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✓ Policies verified: April 17, 2026 · 67 payers including all 50 states + DC Medicaid · Always verify with your specific payer contract before submitting claims.
Telehealth Billing Codes 2026: Complete Guide to Modifiers, POS Codes & CPT Codes
Professional disclaimer: Telehealth billing policies change frequently. The information in this guide reflects CMS guidance, payer policies, and CPT code updates as of April 2026. Always verify modifier requirements, Place of Service codes, and covered service lists directly with your specific payer contract and the current CMS Physician Fee Schedule before submitting claims. This guide does not constitute legal or billing compliance advice. For complex billing situations, consult a certified professional coder (CPC) or healthcare billing attorney.
Telehealth billing is one of the fastest-moving areas in medical revenue cycle management. Since the COVID-19 public health emergency (PHE) ended in May 2023, providers have had to navigate a patchwork of temporary extensions, permanent policy changes, and payer-specific rules that vary wildly — sometimes even within the same insurance company across different states.
This guide cuts through the confusion. Whether you are billing Medicare, a state Medicaid program, or a commercial payer, you will find the exact modifier, Place of Service code, and CPT code you need — plus the documentation requirements to protect against denials.
Use the free Telehealth Billing Code Checker above to get instant, payer-specific answers for your specific situation. The guide below explains the reasoning behind every result the tool produces.
What is telehealth billing and why does it matter in 2026?
Telehealth billing refers to the process of submitting insurance claims for medical services delivered remotely — via video, telephone, or secure patient portal — rather than in person. The claim process itself is largely the same as in-person billing, but requires specific modifiers, Place of Service codes, and sometimes entirely different CPT codes depending on the payer and service type.
In 2026, telehealth billing matters more than ever for three reasons:
- Medicare coverage is extended, not permanent. Congress extended telehealth flexibilities through December 31, 2027 via the Consolidated Appropriations Act (CAA). Without another extension, many flexibilities revert after that date. Providers billing telehealth need to track these deadlines.
- Payer policies have diverged significantly post-PHE. What Medicare covers does not automatically apply to commercial payers or state Medicaid programs. Each payer has developed its own telehealth policy, creating a complex, fragmented billing landscape.
- Telehealth claim denials are rising. According to industry data, telehealth claims are denied at a significantly higher rate than in-person claims — primarily due to incorrect modifiers, wrong POS codes, missing documentation, and services not on a payer’s covered telehealth code list.
Telehealth modifiers explained: 95, 93, and GT
Modifiers are two-digit codes appended to CPT codes on a claim to provide additional context about how or where a service was delivered. For telehealth, three modifiers are in active use in 2026:
| Modifier | Meaning | When to use | Payers |
|---|---|---|---|
| 95 | Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications | Audio + video telehealth visits | Medicare, most commercial, CMS-aligned Medicaid states |
| 93 | Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications | Audio-only (telephone) telehealth visits when patient lacks video or declines | Medicare, most commercial, 95-states Medicaid |
| GT | Via interactive audio and video telecommunication systems (legacy CMS modifier) | All telehealth (audio or video) — for payers still requiring this modifier | 19+ state Medicaid programs, some legacy payer contracts |
Modifier 95: the standard audio-video telehealth modifier
Modifier 95 is the primary telehealth modifier recognized by CMS, the AMA, and the majority of commercial payers. It tells the payer that the billed service was delivered via a real-time, two-way audio-video connection — such as Zoom for Healthcare, Doxy.me, or an EHR-integrated telehealth platform like Epic MyChart. Modifier 95 should never be used for telephone-only visits.
Modifier 93: audio-only telehealth
Modifier 93 was introduced by the AMA in 2022 to create a distinct billing pathway for telephone-only services. Under Medicare, modifier 93 is covered only when the patient lacks video capability or explicitly declines video — and you must document the specific reason. It cannot be used as a routine alternative to modifier 95 simply because it is more convenient. Under UHC, modifier 93 is only permitted on CPT codes specifically listed in CPT Appendix T.
Modifier GT: the legacy modifier
Modifier GT predates the 95/93 system and is still required by approximately 19 state Medicaid programs as of 2026. Using modifier 95 on a claim for a state that requires GT will result in an automatic denial. States including Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, Missouri, Montana, North Dakota, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, West Virginia, and Wyoming still require modifier GT. Use the payer search tool above to identify which modifier your specific state Medicaid program requires.
