Telehealth Billing Guide: Place of Service 02 and 10, Modifiers 95 and 93, and the Codes Payers Accept

The building blocks

Place of service

• POS 10 — telehealth provided in the patient’s home. Medicare pays services at POS 10 at the non-facility rate, the same as an office visit.
• POS 02 — telehealth provided other than in the patient’s home (the patient is at a clinic, facility or other site). Medicare pays at the facility rate.
• Some commercial payers still want the originating office POS (11) with modifier 95 instead of POS 02/10. This is the most common source of telehealth denials: check each payer’s telehealth policy and store it.

Modifiers

• 95 — synchronous real-time audio and video.
• 93 — synchronous audio-only (telephone). Used where the payer covers audio-only for that service.
• GT — the older telehealth modifier, retired by Medicare but still required by a few payers and some Medicaid programs.
• FQ / FR — Medicare modifiers for audio-only behavioral health and for a required in-person component, in specific circumstances.

Which codes

For office or outpatient E/M visits, most payers have you bill the standard codes (99202–99215) with the telehealth POS and modifier. CPT introduced a dedicated telemedicine code family (98000–98015, covering audio-video and audio-only visits by medical decision-making or time, plus 98016 for a brief virtual check-in) effective 2025; Medicare does not pay most of those codes and continues to use the standard E/M codes with POS and modifiers, while some commercial payers have adopted them. Behavioral health codes (90791, 90832–90838, 90846, 90847, 90853) are widely covered via telehealth with modifier 95 and, for many payers, audio-only with 93.

Communication-technology services are separate from telehealth: virtual check-ins (G2012 for Medicare, 98016 under CPT), remote evaluation of recorded video or images (G2010), online digital E/M (99421–99423) and remote patient monitoring (99453–99458). They have their own frequency and time rules and are not billed with modifier 95.

Medicare specifics

During the public health emergency, Medicare waived its geographic and originating-site restrictions and allowed telehealth from the patient’s home for all services. Those flexibilities have since been extended by Congress in short increments rather than made permanent, and the rules for non-behavioral telehealth from the home have lapsed and been reinstated more than once. Behavioral and mental health telehealth from the home is permanent, with a periodic in-person requirement that has itself been delayed. Before billing a Medicare telehealth service, confirm three things against the current CMS telehealth list and the latest extension: that the code is on the list, that the patient’s location is allowed for that code, and whether audio-only is permitted.

Commercial and Medicaid

Commercial payers each publish a telehealth policy covering POS, modifiers, which codes are covered, whether audio-only is paid and at what rate, and whether out-of-state providers can bill. State Medicaid programs do the same, and several states have payment-parity laws requiring telehealth to be paid at the in-person rate. The rule that works for Aetna in New York may not work for the same patient’s employer plan administered in another state. Keep a payer-by-payer grid and update it when policies change.

Documentation

• Patient consent to telehealth, obtained and documented (annually for many payers and Medicare).
• The modality (audio-video or audio-only) and why audio-only was used if the visit was planned as video.
• The patient’s location and the provider’s location.
• Total time, when billing by time, and the start and stop or total minutes for time-based codes.
• The same clinical content as an in-person note: history, exam elements that can be performed remotely, assessment and plan.

Licensure and location

The provider generally must be licensed in the state where the patient is located at the time of the visit. Interstate compacts and some state waivers ease this for certain professions; payers may require the provider’s enrollment in that state as well. For practices with snowbird patients or college students, this is a routine check at scheduling.

Common telehealth denials

• POS and modifier combination the payer does not accept (for example POS 10 with no modifier 95, or POS 11 where the payer wants 02).
• Audio-only billed with 95 instead of 93.
• Service not on the payer’s covered telehealth list.
• Patient located out of state with a provider not licensed there.
• Missing consent documentation on audit.

Telehealth-first practices are a growing part of Core MB’s billing work; see telemedicine billing and the broader medical billing service.