Are your telehealth claims still following emergency-era billing practices? In 2026, CMS continues to update Medicare telehealth policies, including place of service and service-specific billing requirements. For example, Medicare professional claims use POS 02 when the patient is receiving telehealth somewhere other than home and POS 10 when the patient is at home.
These telehealth billing and coding guidelines also require attention to important 2026 changes. CMS states that, beginning October 1, 2026, Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) must report the individual CPT or HCPCS code for a distant-site telehealth service instead of G2025, using Modifier 93 for qualifying audio-only services or Modifier 95 for real-time audio-video services. The CY 2026 RHC/FQHC telehealth payment rate is $97.53.
These updates can help billing teams make more precise coding and claim-review decisions, but they also create a risk if older emergency-era workflows are applied automatically. Payer, provider type, service modality, and date of service can affect the correct billing approach.
This guide explains POS 02 vs. 10, Modifier 95, Modifier 93, virtual check-ins, e-visits, and commercial payer requirements so billers and coders can review each claim using the rules that apply to it.
Telehealth Billing and Coding Guidelines After Emergency-Era Flexibilities
Emergency-era telehealth policies changed how remote care was delivered and billed. In 2026, billing teams must check the date of service, payer, patient location, service type, and provider setting before applying an older workflow.
Why Emergency-Era Telehealth Workflows Cannot Be Assumed to Continue
Temporary telehealth provisions do not automatically remain active after an emergency period. CMS updates its Medicare telehealth service list through the annual Physician Fee Schedule, so a code or billing rule used during the COVID-19 period should not be treated as a permanent requirement.
For each claim, billers should verify:
Patient location: Determine whether POS 02 or POS 10 applies.
Modality: Confirm whether the service was audio-video, audio-only, or another virtual service.
Date of service: Apply the rule effective on that date.
Payer: Medicare, Medicaid, and commercial plans may have different requirements.
Documentation: Confirm that the record supports the reported service and modality.
What Changed for Medicare Telehealth in 2026?
Medicare telehealth rules saw important changes during 2026. CMS’s current materials show that Congress extended certain telehealth flexibilities, while other requirements changed based on provider type and service.
One major update affects RHCs and FQHCs. For dates of service on or after October 1, 2026, they must report the individual CPT or HCPCS code for eligible distant-site telehealth services instead of G2025. Modifier 93 identifies qualifying synchronous audio-only services, while Modifier 95 identifies synchronous audio-video services. The CY 2026 payment rate is $97.53.
CMS also reports a $31.85 Medicare telehealth originating-site facility fee (Q3014) for 2026.
Start With the Type of Virtual Service
The first coding decision is to determine what actually happened during the virtual contact. Audio-video visits, audio-only services, virtual check-ins, and e-visits have different coding requirements.
Before choosing a CPT or HCPCS code, confirm the modality, patient initiation, duration or clinical work, payer, and date of service. This reduces the risk of reporting a full telehealth visit for a service that fits a shorter digital-service code.
Synchronous Audio-Video Visits
A real-time audio-video encounter allows the practitioner and patient to communicate interactively. Depending on the payer and service, the claim may require an appropriate telehealth CPT/HCPCS code, POS, and modifier.
For Medicare, billers should verify the current telehealth services list and applicable POS requirements before submission. CMS updates the Medicare telehealth list through annual Physician Fee Schedule rulemaking.
Synchronous Audio-Only Services
Audio-only encounters should not automatically be coded like audio-video visits. Modifier 93 identifies synchronous telemedicine delivered through telephone or another real-time interactive audio-only system in applicable billing settings.
Always confirm whether the payer recognizes the service and modifier for the specific date of service.
Virtual Check-Ins
CPT 98016 covers a brief synchronous communication technology-based service involving 5–10 minutes of medical discussion for an established patient, subject to its coding requirements. It is distinct from a routine communication or a service that leads to a more extensive encounter.
E-Visits and Patient-Initiated Digital Services
Patient-initiated online evaluation and management services may fall under CPT 99421–99423, depending on the documented service and applicable payer policy. Review the communication period and documentation before reporting the code.
For every virtual claim, verify:
- Service modality
- Patient initiation
- CPT/HCPCS eligibility
- POS
- Modifier
- Payer policy
- Documentation
Place of Service Code 02 vs. 10 Billing
Choosing the correct POS code is a basic but important step in telehealth billing and coding guidelines. The deciding factor is where the patient receives the service, not the provider’s physical location.
A wrong POS can affect claim processing and reimbursement. Before submission, confirm the patient’s location, payer, service type, and applicable date-of-service rules.
When to Use POS 10
POS 10 – Telehealth Provided in a Patient’s Home applies when the patient is receiving the telehealth service from their private residence. Medicare began using POS 10 for home-based telehealth effective January 1, 2024, and pays these services at the Medicare Physician Fee Schedule non-facility rate.
Billers should verify that the documentation supports the patient’s home location rather than selecting POS 10 simply because the encounter was virtual.
POS 02 vs. POS 10: Quick Comparison
| Billing Point | POS 02 | POS 10 |
| Patient location | Other than home | Patient’s home |
| Telehealth | Yes | Yes |
| Medicare professional claims | Applicable | Applicable |
| Key check | Confirm non-home location | Confirm private residence |
| Reimbursement | Verify payer policy | Medicare uses non-facility PFS rate |
Modifier 95 Telehealth Reimbursement: What Billers Should Check
Modifier 95 is commonly associated with real-time audio-video telehealth, but adding it does not automatically make a claim payable. Billers must first confirm the payer, claim type, service, POS, and date of service.
A strong claim review separates modality identification from reimbursement eligibility. This helps prevent outdated modifier rules from being applied to current claims.
