Telehealth Billing for Nutrition Therapy: Correct Modifier Usage Explained

Telehealth has quickly shifted from being optional to becoming an essential way of delivering care, especially for nutrition therapy. In the last quarter of 2023, more than 12.6% of Medicare beneficiaries utilized some form of telehealth service indicating that virtual care remains in high demand. At the same time, studies show that about 45% of patients receiving nutrition therapy through telehealth used audio-only visits, which highlights that not every patient has access to video technology.

These shifts highlight a new challenge for dietitians and billing teams in ensuring that telehealth claims are coded correctly. Among billing details, modifier choice is one of the most critical pieces. The correct modifier tells payers how the session was delivered (video vs. audio-only) and can make the difference between approved and denied claims.

In this blog, we will walk you through the step-by-step process of applying the correct modifiers in telehealth billing for nutrition therapy.

Step 1: Identify the Service Delivered (Video or Audio-Only)

The first step in correct modifier usage is determining whether the medical nutrition therapy session was delivered via real-time video or audio-only. When a dietitian provides services through live, two-way video, you should always use modifier 95 as it signals to payers that the visit was a synchronous telehealth encounter.

If the patient received services through an audio-only means, such as a phone call, then modifier 93 may be appropriate, but only when your payer explicitly allows audio-only MNT. In rare instances, some older payers may request modifier GQ for asynchronous encounters.

Step 2: Match the Modifier to the Correct CPT/HCPCS Code

After confirming the type of telehealth service, the next step is to connect the correct modifier with the appropriate CPT or HCPCS code. This ensures the claim is accurate and supports reimbursement.

• CPT Codes

You can use 97802 for initial assessments, 97803 for follow-up visits, and 97804 for group sessions for medical nutrition therapy. When these services are delivered via real-time video, always append modifier 95 to indicate that the session was a synchronous telehealth encounter. If your payer explicitly allows audio-only services, then modifier 93 should be applied to reflect the service modality accurately. This distinction ensures clarity for payers and prevents claim rejections.

• HCPCS and Special Situations

In certain cases, report G0270 or G0271 with the appropriate modifier for additional hours after a new referral. Some payers may still require legacy modifiers such as GT or GQ. In contrast, Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs) may require modifier FQ for audio-only encounters.

Step 3: Use the Appropriate Place of Service (POS)

The place of service code must always align with the telehealth modifier applied on the claim. This ensures the payer knows where the patient was during the telehealth session and prevents denials.

• Telehealth POS Codes

You should use POS 02 for telehealth sessions conducted outside the patient's home. If the patient receives care in their own home, report POS 10. These codes enable payers to distinguish clearly between traditional clinic visits and home-based telehealth sessions, which can impact reimbursement rates and payer requirements.

• In-Person and Institutional Billing

POS codes such as 11, 12, or 22 should be applied for in-person visits. Additionally, institutional claims often require including Revenue Code 942 alongside the CPT/HCPCS code and modifier. CMS clarified in 2024 that at-home telehealth visits must use POS 10.

Step 4: Handle Special Settings

Special billing rules apply when providing medical nutrition therapy in FQHCs or RHCs. These facilities operate under distinct reimbursement structures, so using the correct modifiers is critical for accurate billing and timely reimbursement.

• FQHC Telehealth Billing

Medicare requires reporting G2025 for distant site telehealth visits in FQHCs. You should apply modifier 95 for video-based sessions, whereas modifier FQ may be needed if the session is audio-only.

• MAC Variations

Medicare Administrative Contractors (MACs) may also require modifier 93 for audio-only visits in these settings. As FQHCs and RHCs follow unique rules compared to private practices, it is important to verify local MAC requirements before submitting claims.

Step 5: Document Everything to Support the Modifier Choice

Your documentation must clearly support the modifier applied to each claim as thorough records prevent denials and delays in reimbursement.

• Consent: Always document that the patient agreed to receive telehealth services, specifying whether the consent was verbal or written. Additionally, include the date and time to ensure that the record meets all payer and regulatory requirements.
• Modality Used: Clearly indicate whether the session was conducted via live video or audio-only.
• Reason for Audio-Only: If modifier 93 is used, explain why video could not be utilized. For instance, note patient limitations, technical difficulties, or lack of access to video technology, as this information justifies the use of an audio-only encounter.
• Start and Stop Times: Record the exact start and stop times for sessions billed under 97802 or 97803.
• Provider and Patient Location: Document both the provider's location and the patient's site of service to ensure proper alignment with the correct POS code.
• Clinical Notes: Include comprehensive clinical notes that cover assessment, counseling, and the plan of care.

Step 6: Avoid Common Mistakes with Modifiers

Avoiding errors with modifiers is essential as it ensures cleaner claims, faster reimbursement, and reduced risk of audits or denials.

• Wrong Modifier on Audio-Only: Do not apply modifier 95 for audio-only sessions as it incorrectly indicates a video-based encounter, which can result in claim rejection.
• Omitting Modifier 93: Always use modifier 93 when payers explicitly allow or require audio-only visits.
• Mismatch Between POS and Modifier: Ensure that the POS code aligns with the telehealth modifier that has been applied. For example, use POS 10 for at-home audio or video sessions to maintain consistency and compliance.
• Assuming Uniform Rules: Remember that commercial insurers, Medicaid, and Medicare may have different modifier requirements. Avoid assuming that one payer’s rules apply universally.
• Outdated Modifiers: Use legacy modifiers, such as GT or GQ, only if specifically required by the payer.

Conclusion

Telehealth billing rules are changing quickly, and nutrition practices must stay updated to avoid errors. Medicare has extended telehealth flexibilities, including coverage for audio-only visits, through March 2025. Beginning in 2025, the definition of "interactive telecommunications" will officially include audio-only encounters if a patient is unable to use video technology and the provider can offer video. At the same time, commercial insurers are testing new telehealth billing codes, and state Medicaid programs often implement updates more quickly than federal rules. This constant evolution means that the correct modifier today may no longer apply tomorrow.

Due to the frequency of such updates, outsourcing telehealth billing and coding services to 24/7 Medical Billing Services provides access to a team that consistently monitors payer updates and changes. These professionals apply the correct modifiers, such as 95, 93, FQ, GT, or GQ, depending on the service delivered. Also, the team ensures that CPT and HCPCS codes are paired with the proper place of service codes and supported by accurate documentation. As a result, nutrition practices can reduce errors before claims are submitted, which helps prevent costly denials and delays in payment.

FAQs

Q1. How often can patients receive nutrition therapy through telehealth?

Frequency depends on payer policy, with Medicare allowing a certain number of initial and follow-up hours each year.

Q2. Are group telehealth sessions for nutrition therapy reimbursable?

Group sessions can be billed, but payer approval is required.

Q3. Can out-of-state telehealth nutrition therapy be reimbursed?

Yes, but providers must meet state licensure rules where the patient is located.

Q4. Are telehealth nutrition therapy services covered for pediatric patients?

Many plans cover pediatric sessions, but rules vary.