Telehealth billing asks three questions before a claim is built: where was the patient, how was the visit delivered, and is this payer covering it this year. Medicare identifies a professional telehealth service through the place of service code, most commercial and Medicaid plans also want modifier 95 or 93, and the flexibilities that broadened all of it run through December 31, 2027 rather than forever. A practice that assumes the rules match everywhere finds the denial weeks later, when the visit cannot be repeated.
What this covers
- Place of service follows the patient, not the clinician: POS 10 when the patient is at home, POS 02 when they are somewhere else, and POS 11 is not a Medicare telehealth code.
- POS 10 pays the Medicare non-facility rate and POS 02 pays the facility rate, so the place of service choice is a rate decision, not a formality.
- Modifier 95 attests to real-time audio and video, modifier 93 attests to audio-only, and modifier GT survives on Critical Access Hospital Method II institutional claims.
- The Consolidated Appropriations Act, 2026 extended the Medicare telehealth flexibilities through December 31, 2027, and the pre-2020 geographic and originating site rules return on January 1, 2028 for everything except behavioral health.
- Medicaid and commercial plans set their own modifier and place of service combinations, so the payer’s published policy, not Medicare’s, decides the claim.
The modifier says how the visit happened. The place of service code says where the patient sat, and only one of the two moves the money.Why a default POS code quietly underpays every home visit in the batch
Place of service follows the patient, not the clinician
The place of service code answers one question: where was the patient when the visit happened. CMS defines POS 02 as Telehealth Provided Other than in Patient’s Home and POS 10 as Telehealth Provided in Patient’s Home. POS 02 carries a 2017 effective date in the CMS code set, and its description was narrowed on January 1, 2022 so the home could have a code of its own.
The code is not a preference, and it is not decided by where the clinician sat. It follows the patient’s physical location, and it sets the rate. In the CY 2024 physician fee schedule CMS finalized that Medicare telehealth furnished to a patient in the home pays at the non-facility rate, the higher office-type rate, while POS 02 pays the facility rate. The CMS Telehealth FAQ names both codes directly.
| Field | What it describes | Where the answer comes from |
|---|---|---|
| Modifier 95 or 93 | How the visit was delivered | Real-time audio and video, or audio only |
| POS 02 | The patient is not at home | Facility rate |
| POS 10 | The patient is at home | Non-facility rate |
| POS 11 | The patient is in the office | Not a Medicare telehealth code; some payers still want it with modifier 95 |
Noridian reads the home code broadly. Its telehealth page lists temporary lodging such as a hotel or a homeless shelter, and a car or workplace chosen for privacy, as POS 10 situations, because CMS treats the home code as any private place that is not a hospital or other facility. Read home literally and the claim quietly pays the facility rate instead of the office rate.
HCPCS Q3014 is the originating site facility fee, billed by the site where the patient is, not by the distant-site practitioner. CMS set it at $31.85 for CY 2026, which is 80 percent of the lesser of the actual charge. Noridian adds that no originating fee should be billed when the patient is at home.
Modifier 95 and modifier 93: what each one attests
The modifier answers a different question. Noridian and Novitas both carry the same descriptor for modifier 95, synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system, and the same descriptor for modifier 93, synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system.
For Medicare fee-for-service, the modifier does less work than most billers assume. Noridian narrows modifier 95 to two situations, a visit where the clinician is in the hospital and the patient is at home, and outpatient therapy by a hospital-employed physical therapist, occupational therapist, or speech language pathologist, then states that it is not required on other telehealth visits. On a professional claim the place of service field carries the telehealth signal instead.
Commercial and Medicaid claims usually want more. Many plans require modifier 95 on a video visit and modifier 93 on an audio-only visit even when the place of service already says telehealth, and some refuse a claim without it. The fix is a written payer grid that names the identifier each plan expects.
Three older identifiers still appear. Modifier GT is allowed only on institutional claims billed by a Critical Access Hospital under optional payment Method II. Modifier GQ certifies asynchronous store-and-forward transmission and applies only to the Alaska and Hawaii federal demonstration. Modifier FQ marks audio-only and belongs only to rural health clinics and federally qualified health centers.
Modifier 95 with POS 11 says the visit was telehealth and in the office at once. Modifier 93 with POS 02 reports an audio-only visit outside the home, which sits outside the home-based audio-only permission CMS describes. Neither is a formatting problem; each is the claim disagreeing with the note.
The flexibilities are extended, not permanent
The current rules rest on legislation with an end date. President Trump signed H.R. 7148, the Consolidated Appropriations Act, 2026, on February 3, 2026, extending the major Medicare telehealth flexibilities through December 31, 2027. Noridian restated that in a February 5, 2026 article and pointed providers to the CMS Telehealth FAQ dated February 26, 2026.
