Telehealth Billing in 2026: Codes, Modifiers, and Payer Rules

Telehealth use has settled well above pre-pandemic levels, but the billing rules have not settled at all. Between changing federal flexibilities, state parity laws, and differences from one payer to the next, telehealth billing in 2026 is still one of the most complex and denial-prone areas of medical billing, even for practices that have offered virtual visits for years.

When telehealth claims keep coming back, the cause is almost always one of three things: the wrong modifier, the wrong place-of-service (POS) code, or a payer rule that changed. This guide covers all three for Medicare, Medicaid, and commercial payers.

Why Telehealth Billing Is So Complicated

In most areas of coding, the same code and modifier logic applies across payers. Telehealth billing has three layers of rules on top of each other:

1. Federal Medicare flexibilities that have been extended, changed, or allowed to expire in phases since 2020
2. State telehealth parity laws, which differ widely in what commercial payers must cover and at what rate
3. Individual commercial payer policies, which may or may not follow federal or state rules

Because of this, a telehealth claim billed correctly for one payer can be denied by another for the same service, delivered the same way.

Telehealth CPT Codes to Know in 2026

Many services that once had separate telehealth codes are now billed with standard E/M and specialty CPT codes, plus a modifier or POS code showing the visit was virtual. Because these rules shift with each annual CPT update, a few code categories need extra attention:

• Standard E/M codes (99202 to 99215): Many payers allow these for telehealth visits, identified by modifier and/or POS code rather than a separate code set.
• Audio-only codes: Telephone visits follow their own codes and payer policies, and many payers treat them differently from audio-video visits.
• Remote Physiologic Monitoring (RPM) codes: These cover device setup, data transmission, and monthly management, and they continue to be clarified and expanded.
• Remote Therapeutic Monitoring (RTM) codes: A newer code family, separate from RPM, covering musculoskeletal and respiratory monitoring.
• Behavioral health telehealth codes: Behavioral health has some of the broadest permanent telehealth flexibilities, with fewer originating-site restrictions than most specialties.

Telehealth Modifiers: 95, GT, 93, FQ, and FR

Using the wrong modifier, or leaving one off, is one of the most common causes of telehealth claim denials.

Modifier 95

Indicates a synchronous telemedicine service delivered through real-time audio and video. It is the modifier most payers require for standard telehealth E/M visits.

Modifier GT

An older telehealth modifier that some state Medicaid programs and certain payers still require, either instead of modifier 95 or in addition to it.

Modifiers 93, FQ, and FR

Modifier 93 and modifier FQ both identify services delivered using audio-only communication, and payers differ on which one they accept. Modifier FR indicates that a supervising practitioner was present through real-time audio-video communication.

So there is no single correct modifier. It depends on the payer, and sometimes on the state Medicaid program, which is why billing teams need a payer-by-payer modifier reference rather than one rule for everyone.

Telehealth Place-of-Service (POS) Codes

POS codes matter as much as modifiers and are just as inconsistent across payers:

• POS 02: Telehealth provided while the patient is somewhere other than home
• POS 10: Telehealth provided while the patient is at home
• POS 11 (or the usual in-person POS): Some payers have allowed telehealth to be billed with the same POS as an in-person visit, paired with a modifier. This can change the payment rate, because some payers pay telehealth at the in-person rate when billed this way and others pay based on POS alone.

A mismatched POS and modifier combination is one of the most frequent telehealth denial triggers. The two must match each payer’s current policy, and that policy can change with new state Medicaid guidance or commercial payer bulletins.

Telehealth Payer Rules for 2026

Medicare

Medicare telehealth policy still depends on periodic Congressional extensions of expanded flexibilities, such as the removal of originating-site restrictions for many services. These extensions have often been renewed close to, or even after, their expiration dates, so practices billing Medicare telehealth claims need to track them closely.

Medicaid

Medicaid telehealth policy varies by state, including which services are covered, which modifier and POS combination is required, and whether audio-only visits are paid at the same rate as audio-video visits. Always check your state’s current Medicaid telehealth billing manual.

Commercial Payers

Commercial payer policies are shaped partly by state parity laws, which require coverage but do not always require payment parity, and partly by each payer’s internal rules. Some pay telehealth at the in-person rate, others pay less, and this can change from year to year as parity laws are updated or expire.

5 Common Telehealth Billing Mistakes

1. Using one modifier and POS combination for every payer instead of keeping a payer-specific reference sheet
2. Not separating audio-only from audio-video visits when payers treat them differently
3. Not checking this year’s Medicare flexibility status before assuming a service is still billable as telehealth
4. Overlooking state Medicaid rules when treating patients across state lines
5. Missing telehealth documentation requirements: many payers require the note to state explicitly that the visit used real-time audio-video communication

How to Build a Reliable Telehealth Billing Process

With this much variation between payers, practices need a structured process rather than general knowledge that may be out of date or apply to only one plan:

1. Keep a payer-specific telehealth reference sheet listing required modifiers, POS codes, and service restrictions, and update it at least quarterly
2. Verify telehealth coverage before each visit, in addition to standard insurance eligibility
3. Train front desk and clinical staff on telehealth documentation requirements, which often differ from in-person notes
4. Review telehealth denials separately from in-person denials, since the patterns and root causes tend to differ

Why Practices Outsource Telehealth Billing

Because telehealth rules depend so heavily on payer and state, many practices, including those with capable in-house billers, work with an RCM partner that tracks these changes across payers and states. As part of our revenue cycle management services, FAS Medical Summit keeps payer-specific telehealth billing guidance up to date, so practices do not have to learn modifier and POS rules through denied claims.

For practices with patients in several states, or those billing a mix of Medicare, Medicaid, and commercial payers, outsourcing this monitoring is often more efficient than handling it in-house, especially without a dedicated billing compliance role.

Before You Submit Your Next Telehealth Claim

Telehealth billing in 2026 is more established than it was a few years ago, but it is not simple. Modifier requirements, POS rules, and payer-specific policies, combined with ongoing federal and state changes, mean telehealth claims need more attention than in-person claims, not less.

Practices with a structured, payer-aware process see fewer denials than those treating telehealth as an extension of in-person coding. If your telehealth denials are rising, ask FAS Medical Summit to review your telehealth billing process.