Place of Service codes for telehealth: POS 02 vs. POS 10
Place of Service (POS) codes tell the payer where the patient was physically located when they received the service. For telehealth, two POS codes are relevant:
| POS Code | Name | When to use | Medicare requirement |
|---|---|---|---|
| POS 02 | Telehealth Provided Other than in Patient’s Home | Patient is at a clinic, hospital, or any location other than their home | Required when patient is NOT at home |
| POS 10 | Telehealth Provided in Patient’s Home | Patient is receiving telehealth from their own home | Required when patient IS at home (since Jan 2022) |
CMS introduced POS 10 in January 2022 specifically to reflect the shift toward patients receiving telehealth from home. The distinction matters because Medicare pays differently for home vs. non-home telehealth in some situations. Most commercial payers have adopted the same POS 02/10 framework, though Aetna commercial is a notable exception — Aetna does not restrict POS codes for telehealth claims and accepts any POS code.
CPT codes for telehealth visits in 2026
The CPT codes used for telehealth depend on the type of service. The table below covers the most commonly billed telehealth codes in 2026:
| Service type | CPT / HCPCS codes | Description | Modifier needed |
|---|---|---|---|
| E/M Office Visit (new patient) | 99202–99205 | Office or outpatient E/M, new patient, level 1–5 | 95 or 93 or GT |
| E/M Office Visit (established patient) | 99211–99215 | Office or outpatient E/M, established patient, level 1–5 | 95 or 93 or GT |
| Mental health (initial) | 90791 | Psychiatric diagnostic evaluation | 95 or 93 or GT |
| Mental health (psychotherapy) | 90834, 90837, 90847 | Individual / family psychotherapy | 95 or 93 or GT |
| E-visit (patient portal) | 99421, 99422, 99423 | Online patient portal visit (5–10 / 11–20 / 21+ min) | None |
| Virtual check-in | 98016 | Brief patient-initiated virtual check-in (5–10 min). Replaced G2012 on Jan 1, 2025 | None |
| RPM — setup | 99453, 99454 | Initial setup and patient education; device supply per 30 days | None |
| RPM — management | 99457, 99458 | Remote physiologic monitoring treatment management (first / additional 20 min) | None |
| AMA telehealth codes (commercial) | 98000–98015 | New AMA audio-video telehealth E/M codes, adopted by Aetna and Cigna for commercial plans | Varies by payer |
Medicare telehealth coverage in 2026
Medicare remains the most important payer to understand for telehealth billing. The Consolidated Appropriations Act (CAA) extended Medicare telehealth flexibilities through December 31, 2027. Key Medicare telehealth coverage facts for 2026:
- Audio-video E/M visits (99202–99215 with modifier 95) are fully covered from the patient’s home (POS 10) or other locations (POS 02).
- Audio-only E/M visits (99202–99215 with modifier 93) are covered only when the patient lacks video capability or explicitly declines video. The specific reason must be documented in the medical record.
- Mental health telehealth is covered, but Medicare requires a documented in-person visit within 6 months of initiating mental health telehealth services, and annually thereafter. Missing this documentation is the number-one cause of mental health telehealth claim denials under Medicare.
- Virtual check-ins (98016) are covered for established patients only. The check-in must be patient-initiated and must not relate to a visit within 7 days or lead to a visit within 24 hours.
- E-visits (99421–99423) are covered for established patients communicating via a secure HIPAA-compliant portal.
- Railroad Medicare (administered by Palmetto GBA) mirrors Medicare Part B telehealth rules exactly.
Struggling with Medicare telehealth denials?
Use our Denial Code Lookup tool to decode any denial reason instantly.
State Medicaid telehealth: how policies differ
No two state Medicaid programs handle telehealth identically. The differences fall into three main categories:
1. Modifier requirement: GT vs. 95
Approximately half of state Medicaid programs have aligned with CMS and now require modifier 95 for audio-video telehealth. The other half still require the legacy modifier GT. A small number accept both. The tool above automatically identifies which modifier your state requires.
2. Audio-only coverage
This is where state Medicaid policies diverge most dramatically. Some states — including California (Medi-Cal), Washington (Apple Health), New York, Illinois, Massachusetts, and Oregon — have permanently and broadly authorized audio-only telehealth for all covered services under state law. Others, like Texas (SB 670), Mississippi, South Dakota, and Wyoming, do not broadly cover audio-only E/M and restrict telephone visits primarily or entirely to mental health services.