When Modifier 95 May Apply
Modifier 95 describes a synchronous telemedicine service delivered through real-time interactive audio and video telecommunications technology. CMS currently specifies its use in certain RHC and FQHC billing situations, including the 2026 transition to individual CPT/HCPCS reporting.
Before reporting 95, verify:
- The encounter used real-time audio-video communication.
- The reported service is eligible for telehealth.
- The payer recognizes Modifier 95 for that claim.
- The POS and CPT/HCPCS code are correct.
- Documentation supports the service provided.
Modifier 95 vs. Modifier 93
The main distinction is the communication method:
| Modifier | Service |
| 95 | Only audio-video |
| 93 | Only audio-only |
Virtual Check-In and E-Visit CPT Codes
Virtual check-ins and e-visits are different services, even though both can occur without a traditional office visit. Correct coding depends on how the patient initiated the interaction, the work performed, the time involved, and the relationship to other E/M services.
CPT 98016 for Brief Communication Technology-Based Services
CPT 98016 describes a brief synchronous communication technology-based service for an established patient. The service involves medical discussion and has specific requirements that must be met before reporting it. AMA coding guidance also indicates that the service should not be reported when it leads to a more extensive E/M service within the applicable period.
Before reporting 98016, check:
- Patient status and initiation requirements
- Documented medical discussion
- Applicable time requirements
- Whether another E/M service is related
- Payer recognition and payment policy
CPT 99421–99423 for Online Digital Evaluation and Management
CPT 99421–99423 covers patient-initiated online digital E/M services for established patients, with cumulative practitioner time measured over a 7-day period:
99421: 5–10 minutes
99422: 11–20 minutes
99423: 21 minutes or more
CMS describes these as patient-initiated portal communications that involve evaluation and management.
When a Virtual Check-In Should Not Be Reported Separately
Do not report a virtual service simply because communication occurred. Routine scheduling, administrative messages, or communication that does not meet the code requirements should not be treated as a separately payable E/M service.
Avoiding Duplicate Reporting With an E/M Service
Review recent and subsequent encounters before billing. AMA guidance states that 99421–99423 should not be separately reported for a related patient-initiated inquiry within seven days of a previous E/M service, or when the digital service leads to an E/M service within the applicable period.
Commercial Payer Telehealth Rules
Commercial payer telehealth rules can differ from Medicare requirements for covered services, POS codes, modifiers, audio-only care, and reimbursement. A code that processes correctly for one payer may require different claim data for another.
For accurate telehealth billing and coding guidelines, billers should check the payer’s current policy and the member’s benefits before claim submission.
Verify the Payer’s Current Requirements
Commercial plans may specify their own requirements for telehealth claims. For example, BCBS North Dakota’s 2026 policy requires POS 02 or 10 for applicable distant-site telehealth and has specific modifier requirements that changed during 2026.
Before billing, confirm:
1. Covered telehealth services and CPT/HCPCS codes
2. Audio-video versus audio-only coverage
3. Required POS code
4. Modifier 95, 93, or another applicable modifier
5. Prior authorization requirements
6. Provider eligibility and network status
7. Patient benefits and cost-sharing
8. Documentation requirements
Do Not Copy Medicare Rules Into Every Commercial Claim
Medicare guidance is a useful reference, but it does not establish every commercial payer’s reimbursement policy. HHS specifically notes that private insurance policies can differ and that telehealth coding guidance may change.
Some commercial plans have also adopted new telehealth E/M codes at different times. For example, Highmark announced adoption of CPT 98000–98015 for certain commercial plans effective September 1, 2026, while applying specific POS requirements.
Build a Payer-Specific Claim Check
For each commercial claim, confirm:
1. Payer and plan
2. Date of service
3. Patient location
4. Modality
5. Eligible CPT/HCPCS code
6. POS requirement
7. Modifier requirement
8. Authorization or benefit restrictions
Conclusion
Accurate telehealth billing starts with identifying the service, patient location, modality, payer, and date of service. Applying current telehealth billing and coding guidelines helps billers avoid outdated emergency-era rules and prevent common claim errors.
POS 02 versus POS 10, Modifier 95 or 93, virtual check-ins, and e-visit codes each have specific requirements. Commercial payer policies can also differ from Medicare, making payer verification an important part of claim review.
For 2026 claims, billing teams should keep coding references current and confirm requirements before submission. A consistent review process supports accurate coding, appropriate reimbursement, and cleaner claims.
FAQs
What are the current telehealth billing and coding guidelines?
Current telehealth billing and coding guidelines require billers to verify the service type, modality, patient location, payer, date of service, CPT or HCPCS code, POS code, modifier, and documentation before submitting a claim.
What is the difference between POS 02 and POS 10 for telehealth?
POS 02 is used when telehealth is provided to a patient somewhere other than their home. POS 10 applies when the patient receives telehealth in their home. The correct POS depends on the patient’s location at the time of service.
When should Modifier 95 be used for telehealth?
Modifier 95 identifies synchronous telemedicine delivered through real-time interactive audio and video when required or accepted by the applicable payer and billing setting. Billers should verify payer-specific requirements before adding it to a claim.
What CPT codes are used for virtual check-ins and e-visits?
CPT 98016 may be used for qualifying brief synchronous communication technology-based services. CPT 99421–99423 cover patient-initiated online digital E/M services based on cumulative practitioner time over a seven-day period, subject to applicable coding and payer requirements.
Do commercial payers follow Medicare telehealth billing rules?
No. Commercial payer telehealth policies can differ from Medicare regarding covered services, CPT/HCPCS codes, POS codes, modifiers, authorization, and reimbursement. Billing teams should verify the current policy for the specific payer and plan.
