What Is Medicare Telehealth?
Medicare covers telehealth services furnished via interactive real-time telecommunications technology between a distant site provider and a patient at an eligible originating site. Coverage is governed by Section 1834(m) of the Social Security Act and administered by CMS under the Medicare Physician Fee Schedule (PFS).
Prior to COVID-19, telehealth was restricted to rural and underserved geographic areas. Pandemic-era flexibilities substantially expanded access. While Congress has extended those expansions multiple times, they remain subject to ongoing legislative action and are not permanent for most services.
The Centers for Medicare and Medicaid (CMS) has several recent changes beginning January 1, 2024. These changes included CPT codes, HCPCS code, telehealth service provider and an additional location for telehealth services. Medicare Telehealth services include CPT codes 0591T – 0593T for health and well-being coaching services, which we are adding on a temporary basis and HCPCS code G0136 for Social Determinants of Health Risk Assessment, which we are adding on a permanent basis.
With, the temporary expansion of the scope of telehealth originating site of service to now include a person’s home as an originating site with the U. S. Telehealth practitioner types expand to occupational therapists (OTs), physical therapists (PTs), speech-language pathologists (SLPs), and audiologists. Also adding mental health counselors (MHCs) and marriage and family therapists (MFTs) as distant site practitioners for purposes of providing telehealth services.
CMS gives clarification of modifier ’95’ stating it should be used when the clinician is in the hospital and the patient is in the home, as well as for outpatient therapy services provided via telehealth by PT, OT, or SLPs. While, delaying the requirement for an in-person visit with the physician or practitioner within 6 months prior to initiating mental health telehealth services, and, again, at subsequent intervals as the Secretary determines appropriate, as well as similar requirements for RHCs and FQHCs. The continued coverage and payment of telehealth services included on the Medicare Telehealth Services List (as of March 15, 2020) until December 31, 2026.
Key Terms Every Biller Must Know
| Term | Definition |
|---|---|
| Originating Site | The location where the Medicare beneficiary (patient) receives the telehealth service |
| Distant Site | The location where the physician or practitioner providing the service is located |
| POS 02 | Place of Service: telehealth provided OTHER than in patient’s home — paid at facility rate |
| POS 10 | Place of Service: telehealth provided IN patient’s home — paid at non-facility rate (higher) |
| Modifier 95 | Synchronous audio-video telehealth service |
| Modifier 93 | Synchronous audio-only (telephone) telehealth service — required by Medicare for audio-only |
| Modifier FQ | Audio-only service — used by FQHCs and RHCs; identical meaning to Modifier 93 |
| Modifier GT | CAH Method II practitioners and institutional claims ONLY |
| PHE | Public Health Emergency — COVID-19 PHE period that triggered expanded telehealth rules |
| CTBS | Communication Technology-Based Services — virtual check-ins, e-visits; not subject to originating site restrictions |
Who Can Bill Medicare for Telehealth?
The following provider types are permanently eligible to bill Medicare as distant site telehealth providers. All are subject to state licensing requirements and must be separately enrolled in Medicare for each state where they provide services.
- Physicians (MD/DO)
- Physician Assistants (PA)
- Nurse Practitioners (NP)
- Clinical Nurse Specialists (CNS)
- Certified Registered Nurse Anesthetists (CRNA)
- Certified Nurse-Midwives
- Clinical Psychologists
- Clinical Social Workers
- Registered Dietitians or Nutrition Professionals
- Marriage and Family Therapists (MFT)
- Mental Health Counselors
- Physical Therapists (PT) — tied to flexibility extension period
- Occupational Therapists (OT) — tied to flexibility extension period
- Speech Language Pathologists (SLP) — tied to flexibility extension period
- Audiologists — tied to flexibility extension period
Originating Site Requirements
An originating site is where the patient is physically located when receiving the telehealth service. Under standard Medicare law (Section 1834(m)), originating site eligibility is geographically restricted to rural and underserved areas. These restrictions are waived during active flexibility extension periods.
Standard Geographic Requirements (When Flexibilities Expire)
Without an active Congressional extension, patients must be located in:
- A county outside a Metropolitan Statistical Area (MSA), OR
- A rural Health Professional Shortage Area (HPSA) in a rural census tract
Use the HRSA Medicare Telehealth Payment Eligibility Analyzer to check originating site geographic eligibility by ZIP code.
