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How to Bill Telehealth Therapy Sessions: Codes, POS and Modifiers

A practical guide for therapy and behavioral health practices

Telehealth is now a normal part of how therapy is delivered, but billing for it is still one of the most confusing parts of running an insurance-based practice. The CPT codes are usually the same as for in-person sessions. What changes is the place of service code, the modifiers, and each payer's rules about what it covers. Get those wrong and a perfectly good session can be denied or underpaid.

This guide explains the main elements of a telehealth therapy claim and how to keep them straight across payers.

Start with the same service codes

For most telehealth psychotherapy, you bill the same CPT code you would for the same service in person:

• 90791 / 90792 for psychiatric diagnostic evaluation (90792 includes medical services)
• 90832, 90834, 90837 for individual psychotherapy, chosen by documented time
• 90846 / 90847 for family psychotherapy without or with the patient present
• 90853 for group psychotherapy (check payer coverage for telehealth groups)
• 90785 as the interactive complexity add-on, where it applies

The service and its documentation requirements don't change because the session is on video. Time-based codes still need the time documented, and the note still needs to support medical necessity.

Most payers also want the documentation to show that the session was delivered via telehealth, the modality (audio-video or audio-only), and where the patient and clinician were located. Some payers and states also have specific consent requirements.

Place of service (POS) codes

The place of service code tells the payer where the service was delivered. For telehealth there are two main codes:

• POS 02: telehealth provided somewhere other than the patient's home
• POS 10: telehealth provided in the patient's home

Medicare introduced POS 10 in 2022, and many commercial payers adopted it. However, payers differ on which POS they want and how they pay for it. Some pay telehealth at the facility rate, some at the non-facility rate. Some commercial payers ask you to use the POS you would have used in person (such as 11 for office) together with a telehealth modifier.

Practical tip: Don't assume one rule fits all. Check each major payer's current telehealth policy and record its preferred POS in a payer grid.

Telehealth modifiers

Modifiers tell the payer how the service was delivered. The common ones in behavioral health are:

• Modifier 95: synchronous telehealth service delivered by real-time audio and video
• Modifier 93: synchronous telehealth delivered by audio only (telephone), where the payer allows it
• Modifier FQ: used by Medicare to indicate a service furnished using audio-only communication
• Modifier GT: an older "via interactive audio and video" modifier that some Medicaid programs and legacy payer policies still ask for

Which modifier is required, and whether one is required at all, depends on the payer. Some payers deny claims without modifier 95. Others ignore it, and some reject claims that use the wrong combination of POS and modifier.

Audio-only sessions

Audio-only therapy has been important for clients without reliable video access. Many payers cover audio-only behavioral health services in some circumstances, but the rules are stricter: some limit which codes can be billed audio-only, some require that video was offered first or wasn't possible, and some don't cover it at all. Documentation should clearly state that the session was audio-only and why.

Medicare, Medicaid and commercial differences

• Medicare has its own telehealth rules, including rules on in-home behavioral health telehealth and, in some cases, in-person visit requirements. Several of these have been changed and extended by Congress and CMS over recent years, so check the current CMS guidance before billing Medicare telehealth.
• Medicaid telehealth rules are set state by state, and managed care plans within a state can add their own requirements. In Texas, for example, check Texas Medicaid (TMHP) guidance and each managed care plan's policy.
• Commercial payers publish their own telehealth reimbursement policies. Some follow Medicare conventions and some don't.

Because the rules differ so much, keeping a single up-to-date payer grid is one of the most valuable billing habits a practice can have.

Licensing and location

The clinician generally needs to be licensed in the state where the client is physically located at the time of the session, not just the state where the clinician sits. Some payers also require the client's location in the documentation. If clients travel or live near a state line, confirm where they are at the start of each session.

A simple telehealth billing checklist

Before submitting each telehealth claim, check:

1. Is the CPT code correct, and does the documented time support it?
2. Does the note record the modality (video or audio-only) and the locations?
3. Is the POS code the one this payer wants (02, 10 or in-person POS)?
4. Is the right modifier attached (95, 93, FQ, GT or none) for this payer?
5. Does this payer cover this service by telehealth for this provider type?
6. Is authorization in place if the plan requires one?
7. Was the clinician licensed in the client's state on that date?

Common telehealth denials to watch for

• POS and modifier combinations the payer doesn't accept
• Audio-only sessions billed with video modifiers
• Group therapy billed via telehealth where the plan doesn't cover it
• Services denied because the payer's telehealth coverage changed and the practice's settings weren't updated

When these appear, fix the cause in your billing setup, not just on the one claim, so the same error doesn't repeat across dozens of sessions.

Get help with telehealth billing

MedBill Solutions supports US therapy and behavioral health practices with claims submission, denial follow-up and payer follow-up, including telehealth claims. Our ongoing billing starts at 3% of what we collect for you. If telehealth denials have left you with a backlog, we'll work your old unpaid claims and you only pay 3% of what we recover.

Talk to us about your practice → or see our old claims recovery offer.

This article is general information, not legal, coding or compliance advice. Telehealth rules change often. Always confirm current requirements with CMS, your state Medicaid program and each payer.

More resources

• Why Therapy Insurance Claims Get Denied (and How to Fix Them)
• Should a Small Group Practice Outsource Billing?