Telehealth Billing: How It Differs From In-Person Billing

Telehealth billing is the process of submitting insurance claims for health care services delivered remotely, by video or phone, instead of in person. The service itself is usually coded the same way as an in-person visit. What changes is the place of service code, the modifier, and the payer rules behind them. Get any of those three wrong and the claim comes back unpaid.

That is the whole game in one paragraph. A video visit is not a different kind of medicine. It is the same visit, delivered through a screen, and the billing has to say so in a language the payer's system understands.

How a telehealth claim differs

Three things change on every telehealth claim, and they change independently. Mixing them up is an easy way to get a claim denied.

Where the patient was. The place of service code, or POS code, describes the patient's location during the visit, not the clinician's office. A therapist working from the practice who sees a patient at home reports POS 10. The same therapist seeing a patient at a rural clinic reports POS 02. The code follows the patient.

How the visit happened. The modifier tells the payer what technology connected the two sides. Live video gets one modifier. A phone call gets another. A recorded message sent for later review gets a third. The modifier is the payer's proof that the visit really was remote.

Whether this payer covers it. Medicare, Medicaid programs, and commercial plans each publish their own telehealth policy, and those policies have changed often since 2020. A code that pays under one plan can be non-covered under another. There is no single telehealth rulebook. There is a federal baseline, fifty state Medicaid programs, and hundreds of commercial policies.

For the wider billing cycle this sits inside, see how medical billing works.

What counts as telehealth for billing

Payers sort remote care into three buckets, and the bucket decides the code.

Synchronous telehealth is a live, real-time visit over audio and video. Patient and clinician talk at the same time, face to face on a screen. This is the standard telehealth visit, and the billing rules in this guide are written around it.

Audio-only telehealth is a live visit by phone, with no video. It exists because some patients cannot do video: no broadband, no smartphone, no comfort with the technology. Payers treat it as a narrower category with its own codes and modifiers, and the rules around it are stricter.

Store-and-forward is asynchronous care. A patient or clinician records images, video, or messages, and the other side reviews them later. It is common in dermatology and ophthalmology. Medicare covers it only in narrow federal demonstration programs in Alaska and Hawaii.

The distinction matters because a claim coded for the wrong bucket gets denied on the technology, not the care. A phone visit billed as a video visit is a miscoded claim, even if the clinician did exactly the right work.

Place of service codes: POS 02 vs POS 10

Professional claims report the place of service on each service line, in box 24B of the CMS-1500. For telehealth, two codes do almost all the work.

The payment difference is real money. Since January 1, 2024, Medicare pays POS 10 claims at the non-facility rate, the same rate as an in-person office visit. POS 02 claims pay at the lower facility rate, because the payer assumes a facility is absorbing some of the overhead. Using the wrong one does not just risk a denial. It can mean getting paid at the wrong rate on a claim that sails through.

Three habits keep this clean. First, record the patient's location at the start of every visit, along with the state they are in, because licensure rules depend on the patient's state too. Second, never use POS 11, the office code, for a telehealth visit. That was allowed during the pandemic under temporary waivers. The waivers ended, and POS 11 on a telehealth claim now reads as an in-person visit that never happened. Third, remember that POS describes the patient's side. Where the clinician sits does not matter.

Telehealth modifiers

The modifier rides on the CPT code and tells the payer how the service was delivered. The common ones:

Two things trip people up here. The first is that modifiers do not change what Medicare pays. The place of service code does that. A modifier marks the visit; the POS code prices it. The second is that commercial payers do not agree with each other. Some want modifier 95, some want GT, some want both, and some want the POS code alone. The only safe habit is checking the plan's policy before filing, not after the denial arrives.

For how modifiers work generally, see medical billing modifiers explained.

Which CPT codes get used

Here is the part that surprises people new to telehealth: the procedure code usually stays the same as in person. A 15-minute established patient visit is 99213 whether it happens in an exam room or on a laptop. The telehealth signal rides on the POS code and the modifier, not on a special telehealth CPT code.

The codes practices use most:

The E/M level for a video visit is set by the same medical decision-making criteria as in person.

Specialty services keep their own codes too. A telehealth psychotherapy session uses the psychotherapy code, a telehealth physical therapy visit uses the therapy code. The pattern holds: same code, plus the telehealth markers.

Audio-only visits: the rules

Audio-only is where telehealth billing gets narrowest.

Medicare covers audio-only visits when the patient is at home, the provider has the capability to use video, and the patient cannot or will not use it. The visit is billed with the telephone E/M codes 99441-99443, or with the standard E/M code plus modifier 93, depending on the service and the payer. Document why video was not used on every audio-only encounter: patient preference, no broadband, a failed connection. That note is the difference between a payable claim and a denial that is hard to overturn, because the payer cannot verify the reason after the fact.

Two limits to know. First, audio-only never earns the originating site facility fee, because there is no video component and no facility hosting a video visit. Second, behavioral health is the exception to almost every audio-only restriction. Mental health telehealth to the home, including audio-only, is permanent under federal law, and it does not depend on the temporary flexibilities that cover other services.