Eligible Originating Site Types
| Originating Site | Notes |
|---|---|
| Physician or practitioner office | Standard outpatient setting |
| Hospital (inpatient and outpatient) | |
| Critical Access Hospital (CAH) | Method I and Method II billing rules apply |
| Rural Health Clinic (RHC) | Special billing rules — see Section 7 |
| Federally Qualified Health Center (FQHC) | Special billing rules — see Section 7 |
| Skilled Nursing Facility (SNF) | Patient is NOT considered “in their home” — use POS 02 |
| Community Mental Health Center (CMHC) | Mental health services only |
| Renal Dialysis Facility | Home dialysis patients only |
| Hospital-based renal dialysis center | Includes satellites and self-dialysis units |
| Patient’s Home (POS 10) | Permanently expanded for BH/MH and SUD services; tied to flexibility period for others |
Permanent Exceptions — No Geographic Restriction Required
Congress permanently removed geographic and originating site restrictions for the following services, regardless of the status of any flexibility extension:
- Behavioral and mental health (BH/MH) services — patients can receive these from home in any geographic area
- Substance Use Disorder (SUD) treatment — same permanent home/any-geography rule
- Treatment of Acute Stroke
- ESRD monthly clinical assessments — patient home is a permanent originating site
2025 Medicare Telehealth Coding — Critical Rules
E/M Telehealth Billing — Audio-Video vs Audio-Only
| Service Type | CPT Code | Modifier | POS Code | Payment Rate |
|---|---|---|---|---|
| New patient E/M — audio/video | 99202–99205 | 95 (recommended; POS code is sufficient for Medicare) | POS 10 (home) or POS 02 (other site) | Non-facility (POS 10) / Facility (POS 02) |
| Established patient E/M — audio/video | 99211–99215 | 95 (recommended) | POS 10 or POS 02 | Non-facility / Facility |
| Audio-only E/M (patient in home, video unavailable/declined) | 99202–99215 | 93 — REQUIRED | POS 10 only | Non-facility rate |
| Prolonged service add-on | +99417 | Same as base E/M | Same as base | Per PFS schedule |
| Brief virtual check-in (established patient, 5-10 min) | 98016 | None required | POS 10 or POS 02 | ~$15.85 non-facility (unadjusted) |
Deleted & Replaced Codes — Effective January 1, 2025
| Deleted Code | Previous Description | What to Use Instead in 2025 |
|---|---|---|
| 99441 | Telephone E/M, 5-10 min | 99202-99215 with Modifier 93 (audio-only, patient in home only) |
| 99442 | Telephone E/M, 11-20 min | 99202-99215 with Modifier 93 |
| 99443 | Telephone E/M, 21-30 min | 99202-99215 with Modifier 93 |
| G2012 | Brief virtual check-in | 98016 — Brief communication technology-based service (5-10 min, established patients) |
| NOTE: CPT codes 99441-99443 were deleted by the AMA effective January 1, 2025. CMS did not create replacement HCPCS codes. Update all billing templates and charge master entries immediately. Audio-only phone visits for Medicare patients in their home now bill as standard E/M (99202-99215) with Modifier 93. |
Modifier Quick Reference
| Modifier | Full Description | When to Use | Required by Medicare? |
|---|---|---|---|
| 95 | Synchronous telehealth — real-time audio AND video | Audio-video telehealth visits | Optional — POS code alone is sufficient for Medicare, but append for clarity |
| 93 | Synchronous telehealth — real-time audio-only (telephone) | Audio-only visits to patients in their home (provider capable of video, patient declined or cannot) | YES — required on all audio-only Medicare claims |
| FQ | Service furnished using audio-only communication technology | FQHCs and RHCs billing audio-only; use alongside or instead of 93 | YES for FQHCs/RHCs — use FQ and/or 93 |
| GT | Via interactive audio and video telecommunications systems | CAH Method II practitioners on institutional claims ONLY | Yes — CAH Method II only. Do NOT use on standard professional claims |
| FR | Supervising practitioner present via two-way audio/video | Direct supervision delivered via telehealth | Situational — use when applicable supervision scenario applies |
Place of Service (POS) — Billing & Payment Rules
| POS Code | Description | Patient Location | Payment Rate | Common Error |
|---|---|---|---|---|
| POS 02 | Telehealth — not in patient’s home | Clinic, hospital, SNF, school, any non-home site | Facility rate (lower) | Using POS 02 when patient is at home — results in underpayment |
| POS 10 | Telehealth — in patient’s home | Private residence (includes assisted living where patient lives) | Non-facility rate (higher) | Using POS 10 when patient is at SNF — results in overpayment and compliance risk |
| NOTE: POS 10 (non-facility rate) pays MORE than POS 02 (facility rate). Always confirm and document the patient’s exact physical location before selecting a POS code. SNFs are NOT the patient’s home for POS purposes. Assisted living facilities where the patient lives ARE considered the patient’s home. POS 10 does not apply to originating site facilities billing a facility fee. |
Audio-Only Telehealth in 2025
Conditions Required for Audio-Only Billing
