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Telehealth Intelligence Center

Telehealth Billing
Reference Hub

Everything you need to bill telehealth correctly — POS requirements, modifiers (95, 93, FQ, FR), documentation, denials, payer rules, an interactive decision workflow, and FAQ.

Decision WorkflowPOS Intelligence Center

Important: Telehealth policies evolve rapidly. Always verify current CMS guidance, payer-specific telehealth policies, state laws, and licensing requirements. The information here is for educational purposes only and does not guarantee payment.

Telehealth Modalities

Four primary telehealth delivery methods — each with different coverage, POS, and modifier requirements.

Audio + Video (Synchronous)

Real-time, two-way audio and visual communication between provider and patient. This is the standard for synchronous telehealth.

POS: 10 (patient home) or 02 (other location)
Modifier: 95 (synchronous audio + video telehealth)
Coverage: Broadest coverage. Most CPT codes eligible for telehealth are covered with audio+video. Medicare covers audio+video for most telehealth services.

Audio Only (Synchronous)

Real-time, two-way audio communication without video. Used when video is not available or the patient does not consent to video.

POS: 10 (patient home) or 02 (other location)
Modifier: 93 (audio-only telehealth, where accepted)
Coverage: Limited coverage. Medicare covers audio-only for specific services (e.g., behavioral health, some E/M). Most payers have limited audio-only coverage.

Store and Forward (Asynchronous)

Transmission of recorded health information (images, video, data) through an electronic communication system for review by a provider at a later time.

POS: Typically not applicable (no POS for store-forward in most cases)
Modifier: GQ (asynchronous telehealth, where accepted)
Coverage: Limited coverage. Medicare covers store-forward in limited circumstances (e.g., dermatology, radiology). Some payers offer broader coverage.

Remote Patient Monitoring (RPM)

Digital technologies to collect medical and other health data from patients and electronically transmit to providers for assessment.

POS: Typically not applicable (no POS for RPM)
Modifier: RP (RPM, where accepted)
Coverage: Growing coverage. Medicare covers RPM under specific codes. Most payers now offer some RPM coverage. Check payer policies for specific RPM codes.

POS Requirements for Telehealth

Correct POS is critical for telehealth billing. Use POS 10 (home) or 02 (other) post-PHE.

10

POS 10

Telehealth in Patient's Home

Use when the patient is at their home (house, apartment, residence) during the telehealth visit.

When: Patient is at home.
Modifier: 95 (audio+video) or 93 (audio-only)
Example: Patient has a video visit from their living room with a doctor at the clinic.
02

POS 02

Telehealth Other than Patient's Home

Use when the patient is at a location other than their home (clinic, school, nursing facility) during the telehealth visit.

When: Patient is NOT at home (clinic, SNF, school, work, etc.).
Modifier: 95 (audio+video) or 93 (audio-only)
Example: Patient at a rural clinic has a video visit with a specialist at a hospital.
11

POS 11

Office (PHE Flexibility — Ended)

During the COVID-19 PHE, telehealth could be billed as if in the office using POS 11 with modifier 95. Post-PHE, use POS 10 or 02 for telehealth.

When: No longer standard for telehealth (post-PHE). Verify payer policies.
Modifier: 95 (if still accepted by payer for telehealth in office)
Example: During PHE, a video visit was billed as POS 11 with modifier 95.
Browse all POS codes

Telehealth Modifiers

Choose the right modifier for the telehealth modality. Incorrect modifiers cause denials.

ModifierNameWhen to UsePayer Notes
95Synchronous Telehealth (Audio + Video)Audio + video, real-time.Accepted by most payers. Medicare, Medicaid, and most commercial payers accept modifier 95 for synchronous audio+video telehealth.
93Audio-Only TelehealthAudio only, real-time.Acceptance varies. Medicare covers audio-only for specific services (behavioral health, some E/M). Check payer policy for audio-only coverage and modifier requirements.
FQAudio-Only Behavioral Health (Medicare)Audio only, behavioral health, Medicare.Medicare-specific. Use FQ for audio-only behavioral health services. Check Medicare telehealth behavioral health policies.
FRAudio-Video Behavioral Health (Medicare)Audio + video, behavioral health, Medicare.Medicare-specific. Use FR for audio+video behavioral health services. Check Medicare telehealth behavioral health policies.
GQAsynchronous (Store-and-Forward) TelehealthAsynchronous, store-and-forward.Limited acceptance. Medicare covers store-forward in limited circumstances. Check payer policy for store-forward coverage.
GTSynchronous Telehealth (Legacy)Audio + video, real-time (legacy).Mostly deprecated. Most payers now accept modifier 95 instead of GT. Check if the payer still accepts GT.

Documentation Requirements

  • Modality: Document audio+video or audio-only.
  • Patient location: Document the patient's location (originating site).
  • Provider location: Document the provider's location.
  • Patient consent: Document consent for telehealth and audio-only if applicable.
  • Clinical content: Document the same clinical content as an in-person visit.
  • Medical necessity: Document the medical necessity of the service.
  • Audio-only justification: If audio-only, document why video was unavailable or declined.

