Most therapy practices now see a large share of their patients by video, and the CPT codes don't change when a session moves online: a 53-minute session is still 90837. What changes is everything around the code. The place of service, the modifier, where the patient was sitting, and whether the session was video or audio-only all decide whether the claim pays, and each payer has its own version of the rules.
This article covers the coding pieces of a telehealth claim, how Medicare and commercial payers differ, and the denials we see most often. For the codes themselves, start with our complete guide to mental health billing.
The four parts of a telehealth claim
1. The CPT code: same as in person
Intakes (90791, 90792), psychotherapy (90832, 90834, 90837), family therapy (90846, 90847), psychiatric E/M visits with add-ons, and group therapy (90853) can all be delivered by telehealth with most payers. The time rules are the same as in the office. A few codes, such as some psychological testing administration, have narrower telehealth coverage, so check before scheduling them remotely.
2. Place of service: POS 10 or POS 02
- POS 10: telehealth with the patient in their home. This is the right code for most therapy sessions.
- POS 02: telehealth with the patient somewhere other than home, such as a clinic, school, or workplace.
The place of service describes where the patient is, not the clinician. A therapist working from home while the patient is at home still bills POS 10. Some commercial plans instead want the POS you would use in person (usually 11, office) plus a telehealth modifier. That's a payer-specific rule, so record it in your payer setup rather than guessing claim by claim.
3. The modifier
| Modifier | Meaning | Where it's used |
|---|---|---|
| 95 | Synchronous audio-video telehealth | Most commercial plans, Medicaid plans, and Medicare when the payer asks for it |
| 93 | Synchronous audio-only | Medicare and many other payers for audio-only behavioral health |
| FQ | Audio-only, Medicare FQHC/RHC billing | Federally qualified health centers and rural health clinics |
| GT | Legacy telehealth modifier | A few Medicaid and commercial plans still require it; most replaced it with 95 |
For Medicare professional claims, the place-of-service code is what identifies telehealth, and modifier 95 is used where Medicare instructs it, such as under some telehealth flexibilities. Many commercial payers require 95 on every video visit. Getting this wrong rarely changes the payment amount, but it's one of the most common reasons a telehealth claim is rejected outright.
4. The documentation
Every telehealth note should record:
- That the session was by telehealth, and whether it was video or audio-only
- The patient's location (city and state at minimum) and the clinician's location
- The patient's consent to telehealth, if the state or payer requires it
- For audio-only sessions, why video wasn't used (the patient couldn't use it or didn't consent to it)
- Start and stop times, the same as an in-person session
Audio-only therapy sessions
Medicare allows audio-only telehealth for mental health services when the clinician is able to use video but the patient can't or won't. The claim carries modifier 93, and the note should say why the visit was audio-only. Many Medicaid programs and commercial plans also cover audio-only behavioral health, but some pay it at a lower rate or not at all, and some limit which codes qualify. If a meaningful share of your sessions fall back to phone, check each payer's audio-only policy before assuming the claim will pay.
Medicare telehealth for mental health
Mental health telehealth to the patient's home is permanent in Medicare. The rule that requires an in-person visit within six months before starting telemental health, and periodically after that, has been delayed several times. Under the Consolidated Appropriations Act, 2026, the current flexibilities run through December 31, 2027, so practices should plan for the in-person requirement to return in 2028 unless Congress extends it again. LPCs and LMFTs, who gained Medicare billing rights in 2024, follow the same telehealth rules as other Medicare mental health providers. Our article on Medicare mental health billing covers enrollment.
Cross-state telehealth
The session is delivered where the patient is. A therapist licensed in Rhode Island seeing a patient who is in Massachusetts that day needs a Massachusetts license (or compact privilege) and, for insurance, the payer's enrollment for Massachusetts. Two common surprises:
- Patients who travel. A patient on vacation or at college in another state can turn a routine session into one the clinician isn't licensed for. Ask where the patient is at the start of every session and document it.
- Compacts don't cover credentialing. PSYPACT and the counseling compacts help with licensure, but each payer still needs the provider enrolled for that state.
See our state-by-state billing guide and the multi-state billing article for how this works across states.
Telehealth payment parity
Whether a telehealth session pays the same as an in-person session depends on the state and the plan. Many states have telehealth payment parity laws for state-regulated plans, but self-funded employer plans aren't subject to state insurance law, and some states only require coverage, not equal payment. Compare your ERAs for telehealth and in-person sessions with the same payer. If telehealth pays less, check whether that's the contract or a coding problem.
The denials we see most on telehealth claims
- POS 02 billed for a patient at home. Some payers pay POS 02 at a lower rate or deny it when their rules expect POS 10.
- Missing or wrong modifier. A commercial plan that requires 95 rejects the claim without it, and an audio-only session billed as video is a compliance problem, not just a denial.
- Provider not licensed or enrolled in the patient's state. This often shows up months later, during an audit.
- The behavioral health carve-out has its own telehealth policy. Optum, Carelon, and other MBHOs may follow different POS and modifier rules than the medical plan on the patient's card.
- Audio-only billed to a payer that doesn't cover it.
A quick self-audit. Run a report of last month's telehealth claims by payer, place of service, and modifier. Each payer should show one consistent combination. If the same payer shows two or three, some of those claims are coded wrong.
Getting telehealth claims paid
Telehealth billing works when each payer's POS, modifier, and audio-only rules are set up once, correctly, and the documentation captures where the patient was. Sharp Networks Group provides mental health billing services for therapists, psychiatric providers, and group practices that see patients by video across one or several states, inside the EHR you already use, and handles credentialing for each state you serve. Schedule a consultation and we'll review your recent telehealth claims with you.