Guide

Teletherapy claims: POS and modifier combinations by payer

Summary

Medicare teletherapy claims generally need place-of-service code 02 (patient not at home) or 10 (patient at home) plus modifier 95 for a real-time video visit; audio-only sessions use a separate combination. Commercial and Medicaid payers frequently expect a different pairing — some still accept the older GT modifier, some skip a modifier and rely on POS alone — so confirm the exact combination in your specific payer's telehealth billing policy before submitting, rather than assuming one set works everywhere.

By Gale Editorial · Updated 2026-07-27. Every figure cited to a dated source. How we write.

The baseline combination: POS 02 or 10, plus modifier 95

For a synchronous video session, the common starting combination is place-of-service code 02 or 10 plus modifier 95, attached to whichever timed code you're billing — 90832, 90834, 90837 — the same way the modifier would attach to any other CPT code on the claim 1Ref 1Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.Supports the annually published code list, permanent-vs-temporary status, and separately tracked audio-only eligibility underlying POS-and-modifier decisions, and that a code must appear on the list before it is payable.. The POS code communicates where the patient was sitting; the modifier communicates that the encounter happened over live video rather than in person.

That baseline isn't universal. It's the combination CMS's telehealth policy is built around, and many commercial and Medicaid payers follow it closely, but "closely" isn't "identically" — treat it as the pattern to check against, not a rule you can submit blind. The same POS-and-modifier logic applies whether the code is a timed psychotherapy visit or the diagnostic evaluation code, including questions about re-billing 90791 when treatment restarts after a gap in care.

Medicare's specific rule

Medicare pays telehealth against its own annually published list of eligible codes, which marks each one permanent or temporary and separately flags audio-only eligibility 1Ref 1Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.Supports the annually published code list, permanent-vs-temporary status, and separately tracked audio-only eligibility underlying POS-and-modifier decisions, and that a code must appear on the list before it is payable.. A code has to appear on that list for a given year before POS and modifier choice even becomes relevant — a code that's fallen off the list isn't payable by telehealth no matter how the claim is coded.

Medicare's mental-health guidance folds behavioral health telehealth into that same structure: the psychotherapy and evaluation codes LMFTs, mental health counselors, psychologists, and clinical social workers bill are eligible telehealth services when they appear on the current list, using the same POS-plus-modifier mechanics as any other Medicare telehealth claim 2Ref 2Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.Supports that Medicare behavioral health telehealth for LMFTs, mental health counselors, psychologists, and clinical social workers uses the same list-based telehealth structure..

Commercial payers: expect a different pairing

Commercial behavioral-health networks publish their own telehealth billing rules rather than adopting Medicare's list wholesale, and the POS-and-modifier combination they expect can differ from what a Medicare claim needs for the identical CPT code. Optum's Provider Express, the enrollment and claims portal for one of the larger behavioral-health networks, is one example of a payer maintaining its own telehealth billing guidance separate from CMS's 3Ref 3Optum Behavioral Health (2026).Provider Express.Supports that a commercial behavioral-health network publishes its own telehealth billing guidance separate from CMS's list-based rule..

Some commercial contracts still accept the older GT modifier that Medicare has largely retired in favor of 95; others require 95 exclusively and reject GT outright. Pull the specific payer's current telehealth billing policy before your first teletherapy claim to that payer, and don't assume a combination that clears one payer will clear the next.

Medicaid: two state examples that don't match each other

State Medicaid programs run their own telehealth billing policy, published in each state's own provider manual, and two states rarely land on an identical POS-and-modifier requirement. Florida's Medicaid billing manual and California's each set their own telehealth rules and fee schedule entries 4Ref 4Florida Agency for Health Care Administration (2026).Florida Agency for Health Care Administration.Supports that Florida Medicaid publishes its own telehealth billing manual and fee schedule, as one example of state-level variation.5Ref 5California Department of Health Care Services (2026).California Department of Health Care Services.Supports that California Medicaid publishes its own telehealth billing manual and fee schedule, as a second example of state-level variation. — useful as concrete examples of how much this varies, not as evidence that either state's rule applies anywhere else.

A biller-of-one working Medicaid claims in more than one state, or picking up a new out-of-state Medicaid contract, needs that state's current manual open before the first teletherapy claim goes out — carrying a rule over from a familiar state is one of the more common sources of an avoidable denial.

Where the client is sitting decides POS 02 vs 10

The split between pos 11, 10, and 02 comes down to the patient's physical location at the time of the session, not the clinician's: POS 10 generally applies when the patient is at home, and POS 02 when the patient is somewhere else — an office, a school, another facility — receiving care remotely. Get this wrong and the claim can process, then surface later in an audit as a location mismatch.

Ask where the client actually was, every session, rather than defaulting to whichever POS code you used last time. A client's location can change week to week — home one session, a workplace the next — and the POS code has to track the real answer, not the practice's usual pattern.