3. Prior authorization for telehealth
Some state Medicaid programs require prior authorization for specific telehealth service types — particularly remote patient monitoring (RPM). Always verify PA requirements for your state before initiating an RPM program.
| State | Modifier | Audio-only E/M | Audio-only Mental Health |
|---|---|---|---|
| California (Medi-Cal) | 95 | Covered | Covered |
| New York Medicaid | GT or 95 | Covered | Covered |
| Washington (Apple Health) | 95 | Covered | Covered |
| Florida Medicaid | GT | Limited | Covered |
| Texas Medicaid | GT | Not covered | Covered |
| Mississippi Medicaid | GT | Not covered | Limited |
| Illinois Medicaid | 95 | Covered | Covered |
| Georgia Medicaid | GT | Limited | Limited |
For the complete list of all 50 states + DC, use the payer search in the billing code checker above and select your specific state Medicaid program.
Commercial payer telehealth policies
Commercial payers have diverged significantly from Medicare in their telehealth policies since the PHE ended. Here are the key distinctions for the major national payers:
UnitedHealthcare (UHC)
UHC follows Medicare telehealth policy for most plans. However, for audio-only visits, UHC does not allow modifier 93 on standard 992XX E/M codes. Instead, you must use telephone E/M codes 99441–99443 for audio-only visits where covered. UHC only allows modifier 93 on codes specifically listed in CPT Appendix T.
Aetna (Commercial)
Aetna commercial does not cover audio-only E/M visits at all — claims submitted with modifier 93 for audio-only E/M will be denied. Aetna is notably adopting the new AMA 98000-series telehealth codes for commercial plans and does not restrict POS codes, accepting any POS on telehealth claims.
Cigna
Cigna restricts audio-only reimbursement to behavioral health and specific chronic disease management scenarios. Billed CPT codes must appear on Cigna’s eligible virtual care code list. Cigna does broadly cover audio-only behavioral health telehealth with modifier 93 — one of the few categories where it allows audio-only broadly.
BCBS and Anthem
Both Anthem BCBS and local BCBS plans generally follow Medicare telehealth policy with modifier 95 for audio-video. Audio-only mental health is broadly covered, but general E/M audio-only varies significantly by state plan. Horizon BCBS (NJ) explicitly covers audio-only with modifier 93.
Check Prior Auth requirements by payer
Our PA Check tool covers 500+ CPT codes across 30+ payers.
Audio-only telehealth billing: what you need to know
Audio-only telehealth (telephone visits) is the most contentious area of telehealth billing in 2026. The fundamental rules are:
- Under Medicare: Audio-only is covered with modifier 93, but only when the patient lacks video capability or explicitly declines video. You must document the specific reason in the chart — a blanket statement like “patient prefers phone” is insufficient and will not survive an audit.
- Under most commercial payers: Audio-only E/M coverage is limited or unavailable for general medical visits. It is more broadly available for mental and behavioral health services.
- Under state Medicaid: Coverage ranges from comprehensive (California, Washington, New York) to completely unavailable for E/M (Texas, Mississippi, Wyoming). Verify before billing.
When audio-only is not covered for E/M, consider whether the patient qualifies for a virtual check-in (98016) instead — which is covered audio-only under Medicare and most major payers.