Medical Necessity

Medical necessity must be documented for both the service and the telehealth delivery. Document why the patient could not be seen in person and why telehealth was appropriate.

  • Document the clinical reason for the visit.
  • Document why telehealth was appropriate for this visit.
  • For audio-only, document why video was not available.
  • For behavioral health, document the treatment plan.
  • For chronic conditions, document ongoing management needs.

Telehealth Service Types

Coverage, POS, and modifier requirements vary by service type.

Behavioral Health

Mental health and substance use disorder services delivered via telehealth. Includes psychotherapy, psychiatric evaluation, and medication management.

CPT Codes: 90791-90792 (psychiatric diagnostic evaluation), 90832-90838 (psychotherapy), 90839-90840 (crisis psychotherapy), 90845-90853 (group/family therapy), 99201-99215 (E/M with psychotherapy add-ons).
POS: POS 10 (home) or 02 (other).
Modifier: 95 (audio+video), 93 (audio-only, some payers), FQ (Medicare audio-only BH), FR (Medicare audio+video BH).
Considerations: Behavioral health has the broadest telehealth coverage. Audio-only is widely covered for behavioral health. Medicare has specific behavioral health telehealth policies. Most payers cover individual and group therapy via telehealth.
Common Denials: CO-16 (missing modifier), CO-50 (not medically necessary), CO-24 (telehealth not covered for this service).

Therapy (PT, OT, SLP)

Physical therapy, occupational therapy, and speech-language pathology services delivered via telehealth. Coverage varies significantly by payer.

CPT Codes: 97110-97164 (PT therapeutic procedures), 97165-97168 (OT evaluation), 92521-92526 (SLP evaluation and treatment), 97010-97546 (modalities and physical medicine).
POS: POS 10 (home) or 02 (other).
Modifier: 95 (audio+video). Audio-only is generally NOT covered for therapy services.
Considerations: Therapy telehealth coverage varies significantly by payer and state. Some payers cover e-visits and virtual check-ins. Medicare covers limited therapy telehealth services. PT/OT/SLP telehealth often requires video.
Common Denials: CO-16 (missing modifier or POS), CO-50 (not medically necessary), CO-24 (therapy telehealth not covered).

Office Visits (E/M)

Evaluation and Management (E/M) office visits delivered via telehealth. The most common telehealth service type.

CPT Codes: 99201-99215 (office/outpatient E/M), 99221-99223 (initial inpatient), 99231-99233 (subsequent inpatient), 99238-99239 (discharge), 99421-99423 (online digital E/M).
POS: POS 10 (home) or 02 (other).
Modifier: 95 (audio+video), 93 (audio-only, limited coverage).
Considerations: Office E/M via telehealth is widely covered. Video is standard. Audio-only coverage is limited. During PHE, E/M telehealth could be billed with POS 11. Post-PHE, use POS 10 or 02. Check payer-specific E/M telehealth policies.
Common Denials: CO-16 (missing POS or modifier), CO-50 (not medically necessary), CO-24 (E/M telehealth not covered).

Hospital Services

Inpatient and outpatient hospital services delivered via telehealth. Includes inpatient E/M, critical care, and consultations.

CPT Codes: 99221-99223 (initial inpatient), 99231-99233 (subsequent inpatient), 99238-99239 (discharge), 99291-99292 (critical care), 99251-99255 (consultations).
POS: POS 21 (inpatient), POS 22 (outpatient), POS 10 or 02 (patient location for telehealth).
Modifier: 95 (audio+video). For inpatient, the facility may bill separately.
Considerations: Hospital telehealth involves both professional and facility billing. Inpatient telehealth requires careful POS selection. The patient's location may differ from the provider's. Check Medicare telehealth policies for inpatient services.
Common Denials: CO-97 (bundling), CO-16 (incorrect POS), CO-50 (not medically necessary), CO-24 (hospital telehealth not covered).

Payer-Specific Considerations

Telehealth coverage varies by payer type. Always verify the payer's current telehealth policy.

Medicare

Medicare telehealth policies are governed by CMS. Coverage expanded significantly during the PHE and continues to evolve.

POS: POS 10 (home) or 02 (other). During PHE, POS 11 was allowed.
Modifier: 95 (audio+video), 93 (audio-only, limited), FQ (BH audio-only), FR (BH audio+video).
Audio-Only: Medicare covers audio-only for specific services (behavioral health, some E/M). Check the Medicare telehealth services list for audio-only coverage.
Audio+Video: Medicare covers audio+video for services on the Medicare telehealth services list. Most E/M, behavioral health, and some specialty services are covered.
Official Policy

Medicaid

Medicaid telehealth policies vary by state. Each state Medicaid program sets its own telehealth coverage rules.