ALL of the following must be true:- Patient is located in their home (POS 10 applies)
- The distant site provider is technically capable of using an audio-video interactive system
- The patient is not capable of using video technology, OR
- The patient does not consent to the use of video technology
| NOTE: The provider MUST be technically capable of audio-video technology. A provider who simply lacks the equipment cannot bill audio-only. The documentation must confirm both capability and the patient-side barrier. This requirement does not apply to behavioral health audio-only, which is permanent and unrestricted. |
Audio-Only Restrictions from October 1, 2025
Beginning October 1, 2025, Medicare audio-only telehealth is restricted to mental/behavioral health and substance use disorder services provided to patients in their home. All other audio-only telehealth services are subject to the flexibility extension status after this date. Confirm active extension before billing.Documentation Requirements — Audio-Only (Non-BH)
| Documentation Element | Required? |
|---|---|
| Provider has audio-video capability available | YES — must be stated |
| Reason for audio-only: patient lacks video capability OR patient declined | YES — document which applies |
| Standard E/M documentation (MDM or time) | YES |
| Duration of encounter (if billing by time) | YES — document total time |
| Standard clinical note (history, assessment, plan) | YES |
| NOTE: BEHAVIORAL HEALTH EXCEPTION: For BH/MH and SUD audio-only services, documentation does NOT need to explain why audio-only was used. Audio-only is permanently and unconditionally available for these services. No exception rationale required. |
Audio-Only Billing Summary
| Element | 2025 Rule |
|---|---|
| CPT code to use | 99202-99215 (standard office E/M — NOT 98008-98015 which Medicare will deny) |
| Modifier required | Modifier 93 — required on every audio-only Medicare claim |
| POS code | POS 10 — patient must be in their home; audio-only to non-home sites is not covered |
| FQHCs and RHCs | Append Modifier FQ (and/or 93) — both acceptable; check MAC guidance |
| 10-minute minimum? | No minimum for office E/M codes. If billing by time, document total minutes. |
| Audio-only to SNF or hospital? | Not covered — audio-only is only permitted for patients in their home (POS 10) |
Permanent Behavioral Health Rules
Congress permanently removed geographic and originating site restrictions for behavioral and mental health telehealth. These rules apply regardless of whether the general COVID-19 telehealth flexibilities are in effect.
Requirement | Standard Telehealth | BH / MH / SUD Telehealth |
|---|---|---|
Geographic restriction | Rural/HPSA required (without extension) | NONE — any location, urban or rural |
Patient location (originating site) | Must be eligible facility (without extension) | Patient’s home is permanently allowed |
Audio-only permitted | Home only; video must be unavailable/declined; expires Oct 1 2025 without extension | Permanently permitted — no documentation of exception required |
Inpatient/NF frequency limits | Apply without extension | Permanently removed (CY 2026 Final Rule) |
In-Person Visit Requirements for Mental Health Telehealth (Patient’s Home)
For mental health services furnished to patients in their home, Medicare requires periodic in-person visits:
- Initial in-person visit: Required within 6 months PRIOR to the first mental health telehealth service in the home (waived through September 30, 2025 under flexibility extension)
- Annual in-person visit: Required within 12 months of each subsequent mental health telehealth service in the home (also waived through September 30, 2025)
- Who can perform it: Physician or practitioner of the same specialty within the same group practice, if the telehealth provider is unavailable
NOTE: FQHC/RHC EXCEPTION: The in-person visit requirement for mental health telehealth to beneficiaries in their home is NOT required for FQHCs and RHCs until January 1, 2026. |
FQHC & RHC Telehealth Billing
Billing Element | FQHC / RHC Rule |
|---|---|
Non-behavioral health telehealth | Bill HCPCS code G2025 for non-BH services furnished via telehealth technology |
Behavioral health telehealth | Align with PFS requirements for BH telehealth; follow same PFS rules |
Audio-only modifier | Use Modifier FQ (and/or Modifier 93) for audio-only services |
In-person BH visit requirement | Not required until January 1, 2026 (extended beyond general September 30, 2025 waiver) |
Originating site facility fee | FQHCs/RHCs may bill Q3014 when serving as originating site (where applicable) |
Geographic requirements | Same general rules apply — waived during active flexibility period |
CAH Method II Telehealth
Critical Access Hospital (CAH) practitioners billing under Method II for distant site telehealth services should use Modifier GT on institutional claims and bill in revenue codes 096x, 097x, or 098x. The CAH bills its A/B MAC (A) directly for professional services provided at the distant site via telecommunications.
