Guide

The telehealth billing matrix: POS × modifier × payer type

Summary

They combine along three axes: payer type, where the patient sits, and the service itself. Medicare wants the place-of-service that reflects the patient — the home POS or the other-than-home POS — plus modifier 95 for audio-video or 93 for audio-only. Commercial payers often want the office POS with modifier 95, or the telehealth POS; the contract controls. Medicaid rules are set by each state agency. Confirm the code is payable by telehealth before you pick any of it.

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

How do POS codes and modifiers combine on a telehealth claim?

POS codes and modifiers combine along three axes on a telehealth claim: the payer type, where the patient physically sits, and whether the visit was audio-video or audio-only. HHS's telehealth billing guidance sets the place-of-service and modifier conventions that tie those axes together 1Ref 1U.S. Department of Health and Human Services (2026).Billing for telehealth.The place-of-service and modifier conventions for telehealth billing, and the Medicare/Medicaid/private distinctions that make the combination payer-specific.. Get the combination right and the claim is clean; mismatch the place of service and the modifier and it denies or pays at the wrong rate.

The rest of this page takes the three axes one at a time — the place-of-service codes, the modifiers, and the payer-type matrix — then the two checks a biller runs before submitting: is the code payable by telehealth at all, and does the place of service match where the patient actually was.

The three place-of-service codes

Three place-of-service codes carry almost all telehealth claims: POS 11, 10, and 02. For Medicare, POS 10 marks a telehealth service delivered to the patient in the home, and POS 02 marks telehealth delivered somewhere other than the home — and the two pay differently, with the home code yielding the non-facility rate 2Ref 2Centers for Medicare & Medicaid Services (2025).Telehealth Services.Medicare telehealth billing specifics, including the home versus other-than-home place-of-service distinction and its effect on the payment rate.. The choice is not stylistic: it must reflect where the patient actually was, which is also the fact that drives licensure 3Ref 3U.S. Department of Health and Human Services (2026).Licensure — Telehealth policy.That the patient's location at the time of service is the fact that governs both the place-of-service code and the licensure that applies..

POS 10 — telehealth provided in the patient's home; on Medicare, the non-facility (higher) rate.
POS 02 — telehealth provided other than in the home; the facility rate.
POS 11 — the office code, which some commercial payers still expect paired with a telehealth modifier rather than a telehealth POS.

When a claim pays less than expected, the place-of-service code is the first thing to check.

The modifiers that ride the code

Two modifiers do most of the telehealth work: modifier 95 for a synchronous audio-video visit and modifier 93 for an audio-only visit. HHS's billing guidance is the reference for which modality convention a given program expects 1Ref 1U.S. Department of Health and Human Services (2026).Billing for telehealth.The place-of-service and modifier conventions for telehealth billing, and the Medicare/Medicaid/private distinctions that make the combination payer-specific.. Those telehealth modifiers rarely travel alone, though — a single claim can also carry credential-level modifiers, the locum modifier Q6, or the ABN modifiers GA, GZ, GY, each governed by its own separate rule.

The discipline is to keep the modality modifier (95 or 93) matched to what actually happened in the visit, and to let the other modifiers answer their own questions — who furnished the service, whether a substitute provider covered it, whether an advance beneficiary notice is on file. Stacking them without knowing what each one asserts is how a claim carries a contradiction a payer will catch.

The matrix, by payer type

Reading the matrix by payer type is the fastest way to keep the combinations straight. Medicare fixes the place-of-service to the patient's location and expects modality modifiers; commercial payers often diverge toward the office place-of-service with a telehealth modifier; Medicaid is set state by state. The table shows the common combinations — always subject to the specific contract or manual in front of you 2Ref 2Centers for Medicare & Medicaid Services (2025).Telehealth Services.Medicare telehealth billing specifics, including the home versus other-than-home place-of-service distinction and its effect on the payment rate..

Payer type	Place of service	Modifier	Notes
Medicare, audio-video	POS 10 (home) or POS 02 (other)	95	Home yields the non-facility rate; confirm the code is on the telehealth list 2Ref 2Centers for Medicare & Medicaid Services (2025).Telehealth Services.Medicare telehealth billing specifics, including the home versus other-than-home place-of-service distinction and its effect on the payment rate.
Medicare, audio-only	POS 10 or 02	93	Only where the code is audio-only-eligible, chiefly behavioral health
Commercial	Often POS 02, or POS 11 with a telehealth modifier	95 or 93	Follow the payer's published telehealth policy; conventions vary by plan and contract
Medicaid	Set by the state agency	State-defined	Each state's manual and fee schedule control 6Ref 6California Department of Health Care Services (2026).California Department of Health Care Services.That California Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid place-of-service and modifier rules are set state by state.7Ref 7Texas Health and Human Services Commission (2026).Texas Medicaid & Healthcare Partnership (TMHP).That Texas Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid billing rules differ from state to state and from Medicare.

No row is a rule you can carry to the next payer unchanged. The matrix is a starting grid, and the contract or manual is the authority.

Confirm the code is payable before you pick a modifier

None of the combinations matter if the code itself is not payable by telehealth. CMS publishes the definitive annual list of codes payable as Medicare telehealth, including which are permanent versus temporary and which are audio-only eligible 4Ref 4Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.That CMS publishes the definitive annual list of codes payable as Medicare telehealth, including permanent-versus-temporary status and audio-only eligibility, used to confirm a code is payable before billing.. Check the current list first, then choose the place of service and modifier — sequencing it the other way is how a biller ends up with a technically perfect claim for a code the program will not pay.