The extension keeps the geographic flexibility: through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories, and an extended range of practitioners can bill for them.
What happens next is already written. Starting January 1, 2028, except for behavioral health services, beneficiaries will generally need to be in a medical facility and in a rural area to receive Medicare telehealth services. Physical therapists, occupational therapists, speech-language pathologists and audiologists will no longer be able to furnish Medicare telehealth.
Behavioral health is the exception that stayed. The Consolidated Appropriations Act, 2021 permanently removed geographic and place of service restrictions for behavioral health telehealth, so a beneficiary can receive it at home in any area, and two-way audio-only technology is permitted permanently. A behavioral health revenue cycle management team therefore works from a different baseline than a primary care practice.
Section 1834(m) of the Social Security Act requires an in-person, non-telehealth visit within 6 months before the first mental health telehealth service, effective after December 31, 2027. A beneficiary who began receiving mental health telehealth at home on or before December 31, 2027 is treated as established and needs at least one in-person visit every 12 months after that date.
Audio-only: permitted, but bounded
Audio-only is real, limited, and easy to bill against the wrong rule. The CMS Telehealth FAQ says beneficiaries may continue to receive audio-only telehealth services in their homes through December 31, 2027. Starting January 1, 2028, audio-only remains available for behavioral health furnished to a patient at home, provided the practitioner is technically capable of audio-video communication and the beneficiary is not capable of or does not consent to using video.
The December 2025 MLN booklet adds the condition that governs most non-behavioral audio-only visits. Since January 1, 2025, a practice may bill audio-only when the distant-site practitioner can support an audio-video system and the patient is at home but is not capable of, or does not consent to, using video.
- The patient was in their home, stated in the note.
- The practitioner’s system supported audio and video on that date.
- Why video was not used: no capable device, no connection, or the patient declined.
- That the patient was offered an audio-video or in-person option where policy requires it.
- That the service furnished every element of the code billed.
State programs write the conditions out in more detail. New York Medicaid covers audio-only only when audio-visual technology was unavailable to the patient for lack of equipment or connectivity, audio-only was the patient’s preference, the provider offered audio-video or in-person appointments on request, and the service could be delivered effectively without a visual component.
What CY 2026 made permanent, and what it added
The CY 2026 physician fee schedule final rule changed structure more than scope. CMS removed the distinction between provisional and permanent services on the Medicare telehealth list, so every service CMS adds now is permanent, though still subject to later review. Five codes were added effective January 1, 2026.
| Code | Descriptor CMS added to the telehealth list |
|---|---|
| 90849 | Multiple family group psychotherapy |
| G0473 | Group behavioral counseling for obesity |
| G0545 | Infectious disease add-on |
| 92622 | Auditory osseointegrated sound processor services |
| 92623 | Auditory osseointegrated sound processor services |
Three limits came off permanently. CMS removed telehealth frequency limits on subsequent inpatient visits (CPT 99231 through 99233), subsequent nursing facility visits (CPT 99307 through 99310), and critical care consultations (HCPCS G0508 and G0509). A MAC that still edits for those frequency limits is working from a superseded article.
Direct supervision changed in a way that reaches beyond telehealth. For services without a 010 or 090 global surgery indicator, the supervising physician or practitioner may now be present through real-time audio and visual interactive telecommunications, with audio-only excluded. That covers most incident-to services under 42 CFR 410.26, diagnostic tests under 42 CFR 410.32, pulmonary rehabilitation under 42 CFR 410.47, and cardiac rehabilitation under 42 CFR 410.49.
Medicaid and commercial payers write their own rules
Medicare’s answer does not transfer. State Medicaid programs set their own modifier and place of service combinations, and the differences are large enough that one template cannot cover them.
New York Medicaid accepts POS 02, 10, or 11 on a professional telehealth claim, treats modifier 95 and modifier GT as interchangeable indicators of audio-visual telehealth, and since July 1, 2025 directs Office of Mental Health providers to modifier 93 for eligible audio-only mental health services. All audio-only claims must carry the 93 or FQ modifier unless modifiers are not allowable, and the UA modifier is no longer used for audio-only. Virginia Medicaid uses modifier GT for telemedicine and 93 for audio-only, with its own tables for which services require the 93.
