Telehealth Billing Services
Medicare’s telehealth flexibilities now run through December 31, 2027, under the Consolidated Appropriations Act, 2026. Until then a Medicare patient can be seen at home anywhere in the country, audio-only is allowed when video is not, and physical and occupational therapists can bill telehealth. The claim still has to show where the patient was and how the visit was delivered, and from January 1, 2027, it needs two new modifiers when they apply.
What telehealth billing covers
The CPT code is the same as for the in-person visit. The location and modality codes are what change.
Medicare pays telehealth only for services on the Medicare Telehealth Services List, which has more than 250 codes; from 2026, every service added to the list is permanent. The claim uses place of service 10 when the patient is at home, paid at the non-facility rate, or 02 when the patient is somewhere else, paid at the facility rate. Modifier 93 marks an audio-only visit. Modifier 95 is not required on most professional Medicare claims, but many Medicaid and commercial plans still ask for it.
When the patient is at an originating site such as a clinic or hospital, that site can bill HCPCS Q3014, paid at 80% of the lesser of its charge or $31.85 in 2026. Care management, remote patient monitoring, and other services that do not replace a face-to-face visit are not Medicare telehealth services, so they do not carry telehealth POS codes or modifiers.
What the telehealth fee covers
- POS 02 or 10 set from the documented patient location
- Modifier 93, 95, or FQ, or the payer’s own rule, set per plan
- Each code checked against the telehealth list and the payer’s policy
- BB and BC modifiers added from January 1, 2027
Telehealth place of service codes and modifiers
What each code tells Medicare. Medicaid and commercial plans can use them differently.
| Code | Meaning | Medicare use |
|---|---|---|
| POS 10 | Patient in their home | Paid at the non-facility rate since January 1, 2024 |
| POS 02 | Patient somewhere other than home, such as a clinic | Paid at the facility rate |
| Modifier 93 | Real-time audio-only | Required on audio-only telehealth |
| Modifier 95 | Real-time audio and video | Not required on most professional claims; used for hospital-employed therapists, opioid treatment programs, and RHC and FQHC telehealth from October 1, 2026 |
| FQ | Audio-only service by an RHC or FQHC | RHCs and FQHCs can report FQ or 93 |
| GT | Audio-video telehealth | Institutional claims under CAH Method II only |
| G0 | Telehealth for acute stroke | With POS 02, CAH Method II, or Q3014 |
| BB | Service delivered through a virtual platform the practitioner contracts with or pays to use | Required from January 1, 2027; no payment effect |
| BC | Telehealth service furnished incident to a physician’s or practitioner’s service | Required from January 1, 2027; no payment effect |
| Q3014 | Originating site facility fee | 80% of the lesser of the charge or $31.85 in 2026 |
Health centers have their own telehealth rules: FQHC and RHC billing · mental health · physical therapy.
Medicare telehealth through 2027, and what returns in 2028
Dates from CMS’s telehealth FAQ, updated October 8, 2026. Congress can extend them again.
| Rule | Through December 31, 2027 | From January 1, 2028 |
|---|---|---|
| Patient location for medical visits | Anywhere in the US, including home | A medical facility in a rural area, with exceptions for acute stroke, home dialysis assessments, and substance use disorder |
| Behavioral and mental health location | Home allowed, no geographic limit | Same, permanently |
| In-person mental health visit | Not required | Within 6 months before a new patient’s first home telehealth visit, then every 12 months; patients who started before 2028 need one every 12 months |
| Audio-only | Allowed at home when the patient cannot use or does not consent to video | Behavioral health at home only |
| Physical and occupational therapists, speech-language pathologists, audiologists | Can bill telehealth | Cannot bill telehealth |
| RHC and FQHC medical telehealth | Distant site, billed with the CPT or HCPCS code plus 95 or 93 since October 1, 2026 | Ends; mental health visits continue under the PPS and all-inclusive rate |
| Frequency limits on subsequent inpatient and nursing facility visits | Removed | Removed permanently since 2026 |
| Virtual direct supervision | Real-time audio-video, for services without a 010 or 090 global period | Same, permanently since 2026 |
Telehealth visits during the fall 2025 government shutdown, when the flexibilities briefly lapsed, are paid as if there had been no lapse.
Where telehealth claims are denied or underpaid
Most telehealth denials are location and modifier errors, not coverage disputes.
POS that does not match the note
The documented patient location decides POS 10 or 02. A home visit billed with POS 02 is paid at the lower facility rate, and a visit with no documented location is hard to defend in an audit.
Audio-only billed as video
An audio-only visit without modifier 93 is billed as if it were audio-video. Medicare allows audio-only at home only when the patient cannot use or does not consent to video, and the note should say so.
