Telehealth billing changed more between 2020 and 2026 than most billing areas change in a decade. The COVID-era flexibilities that expanded telehealth coverage are unwinding on different timelines by payer. Medicare’s telehealth rules differ from Medicaid’s, which differ from commercial payers, which differ by state. A telehealth claim that was correct in 2023 may be incorrect in 2026 under the same payer.
The practices with the lowest telehealth denial rates have one thing in common: a biller who tracks these changes as they happen, not after the denials arrive.
The Three Telehealth Billing Problems That Generate the Most Denials
1. Place of Service Code Errors (POS 02 vs POS 10)
CMS introduced POS 10 (Telehealth Provided in Patient’s Home) in 2022. POS 02 (Telehealth) is now specifically for telehealth services where the patient is in a non-home setting — a clinic, hospital, or originating site.
Most practices are still billing all telehealth visits as POS 02 regardless of patient location. When the patient was home, the correct code is POS 10. Using POS 02 for home-based visits generates a claim-level edit at Medicare and an increasing number of commercial payers that have adopted the same distinction. The denial is CO-4 or a claim-level rejection — not obvious without knowing the POS change.
2. Telehealth Modifier Requirements by Payer
Modifier requirements for telehealth vary by payer and change frequently:
| Payer | Telehealth Modifier Requirement | Notes |
|---|---|---|
| Medicare (Part B) | No modifier required for most telehealth — use correct POS code | GT modifier was deprecated in 2022 |
| Medicare Advantage | Varies by plan — some require 95, some require GT, some require no modifier | Verify with each MA plan individually |
| Medicaid (state-specific) | GT, 95, or no modifier — varies by state and service type | State Medicaid telehealth rules vary widely |
| Most commercial (BCBS, United, Aetna) | Modifier 95 for synchronous audio-visual telehealth | Modifier GT still accepted by some payers |
| Audio-only visits | Modifier 93 for audio-only when allowed | Not all payers cover audio-only; state-dependent |
3. Telehealth Coverage Limitations Post-PHE
The COVID Public Health Emergency ended in 2023. Many telehealth flexibilities that were emergency measures have been extended through congressional action — but on temporary timelines that keep shifting. Mental health telehealth in-person requirements. Audio-only coverage. Originating site restrictions. Federally Qualified Health Center telehealth rules. These are moving targets.
A biller who isn’t actively tracking the current state of telehealth policy for each payer is billing based on rules that may no longer apply. The resulting denials don’t look like telehealth policy errors — they look like standard CO-50 (non-covered service) or CO-4 (incorrect code) denials until someone traces the pattern back to the policy change.
What Telehealth Billing Compliance Looks Like in Practice
For every telehealth claim, a trained telehealth biller verifies:
Patient location at time of visit (home = POS 10, non-home = POS 02 for Medicare; payer-specific for commercial). Correct modifier applied for this payer and service type. Covered service verification — telehealth coverage for this CPT code confirmed active for this payer as of this date. State-specific rules applied if the patient or provider was in a state with specific telehealth regulations.
This verification takes 2–3 minutes per claim for a trained specialist. Skipping it creates denial patterns that take months to unwind.
Pricing
| Option | Cost |
|---|---|
| Full-time dedicated telehealth billing specialist | $7/hr — $1,120/month |
| Free dedicated RCM manager | Included |
| 4-week free pilot | No cost |
| Contract | None |
Frequently Asked Questions
What modifier do I use for telehealth billing?
For most commercial payers: Modifier 95 for synchronous audio-visual telehealth. For Medicare Part B: no modifier required — use correct POS code (02 or 10 based on patient location). For Medicare Advantage: verify with each plan individually. For audio-only visits when covered: Modifier 93. State Medicaid plans vary — check your state’s telehealth billing guidelines.
What is the place of service code for telehealth?
POS 10 for telehealth visits where the patient is in their home. POS 02 for telehealth visits where the patient is in a non-home originating site (clinic, hospital, FQHC). This distinction was introduced by CMS in 2022 and is now applied by most major payers. Using POS 02 for home-based visits generates claim edits at Medicare and some commercial payers.
Is telehealth billing covered by Medicare?
Yes — Medicare covers a broad range of telehealth services, with coverage extended through multiple congressional actions post-PHE. Coverage requirements change periodically. Key current rules: patient must be in an eligible originating site (including the patient’s home), services must be on the Medicare telehealth approved services list, audio-only is covered for certain services with specific documentation requirements.
Book a free 15-minute call — or start the 4-week free pilot for telehealth billing coverage.
Related Resources
Mental health billing services — heavy telehealth users | How to reduce billing denials | What to do when a claim is denied