposed, and what is still open

The document is a proposed rule, identified as CMS-1848-P, for the CY2027 Medicare Physician Fee Schedule. CMS released it on July 14, 2026 and is accepting public comments through September 14, 2026. A proposed rule is a draft: CMS can change, drop, or finalize any part of it after reviewing comments, so nothing described here is settled Medicare policy. The rule is broad, covering payment rates and many Part B policies, but the focus of this piece is the telehealth provisions. CMS's proposal to end Medicare payment for outsourced remote physiologic and remote therapeutic monitoring is a separate part of the same rule, covered in our earlier report on the remote monitoring proposal.

New services on the Medicare telehealth list

CMS maintains a list of services that Medicare will pay for when they are delivered by telehealth. For CY2027, the agency proposes adding five services to that list, using new HCPCS G-codes:

  • GACP1 and GACP2: advance care planning, described as clinical staff time directed by a practitioner.
  • GSMAS: a group medical session for 2 to 10 patients.
  • GSLPP: pediatric speech, language, voice, and communication treatment.
  • GADV1: an evaluation and management service for vaccine adverse effects.

If finalized, these additions would let Medicare pay for those specific services when they are furnished by telehealth, continuing a multi-year pattern of the list growing around chronic care management, care coordination, and patient engagement.

Two new modifiers for platform-based telehealth

The proposal would create two new modifiers, BB and BC, that a billing practitioner would append to a telehealth claim. According to published analyses of the rule, the modifiers identify telehealth services furnished where the practitioner contracts with, or has a payment arrangement with, the entity that owns the virtual care platform, or where the service is furnished incident to a physician's or practitioner's professional service. CMS describes the modifiers as informational: they signal the nature of the arrangement on the claim but, as proposed, do not change the payment amount. The stated purpose is visibility into how much Medicare telehealth flows through third-party virtual platforms.

Which flexibilities continue, and for how long

Many of the telehealth rules patients rely on are statutory flexibilities that Congress extends in blocks, not permanent Medicare policy. The proposed rule implements the flexibilities extended by the Consolidated Appropriations Act, 2026:

  • Waivers of the geographic and originating site restrictions, and the expanded list of eligible practitioners and originating sites, continue through the end of 2027.
  • Coverage of audio-only telehealth continues through the end of 2027.
  • The in-person visit requirement for mental health telehealth is delayed, so that it does not apply through December 31, 2027.
  • CMS also notes that the Act extended its authority to pay rural health clinics and federally qualified health centers for non-behavioral health visits furnished by telecommunication technology through December 31, 2027.

Because these are time-limited extensions, the underlying flexibilities are currently set to change at the end of 2027 unless Congress acts again. The proposed rule carries them out for CY2027; it does not make them permanent.

Supervision, teaching physicians, and the originating site fee

The proposal also includes narrower telehealth-adjacent items. CMS proposes what analysts describe as a modest loosening of the teaching physician virtual presence requirements, which govern when a teaching physician can be present through real-time audio and video rather than in the room. Separately, the rule would raise the telehealth originating site facility fee (HCPCS Q3014) to $32.65 for CY2027, reflecting a Medicare Economic Index update from the CY2026 amount. These are incremental changes rather than structural ones, but they affect how remote and resident-involved care is documented and paid.

Why it matters

For telehealth platforms and the clinicians who work through them, the most consequential telehealth item here may be the new BB and BC modifiers, because they give CMS a clearer view of how much Medicare telehealth is delivered through third-party platform arrangements, the same arrangements CMS is scrutinizing elsewhere in the rule. For patients, the flexibility extensions are what keep familiar telehealth access, such as audio-only visits and mental health care without a prior in-person visit, in place through 2027. The list additions expand what Medicare will pay for by telehealth at the margins. None of this is guaranteed: it is a proposal, and the comment period is the point at which clinicians, platforms, and patient groups can weigh in before CMS finalizes the rule later in the year.

What to do next

This is general information about a proposed federal rule, not billing, legal, or medical advice. Clinicians and organizations that bill Medicare for telehealth should read the proposed rule and the CMS fact sheet directly, track whether each provision is adopted, changed, or dropped in the final rule, and consult a qualified billing or compliance adviser about their own claims. Anyone who wants to influence the outcome can submit a comment to CMS through September 14, 2026.

Frequently asked questions

Is the CY2027 telehealth rule final?+

No. CMS-1848-P is a proposed rule, released July 14, 2026, with a public comment period through September 14, 2026. CMS can change, drop, or finalize any provision after reviewing comments, so nothing in it is settled Medicare policy yet.

What new services would Medicare cover by telehealth in 2027?+

CMS proposes adding five services to the Medicare Telehealth Services List using new HCPCS G-codes: GACP1 and GACP2 (advance care planning), GSMAS (a group medical session for 2 to 10 patients), GSLPP (pediatric speech, language, voice, and communication treatment), and GADV1 (an evaluation and management service for vaccine adverse effects).

What are the new BB and BC telehealth modifiers?+

They are two new informational modifiers that would identify telehealth services furnished through certain third-party virtual platform arrangements, or incident to a practitioner's professional service. As proposed, they flag the arrangement on the claim but do not change the payment amount.

Will audio-only and mental health telehealth still be covered in 2027?+

Under the proposal, which implements the Consolidated Appropriations Act, 2026 flexibilities, audio-only telehealth coverage continues through the end of 2027, and the in-person visit requirement for mental health telehealth is delayed so it does not apply through December 31, 2027. These are time-limited extensions, not permanent policy.

How is this different from the CMS remote monitoring proposal?+

They are two parts of the same CY2027 proposed rule. The remote monitoring proposal would end Medicare payment for outsourced remote physiologic and remote therapeutic monitoring. The telehealth elements described here concern the telehealth services list, the BB and BC modifiers, the flexibility extensions, and the originating site fee. Both are proposals, not final.

When can the public comment on the rule?+

CMS is accepting comments on the CY2027 Physician Fee Schedule proposed rule through September 14, 2026. This is general information, not legal advice; the CMS fact sheet and the proposed rule explain how to submit a comment.

Sources

  1. 1.Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P) fact sheet · Centers for Medicare & Medicaid Services
  2. 2.CMS Issues CY 2027 Medicare Physician Fee Schedule Proposed Rule · Holland & Knight LLP
  3. 3.What Does the CY 2027 Medicare Physician Fee Schedule Proposed Rule Mean for Digital Health Companies? · Nixon Gwilt Law
  4. 4.2027 Proposed Physician Fee Schedule: The Telehealth Elements · Center for Connected Health Policy

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