Telehealth Billing Guide 2026: Modifiers, Place of Service, and Payer Rules
Telehealth billing in 2026 remains one of the most confusing areas in all of medical billing — and the confusion costs practices real money. The Public Health Emergency (PHE) telehealth flexibilities that were extended through 2024 have now been codified into permanent rules, modified, or allowed to lapse depending on the specific provision, the payer, and the state. Practices that have not updated their telehealth billing workflows post-PHE are either leaving revenue on the table or billing incorrectly and accumulating audit risk.
This guide covers the complete 2026 telehealth billing landscape for both Medicare and commercial payers — modifiers, place of service codes, audio-only billing, originating site requirements, and the state-by-state parity law considerations your billing team must know.
1. The Two Telehealth Modifiers: 95 vs GT
The modifier used on a telehealth claim tells the payer how the service was delivered. Using the wrong modifier results in an automatic denial for most payers. The two primary telehealth modifiers are:
| Modifier | Meaning | Use With | Fee Schedule |
|---|---|---|---|
| 95 | Synchronous telemedicine via interactive audio and video | Commercial payers, Medicaid (most states) | Non-facility rate |
| GT | Via interactive audio and video telecommunication systems | Medicare (required) | Non-facility rate |
| GQ | Via asynchronous telecommunications system (store-and-forward) | Medicare — Alaska and Hawaii only | Non-facility rate |
| 93 | Synchronous telemedicine — patient in their home | Medicare (used with POS 02 or 10) | Non-facility rate |
Modifier GT is a Medicare-only modifier. Submitting claims to commercial payers with modifier GT instead of modifier 95 is a systematic error that causes claim rejections or processing as non-telehealth services. Always use modifier 95 for commercial payers and Medicaid.
2. Place of Service Codes for Telehealth
The Place of Service (POS) code on a telehealth claim determines the fee schedule applied and signals where the patient was located during the service. This is one of the most frequently miscoded elements in telehealth billing.
| POS Code | Description | When to Use | Reimbursement Impact |
|---|---|---|---|
| 02 | Telehealth — patient not in their home | Patient at a clinic, hospital, or other facility during the telehealth visit | Facility rate (lower) |
| 10 | Telehealth — patient in their home | Patient at home during the telehealth visit (most common) | Non-facility rate (higher) |
| 11 | Office | Provider's physical office — used when billing in-person with telehealth modifier (some payers) | Non-facility rate |
Critical 2026 update: POS 10 (patient's home) became the permanent standard for most Medicare telehealth services where the patient is at home. POS 02 is still used when the patient is at a healthcare facility. Many practices are still using POS 02 for all telehealth — losing the higher non-facility reimbursement rate that POS 10 provides for home-based services.
3. Audio-Only Telehealth Billing
Audio-only telehealth (telephone-only services without video) has more restrictive permanent coverage than audio-video telehealth. Under 2026 Medicare rules, audio-only telehealth is covered for a limited set of services, primarily behavioral health.
Medicare Audio-Only Covered Services (2026)
- Behavioral health services (psychotherapy, psychiatric diagnostic evaluation) when the patient is unable to use video technology
- The patient must be in their home (POS 10)
- The provider must document that the patient is unable to participate in audio-video telehealth and the clinical reason for proceeding with audio-only
- Use modifier FQ to indicate the service was furnished using audio-only communication technology
Audio-Only CPT Codes for Behavioral Health
| CPT Code | Description | Audio-Only Coverage |
|---|---|---|
| 98966 | Telephone E/M, 5–10 minutes | Medicare — non-behavioral health, limited coverage |
| 98967 | Telephone E/M, 11–20 minutes | Medicare — non-behavioral health, limited coverage |
| 98968 | Telephone E/M, 21–30 minutes | Medicare — non-behavioral health, limited coverage |
| 90832 | Psychotherapy, 16–37 min | Medicare with modifier FQ — behavioral health audio-only |
| 90834 | Psychotherapy, 38–52 min | Medicare with modifier FQ — behavioral health audio-only |
4. Commercial Payer Telehealth Rules (2026)
Commercial payer telehealth coverage varies significantly by payer, plan type, and state. Unlike Medicare, there is no single standard — each payer has its own policies on which services are covered, what modifiers are required, and whether reimbursement is at parity with in-person rates.
| Payer | Modifier Required | POS | Parity with In-Person |
|---|---|---|---|
| UnitedHealthcare | 95 | 02 or 10 | Yes — most services |
| Aetna | 95 | 02 or 10 | Partial — behavioral health at parity |
| Cigna | 95 | 02 or 10 | Yes — most services |
| Anthem / BCBS | 95 | 02 or 10 | State-dependent |
| Humana | 95 | 02 or 10 | Yes — most services |
| Medicaid (varies by state) | GT or 95 | State-specific | State parity law dependent |
5. State Telehealth Parity Laws
As of 2026, 43 states plus DC have telehealth parity laws — requiring commercial payers to reimburse telehealth services at the same rate as in-person services. However, the scope of these laws varies significantly. Some apply to all services; others only to behavioral health or specific specialties.
Key State Parity Considerations
- States with full parity: California, New York, Texas, Florida, Illinois — commercial payers must reimburse all covered telehealth services at in-person rates
- States with behavioral health only parity: Several states mandate parity for mental health and SUD telehealth specifically, without extending to all medical specialties
- States without payment parity: Payers may reimburse at a discount — know your state's law before assuming you will be paid at in-person rates
- If you believe a payer is violating your state's parity law by paying at a discounted rate, this constitutes an underpayment that can be disputed — document your state's specific parity statute and cite it in the dispute
6. Documentation Requirements for Telehealth Claims
Telehealth claims carry elevated audit risk because payers know this is an area of widespread billing errors. Documentation must be airtight for every telehealth visit:
- Platform used — document the HIPAA-compliant telehealth platform used for the visit (not required to name the platform in the note, but must be a compliant platform)
- Patient location — document where the patient was located during the visit (home, office, etc.) — this determines POS
- Provider location — document where you were located — some states have originating site requirements for the provider as well
- Patient consent — document that the patient consented to receive services via telehealth; many payers require a telehealth consent on file
- Clinical content — the clinical note must be as thorough as for an in-person visit; brief notes are an audit red flag
- Audio-only justification — if billing audio-only, document why the patient could not use video
RCMAXIS manages telehealth billing across 40+ EHR platforms with payer-specific rule libraries that update automatically when payer policies change. See our EHR integrations page to confirm we work with your platform, or start with a free revenue assessment to audit your current telehealth billing accuracy.
Related Services & Resources
References
- AMA. (2025). Telehealth Policy and Billing Survey. American Medical Association.
- CMS. (2026). Medicare Telehealth Services. Centers for Medicare and Medicaid Services.
- CMS. (2026). Physician Fee Schedule Final Rule — Telehealth Provisions. CMS.
- CCHP. (2026). State Telehealth Laws and Reimbursement Policies Report. Center for Connected Health Policy.
- ATA. (2025). State Telehealth Parity Laws: 2025 Year-End Update. American Telemedicine Association.
- AMA. (2025). CPT Professional Edition 2026. American Medical Association.