Documentation requirements for telehealth claims
Telehealth claims fail audits and post-payment reviews when documentation is incomplete. The following elements must be in the medical record for every telehealth claim:
- Patient verbal consent for telehealth, documented in the chart (most payers require this for every visit, not just the first)
- Provider’s physical location — city and state — at the time of service
- Patient’s physical location — city and state — at the time of service (this determines the correct POS code)
- Technology used — confirm the platform is HIPAA-compliant (e.g., Zoom for Healthcare, Doxy.me, Teladoc, Epic MyChart) and that it was two-way, real-time audio-video for modifier 95 visits
- For modifier 93 visits: the specific documented reason video was not used
- Clinical documentation supporting medical necessity and the level of service billed — this is the same standard as in-person visits
- For Medicare mental health telehealth: the date of the most recent in-person visit (required within 6 months of initiation and annually)
Common telehealth claim denials and how to prevent them
| Denial reason | Root cause | Prevention |
|---|---|---|
| Wrong modifier | Using 95 instead of GT for a state Medicaid program that requires GT, or vice versa | Verify modifier per payer before billing; use the tool above |
| Wrong POS code | Using POS 02 when patient was at home (should be POS 10) or missing POS entirely | Document patient location at every visit and map POS accordingly |
| Code not on telehealth list | Billed CPT code is not on the payer’s eligible telehealth code list (common with Cigna, UHC) | Verify each billed code against payer’s telehealth code list each plan year |
| Audio-only not covered | Submitted modifier 93 for a payer or state that does not cover audio-only E/M | Check audio-only coverage before scheduling; consider virtual check-in (98016) as alternative |
| Missing in-person visit (mental health) | Medicare mental health telehealth billed without documented in-person visit within prior 6 months | Track in-person visit dates in your telehealth eligibility workflow; document in every chart |
| G2012 used instead of 98016 | Virtual check-in billed with outdated HCPCS code G2012 (retired January 1, 2025) | Update billing system to 98016 immediately; G2012 claims are being automatically denied |
| New patient e-visit | E-visit (99421–99423) billed for a new patient (not allowed) | E-visits and virtual check-ins are for established patients only; restrict access accordingly |
For a comprehensive denial resolution guide, visit our Denial Code Lookup tool, which covers all CARC codes with specific resolution steps. You can also use our Revenue Leakage Calculator to estimate how much telehealth billing errors are costing your practice each month.
Frequently asked questions
- CMS.gov — Medicare Telehealth Services
- CMS Telehealth FAQs — 2025–2026
- AMA CPT Appendix T — Audio-Only Telehealth Codes
- Consolidated Appropriations Act (CAA) — Telehealth Extension Through 2027
- Health Affairs — Telehealth Policy After the COVID-19 PHE
- CureAdvantage — Denial Code Lookup Tool
- CureAdvantage — Revenue Leakage Calculator
- CureAdvantage — CPT Coding Assistant
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Telehealth Billing Codes 2026: Complete Guide to Modifiers, POS Codes & CPT Codes
Professional disclaimer: Telehealth billing policies change frequently. The information in this guide reflects CMS guidance, payer policies, and CPT code updates as of April 2026. Always verify modifier requirements, Place of Service codes, and covered service lists directly with your specific payer contract and the current CMS Physician Fee Schedule before submitting claims. This guide does not constitute legal or billing compliance advice. For complex situations, consult a certified professional coder (CPC) or healthcare attorney.
Telehealth billing is one of the most complex and fast-moving areas in medical revenue cycle management. Since the COVID-19 public health emergency ended in May 2023, providers have navigated a patchwork of temporary extensions, permanent state law changes, and diverging payer-specific rules that vary significantly — sometimes even within the same insurance company across different states.
This guide cuts through the confusion. Whether you are billing Medicare, a specific state Medicaid program, or a commercial payer like Aetna, Cigna, or UHC, you will find the exact modifier, Place of Service code, and CPT code you need for 2026 — plus documentation requirements to protect against post-payment audits and denials.
Use the free Telehealth Billing Code Checker above to get instant, payer-specific answers. The guide below explains the reasoning behind every result the tool produces.
What is telehealth billing and why does it matter in 2026?
Telehealth billing is the process of submitting insurance claims for medical services delivered remotely — via video, telephone, or secure patient portal — rather than in person. The claim process follows the same general workflow as in-person billing but requires specific modifiers, Place of Service codes, and sometimes entirely different CPT codes depending on the payer and service type.
In 2026, telehealth billing matters more than ever for three reasons:
- Medicare coverage is extended, not permanent. Congress extended telehealth flexibilities through December 31, 2027 via the Consolidated Appropriations Act (CAA). Providers billing telehealth need to track these deadlines and watch for further Congressional action.
- Payer policies have diverged significantly post-PHE. What Medicare covers does not automatically apply to commercial payers or state Medicaid programs. Each payer has developed its own telehealth policy, creating a fragmented billing landscape with real denial risk.
- Telehealth claim denials are rising. Industry data shows telehealth claims are denied at a significantly higher rate than in-person claims — primarily due to incorrect modifiers, wrong POS codes, missing documentation, and services not on a payer’s covered telehealth code list.
