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how to bill for telehealth

How to Bill for Telehealth: A 2026 Step by Step Guide to Getting Every Virtual Visit Paid

By the Medicotech Billing Team | CPC Certified | Reviewed October 2026

This guide covers 2026 dates of service, including the October 1 change for rural health clinics and FQHCs and the two Medicare modifiers that start January 1, 2027. If your providers see even five patients a week by video, one wrong default in your EHR can shave money off every one of those claims without a single denial to warn you.

What do you need in place before you bill a telehealth visit?

Most telehealth denials start before the provider opens the video link. Check these five items at scheduling, not after the EOB shows up.

  • Coverage for this modality. A plan can pay for video and exclude phone visits for the same service. Our insurance eligibility verification team confirms video coverage, audio only coverage, copay, and deductible before the patient logs on.
  • A code on the payer’s telehealth list. Medicare publishes its list of covered telehealth services every year. Commercial plans keep their own lists, and they don’t always match.
  • A license in the patient’s state. The state where the patient sits during the visit decides which license applies. Your provider’s office address doesn’t.
  • Active enrollment with the plan. An unenrolled provider gets a denial no matter how clean the coding looks.
  • A HIPAA compliant platform with a signed BAA. Your video vendor touches PHI, so it needs a business associate agreement on file.

How do you bill for a telehealth visit, step by step?

Telehealth billing follows the same path as an office visit. You just make three extra calls on every claim: where the patient was, how the visit happened, and what this particular payer wants to see.

Step 1: Document the encounter like an auditor will read it

The note carries the claim. Record whether the visit ran on live video or phone, where the patient sat, where the provider sat, who else joined, and that the patient agreed to a telehealth visit. Then pick the E/M level by medical decision making or total time, exactly as you would in the exam room.

A real world example: an internal medicine provider in Tampa starts a follow up on video. At minute nine the patient’s connection freezes, so the provider finishes by phone. The note needs both facts and the times, because the change in modality decides which modifier you can defend later.

Step 2: Choose the code family this payer pays

For Medicare, bill video E/M visits with the office codes you already use, 99202 to 99215. The AMA’s newer telemedicine E/M codes, 98000 to 98015, don’t pay under Medicare because CMS treats them as noncovered. The exception is 98016, the brief virtual check in for established patients.

Some commercial plans and Medicaid programs do pay the 98000 series. So your medical coding services setup needs a payer by payer switch, not one default for everyone.

Step 3: Set the place of service from the patient’s location

POS 10 means the patient was at home. POS 02 means the patient was anywhere else: a clinic, a nursing facility, a desk at work. Medicare has paid POS 10 at the nonfacility rate since January 1, 2024, and POS 02 at the lower facility rate, so this one field moves real dollars.

Step 4: Add the telehealth modifier

Modifier 95 marks live audio and video. Modifier 93 marks audio only. Medicare’s claims processing manual pairs POS 02 or 10 with the matching modifier, though the modifier doesn’t change what Medicare pays; the POS does that. Medicaid and commercial plans write their own modifier rules, and a few still ask for GT.

Step 5: Add companion codes when they apply

G2211 can ride on a Medicare office E/M visit delivered by telehealth when your provider manages the patient’s care over time. And if the patient joined from a qualifying facility, that facility bills Q3014, the originating site fee, which CMS set at $31.85 for 2026.

Step 6: Scrub, submit, and reconcile

Run every claim through payer specific edits before the 837P or CMS-1500 leaves. Then match your telehealth schedule against posted charges each business day. Visits run on a standalone video platform slip through unbilled more often than you’d think, and nobody notices until month end.

Telehealth claim line examples (2026 dates of service)

ScenarioCodePOSModifier
Medicare, established patient, moderate MDM, live video, patient at home992141095
Same Medicare visit, patient joined from her office at work992140295
Medicare, 45 minute psychotherapy by phone, patient at home, declined video908341093
Commercial plan that pays the 98000 series, established patient, low MDM, video98005Per plan policyPer plan policy
RHC or FQHC, non behavioral video visit on or after October 1, 2026Individual CPT or HCPCS code (not G2025)Per RHC & FQHC claim rules95
(or audio-only modifier)

 

Which place of service code should you use for telehealth?

Use POS 10 when the patient is at home and POS 02 when the patient is anywhere else. CMS defines home as a private residence, not a hospital or other facility where the patient receives care.

Telehealth place of service codes compared

POSWhat It MeansMedicare PaymentWatch For
10Telehealth in the patient’s homeNonfacility Rate
(Matches an office visit rate)
The default for most direct-to-patient video visits.
02Telehealth anywhere other than homeFacility Rate
(Lower reimbursement yield)
Patients joining from work, a parked car, or a clinic location.
11OfficeInvalid for Medicare
Triggers immediate denial
A handful of commercial and Medicaid plans still want POS 11 with Modifier 95.

