Telehealth Billing for Therapists: The 2026 Modifier and Place-of-Service Decisions That Decide What You Get Paid

Telehealth billing for therapists in 2026 comes down to three fields. Use POS 10 when your client is at home and POS 02 when they are anywhere else. Add modifier 95 for audio-video and modifier 93 for audio-only.

Medicare telehealth flexibilities now run through December 31, 2027, and behavioral health telehealth is already permanent.

What the answer above does not tell you is that POS 10 and POS 02 pay different amounts for the same 90837, that Medicare and your commercial panels disagree about whether modifier 95 belongs on the claim at all, or that the single most expensive telehealth error I see is a default setting inside an EHR that nobody has looked at since 2023.

Below is the decision logic for each field, the payer-by-payer split, and the seven checks I run before a telehealth claim leaves a practice.

What is the correct place of service code for telehealth in 2026?

The place of service code describes where your client sat during the session. It has nothing to do with where you sat.

Per the CMS Telehealth FAQ updated February 26, 2026, practitioners use POS 02 for telehealth provided other than in the patient's home, and POS 10 for telehealth provided in the patient's home.

CMS defines "home" broadly here: the client's own residence, a vacation home, a family member's house, or a temporary shelter all count as home.

Here is the part that costs money. In the CY 2024 Physician Fee Schedule, CMS finalized that telehealth claims for patients in their homes pay at the non-facility rate. POS 02 pays the lower facility rate.

Psychotherapy codes carry different facility and non-facility values, so a practice that bills POS 02 on home sessions underpays itself on every single claim and never sees a denial to warn it.

Across the behavioral health practices HireGaynell supports, place-of-service errors account for roughly one in five telehealth claim corrections we make during a new client's first 60 days. Nearly all of them trace back to an EHR telehealth appointment type still defaulted to POS 02 from the pandemic era.

If you use SimplePractice, TherapyNotes, or TheraNest, open your telehealth appointment settings today and confirm which POS your video sessions are writing to the claim.

One more distinction worth holding onto: POS 11 stays reserved for in-person office visits. It is not a telehealth code, and it does not become one because you added modifier 95.

Do you need modifier 95 for telehealth billing?

It depends entirely on who you are billing, which is why blanket advice on this fails.

Medicare Fee-for-Service identifies telehealth through the place of service code.

The CMS Telehealth and Remote Monitoring booklet (MLN901705) instructs professional billers to submit the appropriate CPT code with POS 02 or POS 10 and reserves modifier 95 for specific institutional scenarios. Medicare does not require modifier 95 on your professional psychotherapy claim.

Most commercial payers do require it. Many state Medicaid programs require it. Some reject the claim without it under CO-197, "payment denied due to absence of modifier indicating telehealth."

My operating rule: append modifier 95 to audio-video sessions on every payer except Medicare Fee-for-Service, unless that payer's published telehealth policy specifically says otherwise.

Medicare will not penalize you for including it, but the cleaner practice is to follow each payer's actual policy and build the rule into your claim scrubber rather than your memory.

If a modifier mismatch has already cost you revenue, the sequence for recovering it is in my guide on how to appeal a denied insurance claim as a therapist.

Which telehealth modifier do you use for audio-only therapy sessions?

Modifier 93 identifies a synchronous session delivered by telephone with no video. Modifier 95 identifies real-time audio and video. Putting Modifier 95 on a phone session misrepresents the modality, and that is a compliance problem, not a coding preference.

Medicare permits audio-only behavioral health telehealth permanently, and the CMS FAQ confirms two-way interactive audio-only technology is allowed for behavioral health telehealth services with no geographic or site restriction.

The conditions attach to the documentation: you must be technically capable of audio-video, and the client must be unable to use video or decline it.

That means your note has to say so. "Phone session" alone does not support the claim. Write the reason: no device, no reliable connection, client declined video. Every audio-only session needs that line.

Modifier FQ also lives in this space.

CMS created FQ to indicate a telehealth service furnished using real-time audio-only communication technology, and it appears most often in Rural Health Clinic and Federally Qualified Health Center billing, though some Medicare Administrative Contractors reference it for audio-only mental health services more broadly.

MAC guidance genuinely varies here. Check your MAC's published article before you standardize on 93 or FQ.

Note: Verify with your MAC: FQ vs. 93 instructions differ by contractor as of mid-2026.

Is modifier GT still used for telehealth in 2026?

For a private therapy practice, no. Medicare retired GT for Part B professional telehealth claims years ago and now uses it only for distant site practitioners billing under the Critical Access Hospital Optional Payment Method II on institutional claims.

A handful of legacy commercial and Medicaid systems still accept or request it, but GT appearing on your professional claims usually signals a billing template nobody has updated.

Modifier GQ stays narrower still: asynchronous store-and-forward, limited to the federal telemedicine demonstrations in Alaska and Hawaii.

What are the 2026 Medicare telehealth rules for behavioral health?

This is where therapists get better news than the rest of medicine, and where the headlines mislead.

Two separate tracks exist. Most Medicare telehealth flexibilities are temporary and were extended by the Consolidated Appropriations Act, 2026, signed February 3, 2026, which pushed the expiration from January 30, 2026 to December 31, 2027 (the American Medical Association summarized the two-year extension in Section 6209).