Telehealth modifiers explained: 95, 93, and GT
Modifiers are two-digit codes appended to CPT codes on a claim to provide additional context about how a service was delivered. For telehealth, three modifiers are in active use in 2026:
| Modifier | Meaning | When to use | Who requires it |
|---|---|---|---|
| 95 | Synchronous telemedicine via real-time interactive audio and video | Audio + video telehealth visits | Medicare, most commercial payers, CMS-aligned Medicaid states |
| 93 | Synchronous telemedicine via telephone or audio-only real-time communications | Audio-only (telephone) visits when patient lacks video or declines | Medicare, most commercial payers (where audio-only is covered) |
| GT | Via interactive audio and video telecommunications systems (legacy CMS modifier) | All telehealth (audio or video) for payers still requiring this modifier | 19+ state Medicaid programs |
Modifier 95: the standard audio-video telehealth modifier
Modifier 95 is the primary telehealth modifier recognized by CMS, the AMA, and the majority of commercial payers. It tells the payer that the billed service was delivered via a real-time, two-way audio-video connection — such as Zoom for Healthcare, Doxy.me, or an EHR-integrated telehealth platform. Modifier 95 should never be used for telephone-only visits.
Modifier 93: audio-only telehealth
Modifier 93 was introduced by the AMA in 2022 to create a distinct billing pathway for telephone-only services. Under Medicare, modifier 93 is covered only when the patient lacks video capability or explicitly declines video — and you must document the specific reason in the medical record. It cannot be used as a routine alternative to modifier 95 simply because it is more convenient. Under UHC, modifier 93 is only permitted on CPT codes specifically listed in CPT Appendix T.
Modifier GT: the legacy Medicaid modifier
Modifier GT predates the 95/93 system and is still required by approximately 19 state Medicaid programs as of 2026. Using modifier 95 on a claim for a state that requires GT will result in an automatic denial. States including Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, Missouri, Montana, North Dakota, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, West Virginia, and Wyoming still require modifier GT. Use the payer checker above to identify which modifier your specific state requires.
Place of Service codes for telehealth: POS 02 vs. POS 10
Place of Service (POS) codes tell the payer where the patient was physically located when the service was received. For telehealth, two POS codes are relevant in 2026:
| POS Code | Name | Use when | Medicare rule |
|---|---|---|---|
| POS 02 | Telehealth Provided Other than in Patient’s Home | Patient is at a clinic, hospital, or any non-home location | Required when patient is NOT at home |
| POS 10 | Telehealth Provided in Patient’s Home | Patient receives telehealth from their own home | Required when patient IS at home (since Jan 2022) |
CMS introduced POS 10 in January 2022 to distinguish home-based telehealth from facility-based telehealth. Most commercial payers have adopted the same POS 02/10 framework. Aetna commercial is a notable exception — it does not restrict POS codes and accepts any POS on telehealth claims.
CPT codes for telehealth visits in 2026
The CPT codes used for telehealth depend on the type of service being delivered. The table below covers the most commonly billed telehealth codes in 2026:
| Service type | CPT / HCPCS | Description | Modifier needed |
|---|---|---|---|
| E/M — new patient | 99202–99205 | Office or outpatient E/M, new patient, level 1–4 | 95, 93, or GT |
| E/M — established patient | 99211–99215 | Office or outpatient E/M, established patient, level 1–5 | 95, 93, or GT |
| Mental health — initial | 90791 | Psychiatric diagnostic evaluation | 95, 93, or GT |
| Mental health — therapy | 90834, 90837, 90847 | Individual and family psychotherapy | 95, 93, or GT |
| E-visit (patient portal) | 99421, 99422, 99423 | Online patient portal visit: 5–10 min / 11–20 min / 21+ min provider time | None required |
| Virtual check-in | 98016 | Brief patient-initiated check-in 5–10 min. Replaced G2012 on Jan 1, 2025 | None required |
| RPM — setup | 99453, 99454 | Initial patient setup and education; device supply per 30-day period | None required |
| RPM — management | 99457, 99458 | Remote monitoring treatment management: first 20 min / additional 20 min | None required |
| AMA telehealth codes (commercial) | 98000–98015 | New AMA audio-video telehealth-specific E/M codes, adopted by Aetna and Cigna for commercial plans | Varies by payer |
Medicare telehealth coverage in 2026
Medicare remains the most important payer to understand for telehealth billing. The Consolidated Appropriations Act (CAA) extended Medicare telehealth flexibilities through December 31, 2027. Key facts for 2026:
- Audio-video E/M visits (99202–99215 with modifier 95) are fully covered from the patient’s home (POS 10) and other locations (POS 02).