Audio-only sessions need their own combination

A phone-only session, with no video component, isn't billed the same way as a video visit — audio-only eligibility is tracked separately on CMS's telehealth list, and a code payable by video isn't automatically payable when delivered by phone alone 1Ref 1Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.Supports the annually published code list, permanent-vs-temporary status, and separately tracked audio-only eligibility underlying POS-and-modifier decisions, and that a code must appear on the list before it is payable.. Confirm audio-only eligibility for the specific code before billing a phone session as telehealth rather than assuming the video rule extends to it.

A telehealth-billed 90837 already draws more payer attention than the same code billed in person, since 90837 under the microscope is a heavily reviewed code well before modality enters the picture — an audio-only 90837 compounds that scrutiny, so keep the documentation especially tight when the format is audio-only and the code is the longest psychotherapy option.

Documentation and platform security have to match what you billed

The POS code and modifier are a claim-level summary of something the note has to independently support: where the patient was, what modality was used, and that informed consent covered remote care specifically. APA's telepsychology guidelines call out informed consent and the security of the medium as their own competence areas for remote practice, separate from competence in the clinical work itself 6Ref 6American Psychological Association (2013).Guidelines for the Practice of Telepsychology.Supports the informed-consent and security-of-medium competence standards documentation should reflect for a telehealth session..

The platform carrying a behavioral health session also has to meet the same privacy expectations as an in-person record — OCR's mental-health-specific HIPAA guidance addresses when and how information from a session can be shared, and that guidance doesn't relax because the encounter happened over video instead of in the room 7Ref 7HHS Office for Civil Rights (2026).HIPAA Privacy Rule and Sharing Information Related to Mental Health.Supports that HIPAA's mental-health-specific privacy expectations for records and platforms apply the same way to a telehealth encounter as to an in-person one.. Write the teletherapy note: location, consent, modality every time, so the record and the claim tell the same story if either one is ever reviewed.

Common questions

For Medicare and most payers following its pattern, yes, for a real-time video visit — but confirm with each specific payer, since some commercial contracts still accept the older GT modifier and a few omit a modifier entirely and rely on the POS code alone. Check the payer's current telehealth billing policy before assuming.

Both indicate a telehealth encounter, but they report the patient's location: POS 10 generally means the patient was at home, and POS 02 means the patient was somewhere else — an office, a school, another facility — while receiving care remotely. Confirm the client's actual location each session rather than defaulting to a habitual code.

No. Audio-only eligibility is tracked separately from video eligibility on Medicare's telehealth list, and the code or modifier combination for a phone-only session can differ from the video combination for the identical CPT code. Confirm audio-only status for that specific code before billing a phone session as telehealth.

No. Medicare, Medicaid programs, and commercial behavioral-health networks each publish their own telehealth billing rules, and the combination that clears one payer's claims can be rejected by another for the identical CPT code and modality. Confirm the specific payer's current policy rather than reusing a combination that worked elsewhere.

It depends on the payer. Some pay telehealth-billed codes at the same rate as an in-person visit; others apply a facility-rate adjustment tied to the POS code rather than the modifier itself. Check your specific payer's fee schedule for the code and POS combination rather than assuming parity with in-person payment.

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References

1.Centers for Medicare & Medicaid Services (2026). List of Telehealth Services. Centers for Medicare & Medicaid Services (CMS). link ✓Supports the annually published code list, permanent-vs-temporary status, and separately tracked audio-only eligibility underlying POS-and-modifier decisions, and that a code must appear on the list before it is payable.
2.Centers for Medicare & Medicaid Services (2025). Medicare and Mental Health Coverage. CMS Medicare Learning Network (MLN1986542). link ✓Supports that Medicare behavioral health telehealth for LMFTs, mental health counselors, psychologists, and clinical social workers uses the same list-based telehealth structure.
3.Optum Behavioral Health (2026). Provider Express. Optum Behavioral Health. linkSupports that a commercial behavioral-health network publishes its own telehealth billing guidance separate from CMS's list-based rule.
4.Florida Agency for Health Care Administration (2026). Florida Agency for Health Care Administration. Florida Agency for Health Care Administration. link ✓Supports that Florida Medicaid publishes its own telehealth billing manual and fee schedule, as one example of state-level variation.
5.California Department of Health Care Services (2026). California Department of Health Care Services. California Department of Health Care Services. link ✓Supports that California Medicaid publishes its own telehealth billing manual and fee schedule, as a second example of state-level variation.
6.American Psychological Association (2013). Guidelines for the Practice of Telepsychology. American Psychological Association. linkSupports the informed-consent and security-of-medium competence standards documentation should reflect for a telehealth session.
7.HHS Office for Civil Rights (2026). HIPAA Privacy Rule and Sharing Information Related to Mental Health. U.S. Department of Health and Human Services. linkSupports that HIPAA's mental-health-specific privacy expectations for records and platforms apply the same way to a telehealth encounter as to an in-person one.

https://www.gale.care/for-providers/bhc-telehealth-modifiers-bh · 7 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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