What place of service code do you use for telehealth visits?

For telehealth visits where the patient is at home, use Place of Service (POS) 10 (Telehealth Provided in Patient's Home). For telehealth visits where the patient is at a healthcare facility, use POS 02 (Telehealth Provided Other than in Patient's Home). Medicare and most commercial payers now reimburse telehealth E/M visits at the same rate as in-person visits when POS 10 is used, though some payers still apply a facility rate reduction.

What modifier is used for telehealth billing?

Modifier -95 is used to indicate a synchronous telehealth service rendered via real-time interactive audio and video. For Medicare, modifier -95 is appended to the CPT code along with the appropriate POS code. Some commercial payers use modifier -GT instead of -95. Always verify the specific modifier requirement with each payer, as using the wrong telehealth modifier is a common denial reason.

Can you bill the same E/M codes for telehealth as in-person visits?

Yes. Standard E/M codes (99202-99215 for office visits, 99241-99245 for consultations) can be used for telehealth visits when the service meets all documentation requirements for the code level. The same medical decision-making criteria apply. The only difference is the addition of the telehealth modifier (-95 or -GT) and the appropriate place of service code. Audio-only visits use different codes (99441-99443) with lower reimbursement.

Does Medicare cover telehealth visits permanently?

Yes. The Consolidated Appropriations Act made many telehealth flexibilities permanent, including coverage for telehealth visits from the patient's home, removal of geographic restrictions, and coverage for audio-only visits for behavioral health. Medicare covers telehealth E/M visits, behavioral health services, and certain specialty consultations permanently. However, the specific list of covered telehealth services is updated annually by CMS.

Telehealth Billing: Coding and Compliance Guide 2026

Billing Compliance March 26, 2026 10 min read

Telehealth billing in 2026 is no longer a temporary COVID-era exception — it is a permanent component of healthcare delivery with its own set of coding rules, compliance requirements, and payer policies. Yet telehealth claims still have a 15-20% higher denial rate than in-person visit claims, primarily due to incorrect modifier usage, wrong place of service codes, and failure to verify payer-specific telehealth policies.

This guide covers everything your practice needs to bill telehealth services correctly, compliantly, and at maximum reimbursement.

15-20%

Higher Denial Rate (Telehealth)

POS 10

Patient-at-Home Code

-95

Primary Telehealth Modifier

Telehealth Visit Types and CPT Codes

Synchronous Video Visits (Real-Time)

Synchronous telehealth visits use standard E/M codes — the same codes you bill for in-person visits. For new patients, use 99202-99205. For established patients, use 99211-99215. The E/M level is determined by the same medical decision-making (MDM) criteria as in-person visits. The key difference is appending modifier -95 (or -GT for certain payers) and using the correct place of service code.

Documentation requirements mirror in-person visits: chief complaint, history of present illness, review of systems, physical examination (to the extent possible via video), assessment, and plan. The exam component is limited by the virtual format — document what was observed (general appearance, visible skin findings, respiratory effort) and note that the examination was performed via real-time video.

Audio-Only Visits (Telephone)

Audio-only visits use dedicated telephone E/M codes: 99441 (5-10 minutes), 99442 (11-20 minutes), and 99443 (21-30 minutes). These reimburse at a lower rate than video visits — approximately 60-70% of the equivalent in-person E/M code. Medicare covers audio-only visits for established patients in behavioral health settings permanently, and for other specialties under certain conditions. Commercial payer coverage for audio-only visits varies significantly — always verify before billing.

Remote Patient Monitoring (RPM)

Remote patient monitoring uses a separate set of CPT codes: 99453 (initial setup and patient education, billed once per episode), 99454 (device supply with daily recording/programmed alert transmission, billed per 30-day period), 99457 (remote physiologic monitoring treatment management, first 20 minutes), and 99458 (each additional 20 minutes). RPM can generate $120-$180 per patient per month in recurring revenue. It requires FDA-cleared devices, a minimum of 16 days of data transmission per 30-day period, and documented clinical review of the data.

Virtual Check-Ins and E-Visits

Brief virtual check-ins (HCPCS G2012, 5-10 minutes by phone or video) and patient-initiated e-visits via patient portal (99421-99423) are separately billable services that many practices underutilize. G2012 reimburses approximately $15-$20 and is appropriate for brief symptom assessments that determine whether an in-person or full telehealth visit is needed.

Place of Service Codes

Place of service (POS) is one of the most common sources of telehealth billing errors. Using the wrong POS code can result in a denial or, for Medicare, reimbursement at the lower facility rate.