 

Here’s our mild hot take. Practices spend weeks comparing video platforms and almost no time on the one field that sets payment. The payer doesn’t care whether you used Zoom for Healthcare or Doxy.me. It cares a lot about where the patient sat.

The fix costs nothing. Have the provider ask “Where are you right now?” at the start of each visit and drop the answer into the note template.

Which telehealth modifier does each payer want?

Modifier 95 covers live video for most payers and modifier 93 covers audio only. The rest apply to narrow situations or start in 2027.

Telehealth modifiers in 2026 and 2027

ModifierWhat It MarksWho Uses It
95Live, synchronous audio and videoCommercial plans and many Medicaid programs; Medicare pairs it with POS 02 or 10 (no payment effect)
93Audio onlyMedicare audio-only visits to the home; many Medicaid and commercial plans
FQAudio only at an RHC or FQHCRural health clinic (RHC) and FQHC claims
GTInteractive audio and video LegacyA few commercial plans; Medicare CAH Method II institutional claims
GQAsynchronous store and forwardFederal telemedicine demonstration programs in Alaska and Hawaii
BBTelehealth through a virtual platform the practitioner contracts with or pays to useMedicare, required from
Jan 1, 2027
BCTelehealth furnished incident to a practitioner’s serviceMedicare, required from
Jan 1, 2027

BC matters most for groups that bill nurse practitioner or PA telehealth under a supervising physician’s NPI. Before you add it, make sure the arrangement qualifies at all. Our breakdown of incident to billing rules walks through the supervision and plan of care requirements. HHS also keeps a plain language summary of Medicare telehealth billing and coding.

 

Stop Telehealth Denials Before They Impact Your Revenue

Telehealth denials usually trace back to one wrong setting: the POS, the modifier, or the code family. Our telehealth medical billing team builds those rules into payer-specific edits, so your virtual visits pay like the in-person work they replace. Talk with us about where your video claims stall.

Get Medical Billing Support →

How do you bill insurance for telehealth services when payers disagree?

Start with the payer type, then read that specific plan’s telehealth policy. Medicare runs one national rule set. Medicaid changes by state. Commercial plans change by contract, and sometimes by product line inside the same carrier.

How to bill insurance for telehealth by payer type (2026)

RuleOriginal MedicareMedicaidCommercial PlansMedicare Advantage
Video E/M Codes99202–99215Set by the state manual; some accept the 98000 series99202–99215 or 98000 series, by planOften follows Medicare; the plan policy decides
Place of Service (POS)POS 10 (home)
POS 02 (elsewhere)
Varies; many follow the CMS splitMost follow the CMS split; a few want POS 11Plan policy
Modifier95 Video
93 Audio-Only
Varies by state95 most often; a few still use GTPlan policy
Audio-OnlyCovered to the home through Dec 31, 2027State policyPlan by plan; some exclude itPlan policy
Coverage DurationDec 31, 2027 for most flexibilitiesState lawThe contract termThe plan year

 

One habit saves hours of rework: keep a one page payer matrix and update it whenever a plan bulletin lands. And watch self funded employer plans. They sit outside state telehealth mandates, so a state coverage or parity law won’t protect those claims.

This payer matrix sits at the heart of our medical billing services, because the same visit can need three different claim formats in one afternoon.

How do you bill for an audio only telehealth visit?

Bill the same service code with modifier 93 and the correct POS. Medicare pays audio only care to patients at home through December 31, 2027, as long as your provider could use video and the patient couldn’t or wouldn’t.

Auditors look for four things in the note:

  • The provider had working video on their end.
  • The patient couldn’t use video or declined it, with the reason if they gave one.
  • The patient’s location (home, for Medicare audio only).
  • Total time, when the code depends on minutes.

Starting January 1, 2028, Medicare narrows audio only coverage to behavioral health services in the home unless Congress acts again. Plan your phone visit workflows with that date in mind.

What changed in telehealth billing in late 2026, and what comes next?

Congress extended most Medicare telehealth flexibilities through December 31, 2027, in the Consolidated Appropriations Act, 2026, signed February 3, 2026. But the billing details keep moving. Here’s the calendar we track for clients:

  • October 1, 2026: RHCs and FQHCs stopped billing G2025 for non behavioral distant site telehealth. They now report the individual CPT or HCPCS code plus a telehealth modifier, per CMS Change Request 14468.
  • Around November 1, 2026: CMS usually publishes the Physician Fee Schedule final rule about now, and the CY 2027 version will confirm or change the proposals below.
  • December 31, 2026: The DEA’s telemedicine prescribing flexibilities for controlled substances expire unless extended again. That’s a prescribing rule, not a billing rule, but it can push some visits back in person.
  • January 1, 2027: Medicare requires modifiers BB and BC on qualifying claims. Neither one changes payment. The proposed rule also raises Q3014 to $32.65.
  • December 31, 2027: Most Medicare telehealth flexibilities end without new action from Congress, including home visits for non behavioral care.
  • January 1, 2028: New telemental health patients at home need an in person visit within six months before their first telehealth service. Patients who started before then need one every 12 months.