Service not on the telehealth list
A code that is not on the Medicare Telehealth Services List is denied when billed as telehealth. The list changes every January with the physician fee schedule.
License and enrollment
The practitioner must be licensed in the state where the patient is during the visit, and Medicare requires a separate enrollment for each state where the practitioner provides services.
Health center claims still on G2025
For dates of service from October 1, 2026, an RHC or FQHC bills the CPT or HCPCS code with modifier 95 or 93. G2025 is no longer how medical telehealth is billed.
Each payer’s own rules
Commercial plans and Medicaid set their own POS and modifier rules: some want POS 02 or 10, others the in-person POS with modifier 95. Rules are kept per plan, not assumed from Medicare.
Telehealth billing in New York
Vector Medical Billing is based in Queens. New York Medicaid has its own telehealth rules.
Payment parity until April 1, 2028
Under Public Health Law §2999-dd, New York Medicaid pays telehealth on the same basis and at the same rate as in-person care, now through April 1, 2028. Article 28 facilities are an exception for facility costs not incurred when neither the patient nor the practitioner is on site.
POS 02, 10, or 11
New York Medicaid accepts POS 02 and 10, and asks practitioners who would bill POS 11 for an in-person visit to use POS 11 on the telehealth claim, because it often pays more.
Modifiers 95, GT, 93, and FQ
95 or GT for audio-video, 93 or FQ for audio-only, and GQ for store-and-forward. New York Medicaid expects audio-only medical visits to be rare; that limit is aimed at medical visits, not behavioral health.
Clinic off-site rate codes
An Article 28 FQHC that has not opted into APGs bills off-site rate code 4012 instead of PPS rate code 4013 when neither the patient nor the practitioner is on site. New York Medicaid pays $26.02 for the originating site fee, Q3014.
Not inside the monthly fee
The monthly cycle bills claims that are already in the system. These are scoped on their own.
Written rate
The fee is a percentage of net collections (flat or per claim in New York). No setup fee on the monthly cycle. Month to month. The written rate follows volume, payer mix, and how much of the cycle you hand over.
See pricing or request a written rate after the free audit.
Separate work
Credentialing in other states for cross-state telehealth, telehealth platform contracts, and audits of past telehealth claims are scoped on their own.
Check a month of telehealth claims
Send a month of telehealth visits with the documented patient location, the modality, and the payer for each. We report POS and modifier errors, codes not on the payer’s telehealth list, what changes on January 1, 2027, and a written rate.
Telehealth billing questions
Straight answers on Medicare, Medicaid, and commercial telehealth claims.
Is Medicare telehealth extended through 2027?
Yes. The Consolidated Appropriations Act, 2026 extended Medicare’s telehealth flexibilities through December 31, 2027. Patients can be seen at home anywhere in the US, audio-only is allowed when video is not possible, and therapists can bill telehealth. From January 1, 2028, most medical telehealth returns to rural, facility-based originating sites unless Congress extends it again.
What is the difference between POS 02 and POS 10?
POS 10 means the patient was at home during the telehealth visit, and Medicare pays it at the non-facility rate. POS 02 means the patient was somewhere else, such as a clinic or hospital, and Medicare pays it at the facility rate.
Is modifier 95 required for Medicare telehealth?
Not on most professional claims, because POS 02 or 10 identifies telehealth. Modifier 93 is required for audio-only visits. Medicare still uses 95 for therapy by hospital-employed therapists, for opioid treatment programs, and for RHC and FQHC telehealth from October 1, 2026. Many Medicaid and commercial plans also require 95.
What are the BB and BC telehealth modifiers?
Two modifiers Medicare requires on telehealth claims from January 1, 2027. BB marks a service delivered through a virtual platform the practitioner contracts with or pays to use. BC marks a telehealth service furnished incident to a physician’s or practitioner’s service. CMS says neither changes payment.
Do Medicare mental health telehealth patients need an in-person visit?
Not through December 31, 2027. From 2028, a new patient needs an in-person visit within 6 months before the first home telehealth visit and then every 12 months. Patients who started telehealth before 2028 need an in-person visit every 12 months, with limited exceptions.
Does New York Medicaid pay telehealth at the in-person rate?
Yes, under Public Health Law §2999-dd, through April 1, 2028, except for Article 28 facility costs when neither the patient nor the practitioner is on site. New York Medicaid accepts POS 02, 10, or 11, with modifier 95 or GT for audio-video and 93 or FQ for audio-only.
How is the fee set?
As a percentage of net collections (flat or per claim in New York) on the book you hand over. No setup fee on the monthly cycle, month to month, with 30 days’ written notice. The written rate follows volume, payer mix, and scope.