2026 Telehealth Billing Rules: What Solo Practices Need to Know
2026 Telehealth Billing Rules: What Solo Practices Need to Know
Telehealth billing has been in a state of rolling change since 2020, and 2026 continues that pattern. Temporary flexibilities get extended, some become permanent, and state parity laws keep evolving. For a solo or small practice billing telehealth visits, the risk isn’t missing a cutting-edge policy change—it’s billing with outdated assumptions from two or three years ago.
This post is a plain-language summary of where things stand: place of service codes, modifier requirements, audio-only rules, and what’s permanent versus what’s still riding an extension.
For the primary source on Medicare telehealth policy, see CMS’s telehealth coverage page.
Place of Service Codes: POS 02 vs. POS 10
The place of service code on a claim tells the payer where the service was rendered. For telehealth, there are now two codes, and using the wrong one leads to a denial or a payment at the wrong rate.
POS 02 — Telehealth, patient not at home: Used when the patient receives telehealth services at a location other than their home—a clinic, a skilled nursing facility, a federally qualified health center, etc. This was the original telehealth POS code.
POS 10 — Telehealth, patient at home: Added in 2022 to distinguish home-based telehealth. Most commercial telehealth visits today—where the patient is sitting at their kitchen table—should use POS 10.
The practical consequence: POS 02 typically reimburses at the facility rate (lower), and POS 10 at the non-facility rate (higher). Billing POS 02 for a patient who was at home means you’re leaving money on the table. Check your ERA/EOBs from Aetna, UHC, Cigna, and BCBS to confirm you’re getting non-facility rates on home-based visits.
Modifier Cheat Sheet: 95, GT, and 93
Modifiers communicate additional information about a service to the payer. For telehealth, three modifiers come up most often, and they are not interchangeable.
| Modifier | When to Use |
|---|---|
| 95 | Synchronous telemedicine service rendered via real-time interactive audio and video. The standard modifier for most Medicare and commercial telehealth claims. |
| GT | Via interactive audio and video telecommunication systems. Required by some Medicaid programs and a handful of commercial payers that haven’t updated to modifier 95. Less common now but still required in certain payer-specific contexts. |
| 93 | Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. Used for audio-only visits where video is not available or is medically inappropriate. |
For most practices billing commercial insurance and Medicare in 2026: use modifier 95 as your default for video visits, modifier 93 for audio-only. Add GT only if a specific payer’s requirements call for it—check their telehealth billing guidelines if you’re getting denials on GT-appended claims.
Always use the telehealth modifier in addition to the correct POS code. A claim with POS 10 and no modifier, or a modifier with POS 11 (office), will often reject or deny.
Audio-Only Telehealth: What’s Allowed and for Whom
Audio-only (telephone) visits have a narrower coverage footprint than video telehealth, and the rules differ by payer and specialty.
Medicare: CMS extended audio-only telehealth coverage for certain services through the end of the current extension period. Behavioral health services—including psychotherapy codes like 90837 and E/M services for mental health diagnoses—have broader audio-only allowances than other specialties. Patients must have access to two-way audio-video and must make an informed choice to use audio-only instead.
Commercial payers: Coverage is inconsistent. Some payers—UHC and Cigna in particular—have defined audio-only telehealth benefits in their 2025–2026 plan documents. Others require video. Check payer-specific telehealth policies before assuming audio-only visits will be covered. A denial with a remark code indicating “service requires interactive audio/video” is a signal that modifier 93 or audio-only visits aren’t covered under that plan.
Documentation requirement: For audio-only, document why video wasn’t used. “Patient does not have access to video-capable device” or “patient declined video” is sufficient. This matters if the claim is audited.
Behavioral Health Telehealth: What’s Permanent vs. What’s Still an Extension
The clearest good news for behavioral health practices is that Congress has moved to make certain telehealth flexibilities permanent for mental health services, rather than relying on rolling extensions.
What has moved toward permanence:
- Mental health services can be provided via telehealth without requiring an in-person visit first for established patients (the in-person requirement for new patients under certain circumstances has had separate legislative treatment—confirm current status with CMS guidance).
- The patient’s home (POS 10) is a recognized originating site for behavioral health telehealth under Medicare.
- Federally Qualified Health Centers and Rural Health Clinics can serve as distant sites for mental health telehealth.
What is still extension-dependent:
- Telehealth for non-behavioral health specialties (primary care, dermatology, etc.) in non-rural areas remains subject to periodic extension under current law.
- The expanded list of telehealth-eligible CPT codes beyond the permanent list is maintained through extension authority.
For ICD-10 coding: behavioral health diagnoses on telehealth claims should be coded to full specificity—F32.9 for major depressive disorder unspecified, F41.1 for generalized anxiety disorder—the same as in-person. There is no telehealth-specific diagnosis requirement.
State Parity Laws
Most states have telehealth parity laws that require commercial insurers to cover telehealth services that are otherwise covered in person. However, “coverage parity” doesn’t always mean “payment parity.” Some state laws require coverage of the service but allow payers to reimburse at a lower rate for telehealth delivery.
The practical implication: even if your state has a parity law, verify your contracted rates with each commercial payer for telehealth CPT codes. If you’re seeing a systematic reimbursement gap between in-person and telehealth rates for the same codes—and your state has payment parity—that’s a contract dispute worth raising with the payer or reviewing with a billing consultant.
State telehealth laws change frequently. The current status of parity laws by state is tracked by several health policy organizations and updated annually.
Telehealth billing is not dramatically more complicated than in-person billing, but it does require paying attention to a few specific details—POS code, modifier, audio vs. video, and payer-specific rules—that don’t apply to office visits. Getting these right on the front end prevents a category of denials that are entirely avoidable.
If your practice has questions about telehealth billing setup or is seeing denials on telehealth claims, reach out to our team.
This post was drafted by AI and reviewed by our editorial team. Last updated 2026-05-30.