Audio-only: the phone visit's narrow billable lane

When is an audio-only visit billable?

Audio-only visits are billable in a narrow, defined lane rather than as a routine substitute for video. Medicare permanently covers audio-only telehealth for behavioral health when the patient cannot use, or does not consent to, two-way video — delivered to the patient's home — and describes the conditions in its Medicare Learning Network telehealth booklet 1Ref 1Centers for Medicare & Medicaid Services (2025).Telehealth Services.The permanent Medicare behavioral-health telehealth provisions, including the home as originating site, the audio-only condition when the patient cannot use or declines video, and the repeatedly postponed in-person-visit requirement.. Outside that lane, whether a phone visit pays depends heavily on the payer and the state.

Because commercial and Medicaid coverage of a phone visit varies by state and plan, say the state-dependence out loud with your patient before the appointment. The rest of this page walks the one place the rule is settled — Medicare behavioral health — then the mechanics that make the claim clean, then the places where you have to read your own contract.

The Medicare behavioral-health carve-out

Behavioral health is the one clinical area where Medicare made audio-only permanent, not temporary. The mental-health coverage booklet confirms Medicare pays for psychiatric diagnostic evaluation and psychotherapy delivered to the home, and — since the 2024 expansion — the services of marriage and family therapists and mental health counselors 2Ref 2Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.That Medicare covers psychiatric diagnostic evaluation and psychotherapy delivered to the home and, since 2024, the services of marriage and family therapists and mental health counselors.. The telehealth booklet layers on the audio-only condition: it is available when the patient is not capable of, or declines, two-way video 1Ref 1Centers for Medicare & Medicaid Services (2025).Telehealth Services.The permanent Medicare behavioral-health telehealth provisions, including the home as originating site, the audio-only condition when the patient cannot use or declines video, and the repeatedly postponed in-person-visit requirement..

One moving part deserves a flag. Medicare's behavioral-health telehealth rules include an in-person-visit requirement that Congress has repeatedly postponed. Confirm its current status in the MLN booklet before you rely on it, and treat any statement of that timing as of July 2026 as subject to the next extension 1Ref 1Centers for Medicare & Medicaid Services (2025).Telehealth Services.The permanent Medicare behavioral-health telehealth provisions, including the home as originating site, the audio-only condition when the patient cannot use or declines video, and the repeatedly postponed in-person-visit requirement..

How to tell a code is audio-only eligible

Do not guess whether a specific code pays as audio-only — look it up. CMS publishes a definitive list each year of the codes payable as Medicare telehealth, and the list marks which are permanent versus temporary and which carry audio-only eligibility 3Ref 3Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.That CMS publishes the definitive annual list of codes payable as Medicare telehealth, marking permanent versus temporary status and audio-only eligibility per code.. Before you bill a phone visit, confirm the exact code sits in the audio-only column of the current list rather than assuming the video rule carries over.

This is the artifact to bookmark: the current-year telehealth services list. A code that is telehealth-eligible by video is not automatically audio-only-eligible, and the two columns diverge. Checking the list takes a minute and turns a modality question into a lookup instead of a judgment call. Keep a short note of the exact codes in your regular mix that carry audio-only eligibility, and re-verify them when the list refreshes each year, because a code can move between the permanent and temporary columns from one year to the next and quietly change whether a phone visit still pays.

The modifier and place-of-service mechanics

Billing a phone visit correctly is a matter of matching the audio-only modifier to the right place-of-service code. HHS's telehealth billing guidance sets out the place-of-service and modifier conventions for telehealth, including the audio-only case 4Ref 4U.S. Department of Health and Human Services (2026).Billing for telehealth.The place-of-service and modifier conventions for telehealth billing, including the audio-only case and Medicare/Medicaid/private distinctions.. In practice that means an audio-only modifier appended to the code, paired with the place-of-service that reflects the patient at home rather than the office place-of-service you would use in person.

• The modifier signals the audio-only modality; modifier 93 is the common audio-only telehealth modifier, and some payers additionally want a distinct audio-only indicator.
• The place of service reflects where the patient is — the home place-of-service for a patient at home, not the in-office code.

Conventions shift between payers and program years, so treat the current HHS guidance and your payer's policy as the source of truth rather than last year's cheat sheet 4Ref 4U.S. Department of Health and Human Services (2026).Billing for telehealth.The place-of-service and modifier conventions for telehealth billing, including the audio-only case and Medicare/Medicaid/private distinctions..

HIPAA still applies to the phone call

A phone visit is still an electronic exchange of protected health information, and the COVID-era enforcement discretion that once relaxed the rules has ended. The HHS Office for Civil Rights maintains specific guidance on audio-only telehealth and expects it to run on HIPAA-compliant arrangements 5Ref 5HHS Office for Civil Rights (2026).HIPAA and Telehealth.That telehealth, including audio-only, must run on HIPAA-compliant arrangements now that the COVID enforcement discretion has ended, per OCR's audio-only telehealth guidance.. That guidance distinguishes an ordinary telephone line from smartphone apps and internet-based calling, so read it before you assume a personal cell phone clears the bar.

The practical takeaway: the modality being simpler than video does not make it exempt. Match your setup to the OCR audio-only guidance, and where a vendor or platform touches the call, confirm the business-associate arrangement covers it.

Where states diverge — commercial and Medicaid

Whether a commercial plan or a state Medicaid program pays for an audio-only visit is a state-by-state and plan-by-plan question, not a national rule. Federal telehealth policy makes the Medicare behavioral-health audio-only lane permanent but flags that many flexibilities remain temporary and can change 6Ref 6U.S. Department of Health and Human Services (2026).Telehealth policy.That the Medicare behavioral-health audio-only lane is permanent while many other telehealth flexibilities remain temporary and subject to change, as of July 2026.. Your state Medicaid manual and each commercial contract control whether the phone visit is covered at all — verify before the visit, not after the denial.

This is where audio-only sessions get providers into trouble: a code that pays for a Medicare patient may be denied for a commercially insured one down the hall. When a patient asks when are audio-only therapy sessions billable for their specific plan, the honest answer is that it depends on their coverage, and the cheapest way to find out is an eligibility check before you schedule.

Documentation that protects the audio-only claim

The note is what defends the claim if a payer questions the modality later. Record why video was not used — the patient lacked the technology, declined it, or the connection failed mid-visit — because that reason is the substantive condition for the audio-only lane, not a formality. For a prescriber's evaluation-and-management service, select the level by medical decision making or total time and document the elements that support it 7Ref 7Centers for Medicare & Medicaid Services (2023).Evaluation and Management Services Guide.That an E/M level is selected by medical decision making or total time under the 2021+ framework, and what must be documented to support the level chosen..

A dropped call is a common trigger for the audio-only lane: a video visit that fails and finishes by phone. Note the failure and the switch. And keep the modalities separate in your head — if the contact was asynchronous messaging rather than a live call, that is a different lane entirely, the online digital evaluation-and-management codes 99421–99423, with its own rules.