Build the check into your intake: before a telehealth code is added to the fee ticket, confirm it appears on the current-year list in the modality you delivered. It is a one-minute lookup that prevents a clean-looking denial.

Behavioral-health specifics

Behavioral health has its own settled telehealth footing, which simplifies the matrix for a solo mental-health practice. 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 5Ref 5Centers for Medicare & Medicaid Services (2025).Medicare and Mental Health Coverage.That Medicare covers psychiatric diagnostic evaluation and psychotherapy to the home and, since 2024, the services of marriage and family therapists and mental health counselors — the codes that dominate a solo behavioral-health claim mix.. That means the home place-of-service and the audio-video modifier are the everyday combination for these codes, with audio-only sessions available in the narrower lane the telehealth rules define.

For a behavioral-health biller-of-one, that stability is the point: the same POS-and-modifier pairing repeats across most visits, so the exceptions — a new-patient evaluation, an audio-only session, a patient seen outside the home — are the ones worth double-checking rather than every claim.

Medicaid: fifty manuals, not one rule

Medicaid is the one axis the matrix cannot flatten, because each state Medicaid agency sets its own place-of-service and modifier rules. California's Department of Health Care Services and Texas's Medicaid & Healthcare Partnership each publish their own provider manuals and fee schedules, and they do not have to match 6Ref 6California Department of Health Care Services (2026).California Department of Health Care Services.That California Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid place-of-service and modifier rules are set state by state.7Ref 7Texas Health and Human Services Commission (2026).Texas Medicaid & Healthcare Partnership (TMHP).That Texas Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid billing rules differ from state to state and from Medicare.. Before billing a Medicaid telehealth claim, pull that state's current manual rather than assuming the Medicare combination carries over.

The practical rule for a biller-of-one: keep a short reference of the exact POS-and-modifier expectation for each Medicaid program you actually bill, sourced from that state's manual, and refresh it when the program updates. One saved lookup per state beats a generic recipe that denies in half of them.

Common questions

For Medicare, use POS 10 when the patient is in the home and POS 02 when the patient is somewhere other than the home; the two pay at different rates, with the home code yielding the higher non-facility rate. Some commercial payers instead want the office POS 11 with a telehealth modifier. The place of service must reflect where the patient actually was.

Modifier 95 signals a synchronous audio-video telehealth service; modifier 93 signals an audio-only service. Use 95 when the visit ran on two-way video and 93 when it was voice only, and only where the code is audio-only eligible. HHS billing guidance and each payer's policy set which modifier a given program expects, so confirm before submitting.

No. Medicare ties the place of service to the patient's location and expects a modality modifier; many commercial payers prefer the office place of service with a telehealth modifier; and Medicaid rules are set by each state agency. Treat the combination as payer-specific and verify against the contract or state manual rather than reusing one recipe everywhere.

Check the CMS list of telehealth services for the current year. It names the codes payable as Medicare telehealth, marks which are permanent versus temporary, and shows audio-only eligibility. Confirm the code is on the list before choosing the place of service and modifier, because a perfect claim for a non-covered code still denies.

The most common cause is the place-of-service code. Under Medicare, the home telehealth POS pays the non-facility rate while the other-than-home POS pays the facility rate, so the same code can pay two different amounts. Confirm the POS matches where the patient actually was, and check that the modifier and code are consistent with the payer's telehealth policy.

Run your practice on Gale

The software is free. Gale earns one flat 3.5% all-in per paid transaction — only on transactions that actually pay. No subscription, no setup fee, no network cut.

Start or manage a practice →

References

1.U.S. Department of Health and Human Services (2026). Billing for telehealth. Telehealth.HHS.gov. linkThe place-of-service and modifier conventions for telehealth billing, and the Medicare/Medicaid/private distinctions that make the combination payer-specific.
2.Centers for Medicare & Medicaid Services (2025). Telehealth Services. CMS Medicare Learning Network (MLN901705). link ✓Medicare telehealth billing specifics, including the home versus other-than-home place-of-service distinction and its effect on the payment rate.
3.U.S. Department of Health and Human Services (2026). Licensure — Telehealth policy. Telehealth.HHS.gov. linkThat the patient's location at the time of service is the fact that governs both the place-of-service code and the licensure that applies.
4.Centers for Medicare & Medicaid Services (2026). List of Telehealth Services. Centers for Medicare & Medicaid Services (CMS). link ✓That CMS publishes the definitive annual list of codes payable as Medicare telehealth, including permanent-versus-temporary status and audio-only eligibility, used to confirm a code is payable before billing.
5.Centers for Medicare & Medicaid Services (2025). Medicare and Mental Health Coverage. CMS Medicare Learning Network (MLN1986542). link ✓That Medicare covers psychiatric diagnostic evaluation and psychotherapy to the home and, since 2024, the services of marriage and family therapists and mental health counselors — the codes that dominate a solo behavioral-health claim mix.
6.California Department of Health Care Services (2026). California Department of Health Care Services. California Department of Health Care Services. link ✓That California Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid place-of-service and modifier rules are set state by state.
7.Texas Health and Human Services Commission (2026). Texas Medicaid & Healthcare Partnership (TMHP). Texas Health and Human Services Commission. link ✓That Texas Medicaid publishes its own provider manuals and fee schedules, cited as a named example that Medicaid billing rules differ from state to state and from Medicare.

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

← Back to for providers