Top Medicare Telehealth Billing Mistakes in 2025
| Error | Root Cause | Fix |
|---|---|---|
| Billing 98000-98015 to Medicare | New AMA CPT codes published in 2025 book — billers assume Medicare adopted them | Medicare denies all 98000-98015. Remove from Medicare payer templates. Use 99202-99215. |
| Using deleted codes 99441-99443 | Old billing templates not updated after Jan 1, 2025 | Purge 99441-99443 from all charge master entries and billing templates immediately. |
| Wrong POS code (02 vs 10) | Not confirming patient’s exact location before billing | Always document patient location in the note. SNF = POS 02. Home = POS 10. |
| Missing Modifier 93 on audio-only | Applying Modifier 95 by default on all telehealth | Create separate billing templates for audio-video (Mod 95) and audio-only (Mod 93). |
| Audio-only without exception documentation | Provider documents the clinical note; biller doesn’t add exception note | Add a documentation checklist: Was video available? Did patient decline/lack capability? Note it. |
| Billing telehealth for non-listed service | Not checking CMS List of Telehealth Services | Always verify CPT is on the CMS telehealth list before billing with POS 02 or 10. |
| Applying geographic restriction to BH services | Confusing general rules with permanently waived BH rules | BH/MH/SUD telehealth has NO geographic restriction — permanently. Flag in payer setup. |
| Billing 98016 (new check-in) for new patients | 98016 is established patients only | 98016 requires prior relationship. For new patients, apply appropriate E/M or decline telehealth. |
How to Bill Every Medicare Telehealth Claim
STEP 1 — Is this service on the CMS List of Telehealth Services?
- Yes → Proceed to Step 2
- No → Do NOT bill with POS 02 or 10. Consider if the service qualifies as a CTBS (e.g., 98016 virtual check-in) or bill as a regular in-person service.
STEP 2 — What technology was used?
- Audio + video → Use Modifier 95 (or no modifier; POS drives payment for Medicare) → Go to Step 3
- Audio-only → Use Modifier 93 → Confirm patient is in home → Document provider capability + patient reason → Go to Step 3
STEP 3 — Where is the patient located?
- Patient’s home → POS 10 → Paid at non-facility rate (higher)
- Clinic, hospital, SNF, school, any non-home site → POS 02 → Paid at facility rate (lower)
STEP 4 — Is this a behavioral/mental health or SUD service?
- Yes → No geographic restriction. Patient home is permanent originating site. Audio-only is permanently allowed without exception documentation.
- No → Confirm flexibility extension is active OR patient is in eligible rural/HPSA area. Check audio-only eligibility date.
STEP 5 — Is the provider an FQHC or RHC?
- Yes → Use G2025 for non-BH services. Use Modifier FQ for audio-only. Follow FQHC/RHC billing rules in Section 7.
- No → Bill 99202-99215 with modifier and POS determined in Steps 2-3.
STEP 6 — Final claim check
- Service is on CMS Telehealth List
- Correct E/M code selected (99202-99215; NOT 98000-98015)
- Correct modifier applied (93 for audio-only / 95 for audio-video)
- POS code matches patient location (02 or 10)
- Audio-only exception documented if applicable
- Provider enrolled in the state where service was rendered