POS 10 — Telehealth Provided in Patient's Home: Used when the patient is at their residence during the telehealth visit. This is the most common POS for telehealth in 2026. Medicare reimburses at the non-facility (office) rate for POS 10.
POS 02 — Telehealth Provided Other than in Patient's Home: Used when the patient is at a clinic, hospital, or other healthcare facility during the telehealth visit. Medicare reimburses at the facility rate for POS 02, which is lower than the non-facility rate.
POS 11 — Office: Do not use POS 11 for telehealth visits. This is a common error that results in denials. POS 11 is only for in-person office visits.

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Modifier Requirements by Payer

Medicare

Medicare requires modifier -95 for synchronous telehealth services. The claim must also include the appropriate POS code (10 or 02). For services on the Medicare Telehealth Services List, no additional modifier is needed beyond -95 and the POS code. For audio-only behavioral health visits, append modifier -93 (synchronous telemedicine service rendered via telephone or other real-time interactive audio-only technology).

Commercial Payers

Commercial payer requirements are inconsistent. Some accept modifier -95, others require modifier -GT (via interactive audio and video telecommunications systems), and some require both. UnitedHealthcare, Aetna, and Cigna generally accept modifier -95. Blue Cross Blue Shield plans vary by state — some require -GT, others accept -95. Always verify the specific modifier requirement for each payer before billing. Building a payer-specific telehealth modifier matrix is essential.

Medicaid

Medicaid telehealth rules vary by state. Some states have adopted Medicare's modifier -95 approach, while others use state-specific modifiers or billing codes. Coverage for audio-only visits also varies by state. Check your state Medicaid program's telehealth billing guide for current requirements.

Compliance Requirements

State Licensure

Providers must be licensed in the state where the patient is physically located at the time of the telehealth visit, not where the provider is located. Interstate compacts (like the IMLC for physicians and the Psychology Interjurisdictional Compact for psychologists) simplify multi-state practice but do not cover all states. Verify licensure requirements before providing cross-state telehealth services.

Informed Consent

Many states require documented patient consent for telehealth services. Even where not legally required, documenting consent is a best practice. The consent should cover the nature and limitations of telehealth, that the visit is being conducted via technology, privacy and security of the platform, the patient's right to decline telehealth and request an in-person visit, and any applicable costs.

Platform Requirements

The telehealth platform must be HIPAA-compliant with end-to-end encryption. Consumer platforms (FaceTime, Zoom consumer, Skype) do not meet HIPAA requirements for routine use. Use a HIPAA-compliant telehealth platform or a BAA-covered version of commercial tools (Zoom for Healthcare, Microsoft Teams for Healthcare).

Maximizing Telehealth Revenue

Bill the correct E/M level. Many providers default to lower E/M levels for telehealth visits. If the MDM complexity supports 99215, bill 99215 — regardless of whether the visit is in-person or virtual. The documentation requirements are identical.
Capture RPM revenue. For patients with chronic conditions (hypertension, diabetes, CHF, COPD), remote patient monitoring generates $120-$180 per patient per month in recurring revenue. A practice with 100 RPM patients generates $144,000-$216,000 annually from RPM alone.
Bill virtual check-ins. Brief phone calls with established patients (G2012) are billable if they are not related to a visit within the prior 7 days or do not lead to a visit within 24 hours. Many practices are already doing these calls but not billing them.
Use the right POS code. POS 10 (patient at home) reimburses at the higher non-facility rate for Medicare. Using POS 02 instead of POS 10 reduces reimbursement by $20-$40 per visit.
Verify payer telehealth policies quarterly. Payer telehealth policies change frequently. A service covered last quarter may not be covered this quarter, and new services are added regularly. Assign someone to review and update your telehealth billing matrix every 90 days.

Revenue opportunity: Practices that optimize telehealth billing — correct modifiers, correct POS codes, RPM enrollment, and virtual check-in capture — typically generate 15-25% more telehealth revenue than practices using default billing approaches. The coding is the same complexity; the revenue difference is in the details.

The Bottom Line

Telehealth billing in 2026 is permanent, complex, and payer-specific. The practices that master telehealth coding — correct modifiers, correct POS codes, appropriate E/M levels, and RPM enrollment — maximize revenue from virtual care. Those that treat telehealth billing as an afterthought lose 15-20% of their telehealth revenue to preventable denials and undercoding.

Need telehealth billing expertise? Revenue Synergy manages telehealth billing across all payers and specialties for 500+ providers. Schedule a free consultation to ensure your telehealth billing is optimized and compliant.