- Audio-only E/M visits (99202–99215 with modifier 93) are covered only when the patient lacks video capability or explicitly declines video. The specific reason must be documented in the medical record.
- Mental health telehealth is covered but requires a documented in-person visit within 6 months of initiating mental health telehealth services, and annually thereafter. Missing this documentation is the leading cause of mental health telehealth claim denials under Medicare.
- Virtual check-ins (98016) are covered for established patients only, must be patient-initiated, and cannot relate to a visit within the prior 7 days or lead to a visit within the next 24 hours.
- E-visits (99421–99423) are covered for established patients communicating via a HIPAA-compliant patient portal.
- Railroad Medicare, administered by Palmetto GBA, mirrors Medicare Part B telehealth rules exactly.
Dealing with Medicare telehealth denials?
Our Denial Code Lookup decodes every CARC reason code with specific resolution steps.
State Medicaid telehealth: how policies differ across all 50 states
No two state Medicaid programs handle telehealth identically. The differences fall into three main categories: the modifier required, the scope of audio-only coverage, and prior authorization requirements for specific service types.
Modifier requirement: GT vs. 95
Approximately half of state Medicaid programs have aligned with CMS and now require modifier 95 for audio-video telehealth. The other half still require the legacy modifier GT. A small number of states — including Arizona (AHCCCS), Iowa, New Mexico, New York, Ohio, and Wisconsin — accept both. The Billing Code Checker above identifies the correct modifier for each state automatically.
Audio-only coverage varies dramatically by state
This is where state Medicaid policies diverge most significantly. Some states have permanently and broadly authorized audio-only telehealth for all covered services under state law. Others restrict telephone visits to mental health only, or exclude them altogether. Here is a summary of key states:
| State | Program name | Modifier | Audio-only E/M | Audio-only Mental Health |
|---|---|---|---|---|
| California | Medi-Cal | 95 | Covered | Covered |
| New York | NY Medicaid | GT or 95 | Covered | Covered |
| Washington | Apple Health | 95 | Covered | Covered |
| Illinois | IL Medicaid | 95 | Covered | Covered |
| Massachusetts | MassHealth | 95 | Covered | Covered |
| Florida | FL Medicaid | GT | Limited | Covered |
| Texas | TX Medicaid | GT | Not covered | Covered |
| Georgia | GA Medicaid | GT | Limited | Limited |
| Mississippi | MS Medicaid | GT | Not covered | Limited |
| Wyoming | WY Medicaid | GT | Not covered | Limited |
For the complete list of all 50 states + DC with full service-level detail, use the payer search in the tool above and select your specific state Medicaid program.
Commercial payer telehealth policies
Commercial payers have diverged significantly from Medicare in their telehealth policies. Here are the critical distinctions for the major national payers:
UnitedHealthcare (UHC)
UHC follows Medicare telehealth policy for most plans. For audio-only visits, however, UHC does not allow modifier 93 on standard 992XX E/M codes. You must instead use telephone E/M codes 99441–99443 for audio-only visits where covered. Modifier 93 is only permitted on codes listed in CPT Appendix T.
Aetna (Commercial)
Aetna commercial does not cover audio-only E/M visits at all — claims with modifier 93 for audio-only E/M will be denied. Aetna is adopting the new AMA 98000-series telehealth codes for commercial plans and notably does not restrict POS codes on telehealth claims, accepting any POS.
Cigna
Cigna restricts audio-only reimbursement to behavioral health and specific chronic disease management scenarios. All billed CPT codes must appear on Cigna’s eligible virtual care code list. Cigna broadly covers audio-only behavioral health telehealth with modifier 93 — one of the few categories where it allows audio-only comprehensively.
Anthem BCBS and local BCBS plans
Both Anthem BCBS and local BCBS plans generally follow Medicare telehealth policy with modifier 95 for audio-video. Audio-only mental health is broadly covered, but general E/M audio-only coverage varies by state plan. Horizon BCBS (NJ) explicitly covers audio-only with modifier 93. Always verify with your specific BCBS state plan.
Kaiser Permanente
Kaiser has a robust integrated telehealth system, but visits must be conducted through Kaiser’s own HIPAA-compliant platform. Kaiser operates in California, Colorado, DC, Georgia, Hawaii, Maryland, Oregon, Virginia, and Washington. Providers outside the Kaiser network generally cannot bill Kaiser for telehealth services.
Check prior authorization requirements by payer
Our PA Check tool covers 500+ CPT codes across 30+ payers with portal links and billing tips.