POS: Varies by state. Check state Medicaid telehealth policy.
Modifier: Varies by state. Some states use 95, others use GT or state-specific modifiers.
Audio-Only: Coverage varies by state. Many states cover audio-only for behavioral health. Check state Medicaid policy.
Audio+Video: Most state Medicaid programs cover audio+video telehealth. Coverage varies by service type and provider. Check state Medicaid policy.
Official Policy

Commercial Payers

Commercial payer telehealth policies vary significantly. Each payer sets its own rules for telehealth coverage, POS, and modifiers.

POS: POS 10 or 02 is standard. Some payers may still accept POS 11 with modifier 95. Check payer policy.
Modifier: 95 (audio+video) is standard. 93 (audio-only) is accepted by some payers. Check payer-specific modifier requirements.
Audio-Only: Audio-only coverage varies by payer. Some cover it for behavioral health. Check payer policy for audio-only coverage and requirements.
Audio+Video: Most commercial payers cover audio+video telehealth. Coverage varies by service type. Check payer policy for specific telehealth coverage.
Official Policy

Common Denials & Rejections

The most common telehealth denial and rejection scenarios — and how to prevent and fix them.

CO-16

Missing or Incorrect Information

Missing or incorrect POS code (should be 10 or 02), missing telehealth modifier (95 or 93), or incorrect modifier for the modality.

Prevention

Verify POS code (10 for home, 02 for other). Append modifier 95 for audio+video, 93 for audio-only. Check payer-specific modifier requirements.

Fix

Correct the POS and/or modifier and resubmit as a corrected claim. Reference the payer's telehealth policy for the correct POS and modifier.

CO-24

Service Not a Covered Benefit

The telehealth service is not a covered benefit under the patient's plan, or the specific CPT code is not eligible for telehealth delivery.

Prevention

Verify the CPT code is eligible for telehealth. Check the payer's telehealth covered services list. Check the patient's plan benefits.

Fix

Appeal with documentation of medical necessity and the payer's telehealth coverage policy. If the service is not covered via telehealth, consider an in-person visit.

CO-50

Medical Necessity

The telehealth service is not deemed medically necessary, or the documentation does not support the medical necessity of the telehealth delivery.

Prevention

Document the medical necessity of the service AND the medical necessity of telehealth delivery (why the patient could not be seen in person).

Fix

Appeal with additional documentation supporting medical necessity. Include the clinical rationale for telehealth delivery.

CO-97

Bundling

The telehealth service is bundled into another service and cannot be billed separately.

Prevention

Check NCCI edits for telehealth services. Do not bill bundled services separately. Use appropriate modifiers (59, XE, XP, XS, XU) for distinct services.

Fix

Check NCCI edits and rebill with appropriate modifier if the service is distinct. If truly bundled, write off the denied service.

CO-11

Diagnosis Inconsistent with Procedure

The diagnosis code does not support the telehealth service or the CPT code billed.

Prevention

Ensure the diagnosis code supports the CPT code and the telehealth delivery. Use the most specific diagnosis code.

Fix

Correct the diagnosis code and resubmit as a corrected claim. Ensure the diagnosis supports the service and the telehealth modality.

CO-24 / Bypass

Multiple Modifiers / Modifier Bypass (Rejected)

Claim rejected due to modifier issues — missing modifier, wrong modifier for modality, or payer does not accept the modifier submitted.

Prevention

Verify the correct modifier for the modality (95 for audio+video, 93 for audio-only). Check payer-specific modifier requirements. Do not use deprecated modifiers (GT, GQ unless required).

Fix

Correct the modifier and resubmit. If the payer does not accept the modifier, check their telehealth billing guide for the correct modifier.

Interactive

Telehealth Decision Workflow

Answer a few questions to determine the correct POS and modifier for your telehealth claim.

1Step 1 of 3

Is the service real-time (synchronous) or asynchronous (store-and-forward)?

Frequently Asked Questions

Common questions about telehealth billing, POS codes, modifiers, and documentation.

Official References

Authoritative sources for telehealth billing policies and guidance.

CMS Medicare Telehealth Services

Official CMS page with the Medicare telehealth services list, POS requirements, and modifier guidance.

CMS Telehealth and Remote Medicine

CMS resource page covering telehealth, telemedicine, and virtual services.

HRSA Telehealth.hhs.gov

U.S. Health Resources & Services Administration telehealth resource with policy updates and best practices.

Medicaid Telehealth Policy

Medicaid.gov telemedicine page with federal guidance and links to state Medicaid telehealth policies.

FCC COVID-19 Telehealth Program

Federal Communications Commission telehealth program information and resources.

HIPAA and Telehealth

HHS guidance on HIPAA compliance for telehealth services, including allowable platforms during PHE.

Future-Ready Pipeline

Connected tools and resources for telehealth billing support.

Knowledge Center

Visit the Knowledge Center for in-depth articles on telehealth billing, POS requirements, and payer policies.

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