Commercial plans diverge further. A UnitedHealthcare Community Plan reimbursement policy recognizes but does not require POS 02 or 10 and requires modifier GQ, GT, or 95 instead. Its state notes read like a warning: in Missouri, modifiers 95, G0, GQ, and GT are not allowed except in POS 02 and 03; Texas disallows GT entirely and wants 95, 93, or FQ; and Nebraska reduces an audio-only service billed with modifier 93 by 15 percent.
| Payer | How it identifies a telehealth visit |
|---|---|
| Medicare fee-for-service | POS 02 or POS 10; modifier 95 in narrow situations |
| New York Medicaid | POS 02, 10, or 11; modifier 95 or GT; 93 for audio-only |
| Virginia Medicaid | POS 02 or 10; modifier GT; modifier 93 for audio-only |
| UnitedHealthcare Community Plan | Modifier GQ, GT, or 95; POS 02 or 10 recognized, not required |
The practical conclusion is a payer grid beside the charge entry screen that names, per plan, the place of service code, the modality modifier, and whether prior authorization is required. A medical billing services team reads it before the visit, not after adjudication.
A pre-visit check that keeps the claim clean
The place of service code and the modifier both describe facts about the encounter, so capture the facts first and let the codes follow.
Confirm where the patient will sit at scheduling and again at the start of the visit, then set POS 10 or POS 02 from that answer.
Record whether the visit was real-time audio and video or audio only, and set modifier 95 or 93 to match what happened, not what was planned.
Confirm the code is on the Medicare telehealth list, or on that plan’s telehealth list for the date of service.
Confirm the practitioner type is eligible and licensed in the state where the patient is. Medicare requires a separate enrollment for each state where the practitioner provides services.
One line on the modality, one on the patient’s location, the consent, and the reason audio-only was used when it was.
Medicare Advantage plans and Medicaid managed care organizations may require prior authorization, and an authorization for an in-person visit does not always cover the virtual one.
Two Medicare edits explain most telehealth denials, both described in the CMS Claims Processing Manual, Chapter 12, Section 190.7. A service billed with POS 02 whose procedure code is not a designated covered telehealth service denies with group code CO, CARC 96 (non-covered charge), RARC N776, and MSN 9.4. A practitioner who is not eligible to bill for telehealth denies with group code CO, CARC 185, and MSN 21.18.
A CARC 96 with RARC N776 on a telehealth line is a coverage-list problem, not a documentation problem. A better note on a code that is not on the payer’s telehealth list will not move it, and the appeal has to argue coverage rather than medical necessity.
Telehealth billing questions
It depends on where the patient was, not where you were. POS 10 covers telehealth provided in the patient’s home, which includes temporary lodging and a car or workplace used for privacy. POS 02 covers every other location, such as a clinic, school, or skilled nursing facility. Medicare pays POS 10 at the non-facility rate and POS 02 at the facility rate.
Usually not on a professional Medicare fee-for-service claim. Noridian lists modifier 95 for a visit where the clinician is in the hospital and the patient is at home, and for outpatient therapy, then states it is not required on other telehealth visits. The place of service code identifies the service. Most commercial and Medicaid plans do require modifier 95, so check each payer’s policy.
Under Medicare, yes, with limits. Through December 31, 2027 beneficiaries may receive audio-only services in their homes. Audio-only remains permanently available for behavioral health to a patient at home when the practitioner can support video and the patient cannot use it or declines it. Bill modifier 93, or FQ for a rural health clinic or federally qualified health center, and document why video was not used.
The current extensions run through December 31, 2027 under the Consolidated Appropriations Act, 2026, which was signed on February 3, 2026. Starting January 1, 2028, beneficiaries will generally need to be in a medical facility in a rural area for most telehealth services. Behavioral health telehealth, including audio-only to a patient at home, is permanent.
Often yes, but the place of service code decides. Since January 1, 2024, Medicare pays telehealth furnished to a patient in the home at the non-facility rate, which is the same higher rate an office visit carries. POS 02 pays the facility rate, which is lower. The modifier does not change the rate; only the place of service code does.
CARC 96 is a non-covered charge, and with RARC N776 on a telehealth line it usually means the procedure code was not on the payer’s covered telehealth list for that date. The CMS Claims Processing Manual, Chapter 12, Section 190.7, describes exactly that edit. A second edit, CARC 185, means the practitioner was not eligible to bill for telehealth.
The bottom line
Telehealth billing is a three-field exercise before it is a coding exercise. Where the patient was sets the place of service code and the rate, how the visit happened sets the modifier, and who is paying decides which list the code must appear on.
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Request a free telehealth billing reviewThis article describes general telehealth billing practice and the Medicare, MAC and Medicaid rules current at the time of writing, and place of service codes, modifiers, covered service lists and payment rates vary by payer, plan and state program, so confirm them with your MAC and each payer before relying on them.
