Introduction: Telehealth Billing Is Still a Moving Target
Telehealth utilization stabilized well above pre-pandemic levels, but the billing rules around it have anything but stabilized. Between shifting federal flexibilities, state-specific parity laws, and payer-by-payer policy differences, telehealth billing in 2026 remains one of the more complex and denial-prone areas of medical billing — even for practices that have been offering virtual visits for years.
This guide walks through the current telehealth billing landscape: which codes apply, which modifiers and place-of-service (POS) codes are required, and how payer rules differ — so your practice can reduce telehealth-related denials and get reimbursed accurately.
Why Telehealth Billing Is Still So Complicated
Unlike most areas of coding, where the same code and modifier logic generally applies across payers, telehealth billing has three layers of variability stacked on top of each other:
- Federal Medicare flexibilities that have been extended, modified, or allowed to expire in phases since 2020
- State-level telehealth parity laws, which vary significantly in what they require commercial payers to reimburse and at what rate
- Individual commercial payer policies, which may or may not align with either federal or state rules
This layering means a telehealth claim that’s billed correctly for one payer can be denied outright by another for the exact same service, delivered the exact same way.
Key Telehealth CPT Codes to Know in 2026
While many services previously billed only with specific “telehealth codes” have been folded into standard E/M and specialty CPT codes (billed with a modifier or POS code indicating telehealth delivery), a few categories still warrant special attention:
- Standard E/M codes (99202–99215): Now billable via telehealth for many payers using standard in-person codes, distinguished by modifier and/or POS code rather than a separate code set.
- Audio-only codes: A distinct set of codes and payer policies apply specifically to audio-only (telephone) visits, which are treated differently than audio-video telehealth in many payer policies.
- Remote Physiologic Monitoring (RPM) codes: Codes covering device setup, data transmission, and monthly management continue to see clarification and expansion.
- Remote Therapeutic Monitoring (RTM) codes: A newer code family covering musculoskeletal and respiratory system monitoring, distinct from RPM.
- Behavioral health telehealth codes: Behavioral health has some of the most permanent and broad telehealth flexibilities, with fewer originating-site restrictions than other specialties in many payer policies.
Modifiers: Getting Them Right Matters More Than Ever
Two modifiers dominate telehealth billing, and using the wrong one — or omitting one entirely — is one of the most common causes of telehealth claim denials:
Modifier 95
Indicates a synchronous telemedicine service rendered via real-time audio and video communication. This is the most commonly required modifier for standard telehealth E/M visits across most payers.
Modifier GT
Historically used for telehealth services, particularly in some state Medicaid programs and specific payer contexts, even as modifier 95 has become more standard elsewhere. Some payers still require GT instead of, or in addition to, modifier 95.
Modifier FQ / FR
Used specifically for audio-only behavioral health services under certain Medicare policies, distinguishing them from full audio-video telehealth encounters.
The key takeaway: the “correct” modifier isn’t universal — it depends entirely on the specific payer, and sometimes the specific state Medicaid program. Billing teams need a payer-by-payer modifier reference rather than assuming one modifier works across the board.
Place-of-Service (POS) Codes: The Other Half of the Equation
Alongside modifiers, POS codes are equally critical and equally inconsistent across payers:
- POS 02: Telehealth provided at a location other than the patient’s home
- POS 10: Telehealth provided while the patient is at home
- POS 11 (or the applicable in-person POS code): Some payers, particularly during certain flexibility periods, have allowed providers to bill telehealth using the same POS code as an in-person visit would use, paired with a modifier instead — which can affect reimbursement rates since some payers pay telehealth visits at the same rate as in-person visits when billed this way, while others reimburse differently based on POS code alone.
Getting POS and modifier combinations wrong is one of the single most common telehealth denial triggers, because the two have to align correctly for a given payer’s specific policy — and that policy can change based on state Medicaid guidance or updated commercial payer bulletins.
Payer-Specific Considerations to Watch in 2026
Medicare
Medicare telehealth policy continues to be shaped by periodic Congressional extensions of expanded flexibilities (such as removing originating site restrictions for many services). Practices billing Medicare telehealth claims need to track these extensions closely, since flexibilities have historically been renewed close to — or sometimes after — their expiration dates, creating billing uncertainty in the interim.
Medicaid
Telehealth Medicaid policy varies significantly by state, including which services are covered via telehealth, which modifier/POS combination is required, and whether audio-only visits are reimbursed at parity with audio-video visits. There is no substitute for checking your specific state’s current Medicaid telehealth billing manual.
Commercial Payers
Commercial payer telehealth policies are shaped partly by state telehealth parity laws (which mandate coverage but don’t always mandate payment parity) and partly by each payer’s own internal policy. Some commercial payers reimburse telehealth visits at the same rate as in-person visits; others apply a reduced rate — and this can change year to year as parity laws are updated or sunset.
Common Telehealth Billing Mistakes Practices Are Still Making
- Using the same modifier/POS combination across all payers, rather than maintaining a payer-specific reference sheet
- Failing to distinguish audio-only from audio-video visits in billing, when payer policy treats them differently
- Not verifying current-year Medicare telehealth flexibility status before assuming a service remains billable via telehealth
- Overlooking state-specific Medicaid telehealth rules when treating patients across state lines
- Missing documentation requirements specific to telehealth — many payers require explicit documentation that the encounter was conducted via real-time audio-video communication, separate from standard clinical documentation
Building a Telehealth Billing Process That Holds Up
Given how much variability exists payer-to-payer, the most effective approach for practices offering telehealth is to build (or outsource) a structured process rather than relying on general knowledge that may be outdated or payer-specific to only one plan:
- Maintain a payer-specific telehealth reference sheet covering required modifiers, POS codes, and any service restrictions — updated at least quarterly
- Verify eligibility and telehealth coverage before each visit, not just standard insurance eligibility
- Train front-desk and clinical documentation staff on telehealth-specific documentation requirements, since these often differ from in-person visit notes
- Audit telehealth claims separately from in-person claims during denial reviews, since the denial patterns and root causes tend to differ
Why Many Practices Outsource Telehealth Billing Specifically
Because telehealth billing rules are so payer- and state-dependent, many practices — even ones with capable in-house billing staff — choose to work with an RCM partner that specializes in tracking these shifting rules across multiple payers and states. FAS Medical Summit maintains updated payer-specific telehealth billing guidance as part of its RCM services, helping practices avoid the trial-and-error of learning modifier and POS requirements payer-by-payer through denied claims.
For practices with patients across multiple states, or those billing a mix of Medicare, Medicaid, and commercial payers for telehealth services, this kind of ongoing payer-policy monitoring is often more efficient to outsource than to maintain internally — particularly for smaller practices without a dedicated billing compliance role.
Final Thoughts
Telehealth billing in 2026 is more established than it was a few years ago, but it’s far from simple. The combination of modifier requirements, POS code rules, and payer-specific policies — layered on top of ongoing federal and state regulatory changes — means telehealth claims require more attention to detail than standard in-person billing, not less.
Practices that build (or partner for) a structured, payer-aware telehealth billing process are seeing far fewer denials than those treating telehealth billing as an extension of standard in-person coding. If your practice is seeing telehealth-specific denials climb, it may be time to have your billing process reviewed by a partner like FAS Medical Summit that specializes in staying current on payer-by-payer telehealth policy.