Two CY 2026 changes are permanent. CMS removed telehealth frequency limits on subsequent inpatient visits, nursing facility visits, and critical care consultations. It also lets physicians provide direct supervision through real time audio and video for services without a 010 or 090 global period. The full detail sits in the CMS telehealth FAQ, updated October 2026.

Think back to the October 2025 shutdown. Practices that kept billing home telehealth without a plan spent weeks resubmitting claims returned with CARC 16 and RARC M77. Practices that held those claims released them the day the extension passed. Put December 31, 2027 on your calendar now.

Why do telehealth claims get denied, and how do you fix them?

Telehealth denials cluster around a short list of codes, and each one points straight at the setting that broke.

Common telehealth denials and fixes

Denial CodeUsual CauseFix
CO-4Modifier missing, or the wrong one for this payerApply the payer’s modifier rule and send a corrected claim.
CO-5POS doesn’t fit the service or the patient’s locationPull the location from the note and correct POS 10 or 02.
RARC N776The service isn’t on the payer’s telehealth listCheck the list before billing; rebill only if the documentation supports another service.
CARC 185The rendering provider isn’t eligible to bill this serviceConfirm the provider type and the enrollment record.
CO-197Pre-authorization missingRequest authorization before the visit and log the number and dates.

When the same denial shows up twice in one month, treat it as a setup problem, not a claim problem. A team that works telehealth denials every day will trace it back to the front desk script or EHR template that caused it.

Telehealth billing checklist

Run these seven checks before each telehealth claim leaves your office:

  1. The note records the patient’s location, and the POS matches it.
  2. The note records video or phone, and the modifier matches this payer’s rule.
  3. The code family fits the payer: 99202 to 99215, or the 98000 series where the plan pays it.
  4. Telehealth consent appears in the note.
  5. The provider holds a license in the patient’s state and active enrollment with the plan. If a provider still needs Medicare enrollment, follow our walkthrough on how to enroll in Medicare as a provider.
  6. Medicare claims with 2027 dates of service carry BB or BC when the arrangement calls for it.
  7. The charge matches an appointment on the telehealth schedule.

Uncover Hidden Revenue Leaks in Your Telehealth Claims

Every new rule, from the G2025 switch to the 2027 modifiers, adds one more place a telehealth claim can stall. Medicotech’s telehealth billing specialists review your last 90 days of virtual visit claims and show you which setting cost you money. Our coders hold a 96% first-pass clean claim rate, so book a free audit and see where your leaks are.

Get Your Free Telehealth Billing Audit →

Frequently asked questions

Can you bill telehealth with the same CPT codes as an in person visit?

Yes, for most services on the payer’s telehealth list. Medicare pays video E/M visits with 99202 to 99215 plus POS 02 or 10. Some commercial plans and Medicaid programs prefer the AMA’s 98000 to 98015 telemedicine codes instead, so check each plan’s policy before you set a default in your EHR.

What is the difference between POS 02 and POS 10?

POS 10 means the patient was at home during the visit. POS 02 means the patient was somewhere else, such as a clinic or a workplace. Medicare pays POS 10 at the nonfacility rate and POS 02 at the lower facility rate. Record the patient’s location in every note so the POS holds up on audit.

Does Medicare pay the 98000 telemedicine codes?

No, apart from 98016. CMS treats 98000 through 98015 as noncovered, so Medicare denies them. Bill Medicare video visits with 99202 to 99215 and the right POS, and use 98016 for a brief virtual check in with an established patient. Commercial plans and Medicaid programs decide for themselves.

Do you need patient consent to bill telehealth?

Usually, yes. Many states and payers require documented consent for telehealth, and Medicare requires consent for communication technology services such as the 98016 virtual check in. A short consent statement in the note, captured each visit or annually as the payer allows, covers most situations.

Can you bill telehealth for a patient in another state?

Only when your provider holds a license, or another legal permission, in the state where the patient sits during the visit. Compacts such as the Interstate Medical Licensure Compact shorten that process. The provider also needs active enrollment with the patient’s plan, or the claim denies even with perfect coding.

What are the new BB and BC telehealth modifiers?

They’re Medicare claim modifiers required from January 1, 2027. BB flags telehealth delivered through a virtual platform the practitioner contracts with or pays to use. BC flags telehealth furnished incident to a practitioner’s service. CMS says neither modifier changes payment, but you’ll need them on every qualifying claim.

How long will Medicare keep paying telehealth visits to patients at home?

Through December 31, 2027, under the Consolidated Appropriations Act, 2026. Starting January 1, 2028, most non behavioral telehealth goes back to rural and facility restrictions unless Congress acts again. Behavioral health telehealth in the home stays permanent, with in person visit requirements for new patients.

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