Audio-only sessions: coverage, consent, and modifier 93

Audio-only is not automatically covered the way video visits increasingly are

Audio-only delivery is not a blanket telehealth category — it is a specific eligibility flag a payer sets code by code, and a code payable for video telehealth is not automatically payable for audio-only just because both fall under a general "telehealth" label. CMS publishes the specific codes it recognizes for Medicare telehealth each year, including which carry audio-only eligibility, current as of when the list was last updated 1Ref 1Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.Supports that CMS publishes an annual, code-specific list of Medicare telehealth eligibility including audio-only status..

Commercial payers are not required to mirror that list, and most publish their own audio-only telehealth policy separately — some cover it broadly for behavioral health codes, others restrict it to established patients only, or require a video option to have been offered first. Confirm the specific code, the specific payer, and the specific plan before scheduling a phone-only session and assuming it will be reimbursed the same as a video visit.

Modifier 93: what it flags, and what the note should carry instead of video

modifier 93 flags a claim line as delivered by real-time audio-only telecommunication rather than video, appended to the procedure code alongside whatever place-of-service code the payer's telehealth policy calls for. It tells the payer exactly how the visit happened; it does not, on its own, establish that the code billed is one the payer covers for audio-only delivery in the first place — that eligibility question is answered separately, before the modifier is even relevant.

Because a phone session carries no visual record of engagement, affect, or environment, the golden thread running through the note — the connection between what the treatment plan targeted and what the session actually did — has to carry more of that weight in an audio-only visit than it does when video corroborates the clinical picture. Note explicitly that the format was audio-only and why, especially for a client whose treatment plan otherwise assumes video.

Where Medicare stands right now

Medicare's behavioral health coverage extends to audio-only delivery for a defined set of codes, documented in CMS's mental health coverage booklet alongside the rest of what Medicare pays for psychiatric diagnostic evaluation and psychotherapy 2Ref 2Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.Supports Medicare's behavioral health coverage scope, including audio-only telehealth rules and the 2024 provider-type expansion.. This is a rule administrations have adjusted several times since the pandemic-era flexibilities began, so treat "covered" as a claim with an expiration date rather than a fixed fact, and recheck the current list before relying on last year's answer.

The same booklet is where Medicare's 2024 opening — the expansion of Medicare enrollment to marriage and family therapists and mental health counselors — intersects with audio-only rules: a newly eligible provider type does not automatically inherit every audio-only allowance a psychologist or physician has held for longer, so confirm the specific code's audio-only status under the newly enrolled provider type rather than assuming parity.

Look it up code by code before you schedule the call

The fastest way to avoid an audio-only denial is to check the specific code against the specific payer's published list before the appointment is on the calendar, not after the claim comes back. Building the habit of consulting the telehealth billing matrix for a given code — Medicare's published list for Medicare patients, the payer's own telehealth policy page for everyone else — turns a guess into a two-minute lookup.

• Recheck at the start of each benefit year, since payer telehealth policies are revised on their own schedule, not synced to CMS's.
• Confirm whether an established-patient requirement applies — several payers restrict audio-only to patients already seen at least once by video or in person.
• Save the specific policy page or list you checked, dated, in case a later audit asks what you relied on.

How commercial payers differ: one example

Payer telehealth policies are not interchangeable, and treating one payer's rule as the industry standard is a common source of a wrongly assumed denial. Cigna publishes its own coverage and claims policy for telehealth, including audio-only parameters, on its provider portal, cited here only as that payer's own published example, not as what every commercial plan does 3Ref 3Cigna (2026).Cigna Coverage and Claims Policies.Illustrates one named commercial payer's own published audio-only telehealth policy, used as an example, not a universal rule..

The EAP funding track complicates this further: EAP work often runs on the vendor's own authorization and billing rules rather than the member's underlying health plan, so a payer's standard audio-only policy may not even apply to a session billed through an employer-funded EAP benefit. Confirm the vendor's own telehealth terms separately rather than assuming the health plan's policy carries over.

Consent: the standards bodies expect it named specifically

Professional ethics codes generally require informed consent that names the specific medium of care, not just consent to treatment in general — APA's telepsychology guidelines call out competence, confidentiality, and security considerations specific to remote delivery as part of that consent conversation 4Ref 4American Psychological Association (2013).Guidelines for the Practice of Telepsychology.Supports the informed-consent, competence, and security standards APA sets for remote/telehealth delivery, including audio-only., and NASW's code of ethics extends the same informed-consent and technology-mediated-practice obligations to social workers 5Ref 5National Association of Social Workers (2021).NASW Code of Ethics.Supports the informed-consent and technology-mediated-practice obligations NASW sets for social workers delivering remote care..

For an audio-only visit specifically, that consent conversation should cover what is different about phone-only care compared with the video or in-person sessions the client may be used to: no visual read of affect, a different privacy risk profile if the client is in a shared or public space, and, where it applies, what happens if the call drops mid-session. Document that this conversation happened, not just that a general telehealth consent form was signed at intake.

HIPAA and the audio-only medium

The COVID-era HIPAA enforcement discretion that once tolerated ordinary consumer video apps for telehealth has ended, and OCR's current guidance addresses audio-only delivery specifically as part of what a HIPAA-compliant telehealth arrangement now requires 6Ref 6HHS Office for Civil Rights (2026).HIPAA and Telehealth.Supports that telehealth, including audio-only delivery, must run on a HIPAA-compliant arrangement now that COVID-era enforcement discretion has ended..

A standard cellular phone call is generally treated differently from a video platform for HIPAA purposes, since there is no video feed or app-based session data to secure the way there is with a video visit, but the surrounding practice — the notes taken during the call, and any recording or transcription tool — still falls under the same HIPAA obligations as any other clinical encounter. Confirm your specific phone system and any transcription or scribe tool against current OCR guidance rather than assuming a phone call is automatically exempt from telehealth security requirements just because it isn't a video app.