Behavioral health telehealth sits on the other track. The Consolidated Appropriations Act, 2021 permanently removed geographic and originating-site restrictions for behavioral health telehealth, so your clients can be at home, in any state you are licensed and enrolled in, urban or rural, permanently.

Three practical points for 2026:

The in-person requirement is not active yet: CMS confirms the statutory in-person visit requirement for mental health telehealth takes effect after December 31, 2027.

Clients who begin receiving mental health telehealth on or before that date are treated as established and will need only one in-person visit every 12 months afterwards. That grandfathering clause is worth planning around now.

Audio-only remains covered: Beneficiaries may receive audio-only telehealth in their homes through December 31, 2027, and behavioral health audio-only continues past that under the permanent definition of an interactive telecommunications system.

Enrollment still follows the client: CMS requires separate Medicare enrollment for each state where you furnish services. Licensure and provider enrollment, not the telehealth rules, are what actually limit where you can practice. If you are weighing whether to join the program at all, I walk through the math in Medicare enrollment for LPCs and LMFTs.

For 2026, CMS also added multiple family group psychotherapy (CPT 90849) to the Medicare Telehealth Services List and removed the provisional-versus-permanent distinction, so everything added now is permanent.

Can therapists bill CPT 98000 - 98015 for telehealth?

Not to Medicare. CPT created the 98000–98015 telemedicine evaluation and management family in 2025 and deleted the old telephone codes 99441–99443.

CMS declined to recognize 98000–98015 in both the CY 2025 and CY 2026 Physician Fee Schedules, assigning them invalid status. Only 98016, the brief virtual check-in replacing G2012, is payable.

For most therapists, this is a non-issue because psychotherapy codes are not E/M codes.

You keep billing 90791, 90832, 90834, 90837, 90846, 90847, and 90853 with the telehealth POS and the payer's required modifier.

It matters if you employ a psychiatrist or PMHNP billing 99202–99215, and it matters because some commercial payers did adopt the 98000 series, creating a split you have to track per contract.

The full code-by-code breakdown sits in my post on CPT codes every therapy practice should know in 2026.

How do you bill telehealth from a home office?

You use your enrolled practice location, not your house.

CMS states that practitioners who furnish telehealth from home but maintain a physical practice location do not report their home address on the Medicare enrollment application and can bill from the practice location as if the service happened in person.

Virtual-only practitioners whose only location is their home must enroll that address, but they can mark it "home office for administrative/telehealth use only" in PECOS to suppress the street address from the public Care Compare profile, or email the Quality Payment Program service center to do the same.

I raise this because I have watched fully virtual therapists discover their home address on a public federal website. Fix it at enrollment, not after.

The 7-step telehealth claim check I run before submission

Step 1: Confirm where the client physically sat during the session, and select POS 10 for home or POS 02 for any other location. Never let the EHR decide by default.

Step 2: Confirm the modality. Audio-video takes modifier 95 on commercial and Medicaid claims. Audio-only takes modifier 93, or FQ where your MAC or payer directs.

Step 3: Check the note supports the modifier. Audio-video notes should name the platform and confirm synchronous two-way interaction. Audio-only notes must state why video was not used.

Step 4: Verify the CPT code is payable as telehealth by that payer, using the CMS List of Telehealth Services for Medicare and the payer's telehealth policy for everyone else.

Step 5: Confirm the rendering provider is licensed in the client's state and enrolled or paneled with that payer for that state. This is a credentialing question, not a billing one, and it is the most common reason a technically perfect claim denies.

Step 6: Confirm prior authorization status where the plan requires it, and confirm the client's telehealth benefit at the plan level rather than the group level. My insurance benefit verification checklist covers the questions that catch telehealth carve-outs before session one.

Step 7: Scrub for retired codes and modifiers. Any claim carrying 99441–99443, or GT on a professional line, gets stopped.

How HireGaynell handles telehealth billing for behavioral health practices

Telehealth billing breaks in a specific place: the gap between what your EHR does automatically and what each payer actually requires. Nobody in a solo or small-group practice has time to reconcile that gap weekly, so it silently drains revenue instead of generating denials you would notice.

That reconciliation is the work I do.

HireGaynell provides done-for-you behavioral health operations for solo and small-group practices that bill insurance and run without a front desk - billing and claim submission, insurance credentialing and provider enrollment, CAQH ProView setup and re-attestation every 120 days, paneling, client intake, and scheduling. I specialize in SimplePractice and work inside whatever EHR you already run.

On telehealth specifically, I audit your appointment types and POS defaults, build a payer-by-payer modifier matrix so the rule lives in your system instead of your head, correct the claims that went out wrong, and appeal the ones that denied. When we audit a new client's most recent 90 days of telehealth claims, we typically surface four figures in underpayments that never triggered a single denial code. We onboard most practices within a week of the first consultation.

Conclusion

In my experience running billing and credentialing for behavioral health practices, the single most expensive telehealth mistake is not a wrong modifier - it is a correct-looking claim that pays at the facility rate because an EHR appointment type has been quietly writing POS 02 on home sessions for three years.

Denials get attention. Underpayments do not. Audit your telehealth place-of-service defaults this week, before you touch anything else on this list, then build the payer modifier rules into your system so a busy Thursday never becomes a coding decision.

If telehealth claims are paying less than they should and you do not have the hours to reconcile every payer's policy, that is exactly the work HireGaynell's billing and practice administration support handles.

Book a free consultation, and we will start with an audit of your last 90 days.