Audio-only telehealth billing: what you need to know
Audio-only telehealth (telephone visits) is the most contentious area of telehealth billing in 2026. Coverage is inconsistent across payers and has been progressively tightening since the PHE ended. The key rules:
- Under Medicare: Audio-only is covered with modifier 93, but only when the patient lacks video capability or explicitly declines video. A generic statement like “patient prefers phone” will not survive an audit. You need a specific clinical reason documented in the chart.
- Under most commercial payers: Audio-only E/M coverage is limited or unavailable for general medical visits. It is more broadly available for mental and behavioral health services across most payers.
- Under state Medicaid: Coverage ranges from comprehensive (California, Washington, New York, Illinois) to restricted to mental health only (Texas, Florida, Tennessee) to essentially unavailable for E/M (Mississippi, Wyoming, South Dakota).
When audio-only is not covered for E/M, consider whether the patient qualifies for a virtual check-in (98016) instead — which is covered as audio-only under Medicare and most major commercial payers, and is a legitimate alternative for brief patient-initiated contacts.
Documentation requirements for telehealth claims
Telehealth claims fail audits and post-payment reviews when documentation is incomplete. The following elements must be present in the medical record for every telehealth claim:
- Patient verbal consent for telehealth, documented in the chart. Most payers require this for every visit, not just the first encounter.
- Provider’s physical location — city and state — at the time of service.
- Patient’s physical location — city and state — at the time of service. This determines the correct POS code.
- Technology confirmation — state the name of the HIPAA-compliant platform used (e.g., “Zoom for Healthcare,” “Doxy.me,” “Epic MyChart video visit”) and confirm it was two-way real-time audio-video for modifier 95 visits.
- For modifier 93 visits: the specific documented reason video was not used (“patient does not have a smartphone or computer with camera capability” or “patient declined video and preferred audio-only”).
- Clinical documentation supporting medical necessity and the E/M level billed — same standard as in-person visits.
- For Medicare mental health telehealth: the specific date of the patient’s most recent in-person visit with your practice.
Common telehealth claim denials and how to prevent them
| Denial reason | Root cause | How to prevent it |
|---|---|---|
| Wrong modifier | Using modifier 95 instead of GT for a state Medicaid that requires GT, or vice versa | Verify required modifier per payer before billing; use the tool above to check instantly |
| Wrong POS code | Using POS 02 when patient was at home (should be POS 10), or missing POS code entirely | Document patient location at every telehealth visit and map to correct POS code before claim creation |
| Code not on telehealth list | Billed CPT code is not on the payer’s eligible telehealth code list | Verify each billed code against the payer’s specific telehealth code list at least once per plan year |
| Audio-only not covered | Submitted modifier 93 for a payer or state that does not cover audio-only E/M | Check audio-only coverage before scheduling; consider virtual check-in (98016) as an alternative |
| Missing in-person visit (mental health) | Medicare mental health telehealth billed without documented in-person visit in the prior 6 months | Track in-person visit dates in your telehealth eligibility workflow; document in every mental health telehealth note |
| G2012 used instead of 98016 | Virtual check-in billed with retired HCPCS code G2012 (retired January 1, 2025) | Update billing system to CPT 98016 immediately; claims with G2012 are being automatically denied |
| New patient e-visit | E-visit (99421–99423) or virtual check-in (98016) billed for a new patient | E-visits and virtual check-ins are for established patients only; restrict access in your patient portal accordingly |
| Non-compliant platform | Service delivered via a non-HIPAA-compliant platform (FaceTime, standard Zoom, WhatsApp) | Use only CMS-approved HIPAA-compliant platforms; document platform name in every telehealth note |
For a comprehensive denial resolution guide covering all CARC and RARC codes, visit the CureAdvantage Denial Code Lookup tool. To estimate the financial impact of telehealth billing errors on your practice, try our Revenue Leakage Calculator. For help selecting the correct CPT code for any clinical scenario, use the CPT Coding Assistant.
Frequently asked questions
- CMS.gov — Medicare Telehealth Services (2026)
- CMS Telehealth FAQs — Consolidated Appropriations Act Extension
- AMA CPT Appendix T — Synchronous Telemedicine Services Rendered via Telephone
- Consolidated Appropriations Act (CAA) — Telehealth Extension Through December 2027
- Health Affairs — Telehealth Policy After the COVID-19 PHE
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