The originating site facility fee

When a patient sits at an eligible facility for a telehealth visit, a clinic, a hospital, a rural health center, that facility can bill for hosting the encounter. The code is Q3014, the telehealth originating site facility fee. For 2026 it pays $31.85 under Medicare.

Q3014 is a facility claim, not a professional claim. It pays the originating site for the room, the equipment, and the staff time. It is separate from the clinician's fee for the visit itself. Three rules govern it: it applies only to live audio-video visits, never audio-only; it applies only when the patient is at an eligible facility, never at home; and the distant-site clinician does not bill it. A practice that bills Q3014 for a patient sitting on their own couch is billing for a facility that does not exist.

Medicare policy timeline, 2025 to 2027

Medicare telehealth rules have swung more in the last two years than in the previous decade. The timeline matters because claims from the lapse windows were handled differently, and some of them can still be resubmitted.

The honest read is that the extension is long but not permanent. The CONNECT for Health Act, which would make the flexibilities permanent, has bipartisan support and has not passed. A practice building a telehealth program should treat December 31, 2027 as a real deadline and watch for the next extension, not assume one arrives.

One more date matters for prescribing rather than billing. DEA telemedicine prescribing flexibilities, which let clinicians prescribe controlled substances after a telehealth visit without an in-person exam, run through December 31, 2026 unless the DEA extends them. That affects what a visit can accomplish, not how it is coded.

Commercial plans and Medicaid: where they differ

Medicare sets the baseline, and then every other payer writes its own variation.

Commercial plans each write their own rules. Large plans commonly accept modifier 95 and POS 02 or 10, but some still require GT, some require both a modifier and a POS code, and some pay telehealth at a lower rate than in-person visits under their own parity rules, which vary by state. A few plans maintain their own telehealth code lists that are narrower than Medicare's. The practical rule is to verify the plan's telehealth policy in writing before the first claim, and to re-check it when the plan updates its provider manual, which usually happens once a year.

Medicaid is fifty different programs. Some states pay telehealth at parity with in-person visits. Some pay less. Some require the patient to be at a specific type of originating site. Some still require GT where Medicare moved on. State Medicaid telehealth policy also changes with state legislation, so a rule that held last year may not hold this one. Practices that see Medicaid patients across state lines need a policy check per state, not per payer.

Documentation that keeps telehealth claims clean

Telehealth documentation is in-person documentation plus four extra facts. Miss one and the claim is deniable even when the care was perfect.

1. Patient location. Where the patient was, and in which state. This drives the POS code and the licensure question.
2. Technology used. Live video, phone, or store-and-forward. Name the platform. This drives the modifier.
3. Consent. The patient agreed to a telehealth visit. Many payers require documented consent, and some require it before the visit starts.
4. Why audio-only, when it applies. If the visit was by phone, say why video was not used. Patient preference, technical failure, no broadband. One sentence in the note covers it.

Everything else follows the normal rules: the same history, exam, and medical decision-making documentation as an in-person visit, the same diagnosis codes, the same medical necessity link between the diagnosis and the service. A telehealth note that skips the exam elements a payer expects for the E/M level will be downcoded or denied exactly the way an in-person note would be.

Common reasons telehealth claims get denied

Telehealth denials trace back to a small set of errors, and the fix for each one happens before submission.

Wrong place of service. POS 11 on a telehealth claim, or POS 10 when the patient was at a clinic. The fix is a location field in the encounter template that the clinician fills in at the start of every visit.

Missing or wrong modifier. A video visit billed without modifier 95 for a payer that requires it, or an audio-only visit billed with 95 instead of 93. The fix is a payer-specific modifier rule in the billing system, not a memory exercise.

Service not on the payer's telehealth list. Medicare publishes a telehealth services list, and commercial plans keep their own. A service that is covered in person is not automatically covered by telehealth. The fix is checking the list before the visit, not after the denial.

Lapsed flexibilities on the date of service. Claims with dates of service in the October 2025 lapse window were returned, and claims from the brief January 2026 lapse need checking too. The fix is resubmission where the law now makes them payable, and a calendar note for December 31, 2027.

Audio-only without justification. A phone visit with no documented reason video was not used. The fix is a one-line template in the note.

Licensure. The clinician was not licensed in the patient's state at the time of the visit. Telehealth crosses state lines by definition, and licensure follows the patient, not the clinician. This one is not fixable after the fact, which is why eligibility verification runs before the visit, not after.

When a telehealth claim is denied, the remittance advice tells you which of these it was. For how to read it, see remittance advice in medical billing.

Telehealth vs in-person billing

The table makes the real point. The billing system is the same. Three fields change, and the policy calendar moves.

A practice deciding whether to run telehealth in house or hand the billing to a specialist team is making the same decision as with any other billing work. Our revenue cycle outsourcing services cover what an outside team takes over, and our methodology explains how we evaluate the firms that do it. The CMS-1500 itself carries the telehealth markers in box 24B for place of service and box 24D for the modifier, as explained in the CMS-1500 claim form.

The rule to remember

Same code, new markers, moving calendar. Get the place of service right, get the modifier right, and check the payer's policy before the visit instead of after the denial.