Telehealth Billing Has Moved Past Its Emergency-Era Rules
Telehealth billing rules expanded quickly and somewhat improvisationally in response to the public health emergency, and while the framework has since settled into something more permanent, it never became fully uniform. Medicare, Medicaid, and commercial payers still diverge on which services qualify, which modifiers apply, and how audio-only visits are treated, which means a billing process built entirely around old, pandemic-era assumptions is likely generating avoidable denials today.
The Codes and Modifiers That Matter Most
Most telehealth visits are billed using standard evaluation and management CPT codes, with the telehealth delivery method indicated through a combination of place-of-service code and modifier rather than a separate code set. Place-of-service 02 generally applies to telehealth provided when the patient is not at home, while POS 10 applies when the patient is at home; commercial payers frequently expect modifier 95 to indicate a synchronous audio-video visit. Audio-only visits are billed differently still, using specific codes and modifiers payers have designated for that lower level of interaction, and mixing these up is one of the most common sources of telehealth denials.
Why Payer-by-Payer Variation Still Matters
Even with a more settled federal framework, Medicare Advantage plans, commercial payers, and state Medicaid programs each maintain their own telehealth coverage policies, including which specialties can bill telehealth at all, whether audio-only counts as a covered service, and what modifier they expect to see. A claim built around Medicare’s rules and submitted unchanged to a commercial payer is a common way telehealth denials happen, particularly for practices that added telehealth quickly and never revisited the billing process payer by payer.
Common Mistakes That Are Easy to Fix
The most frequent telehealth billing errors are also some of the simplest to prevent once identified: using the wrong place-of-service code for where the patient was actually located, omitting the payer-specific modifier, billing an audio-only encounter as a full audio-video telehealth visit, and not verifying that the rendering provider was licensed in the state where the patient was physically located at the time of the visit, which can affect both compliance and reimbursement.
Documentation Still Has to Support the Visit Type
Telehealth documentation needs to explicitly state the modality used (audio-video versus audio-only), the patient’s location, and, where relevant, patient consent to receive care via telehealth. A note that reads identically to an in-office visit, with no reference to how the visit was actually conducted, gives a payer reviewing the claim a reason to question whether it was billed correctly.
Why This Needs Ongoing Attention, Not a One-Time Setup
Because telehealth policy continues to be revisited by CMS and individual payers on a rolling basis, a billing process that was correct last year isn’t guaranteed to still be correct today. Practices that treat telehealth billing as something that was “set up once” during the pandemic are the ones most likely to be carrying outdated rules into current claims. A billing partner that tracks these updates across payers takes this monitoring off a practice’s plate entirely.
A Practical Starting Point
If your practice offers telehealth across several payers, a useful first step is a simple audit: pull the last 90 days of telehealth claims and check each one for the correct place-of-service code, the correct modifier for the payer it was billed to, and whether audio-only visits were coded distinctly from audio-video visits. Patterns that show up in that review, the same error repeating across many claims, point directly at the specific rule that needs to be corrected in the billing workflow going forward.
Quick Reference Checklist
- Confirm POS 02 vs. POS 10 matches where the patient was actually located during the visit.
- Append modifier 95, or the payer-specific equivalent, for synchronous audio-video visits.
- Bill audio-only encounters using their designated codes and modifiers, not as full telehealth.
- Verify the rendering provider was licensed in the state where the patient was physically located.
- Document modality, patient location, and consent to telehealth in every visit note.