Your provider ran a clean video visit. The patient was on time, the connection held, the note was signed the same afternoon. Three weeks later the claim comes back denied, or paid at a rate that makes no sense, and the remittance code points to a place of service problem nobody on your team can explain.
That is the frustrating thing about telehealth billing. The visit itself is rarely the problem. The claim has to prove a handful of facts: where the patient was, how they connected, who provided the service and from where, and which payer’s rules apply. Every payer reads those facts a little differently, and Medicare’s own rules have shifted several times since 2024.
This guide covers what you need to get telehealth claims right: POS 02 vs POS 10, when modifier 95 for telehealth applies and when modifier 93 replaces it, a four-question check your team can run before any telehealth claim goes out, and what is scheduled to change in 2027 and 2028. It is built from the telehealth billing work our VAs handle for primary care, behavioral health, and specialty practices.
Why Telehealth Claims Fail Even When the Visit Went Perfectly
A behavioral health group in Pennsylvania came to us after a quarter of rising denials on one commercial plan. Their billing was textbook Medicare: POS 10 for patients at home, modifier 95 for video sessions. The problem was that this particular commercial plan didn’t follow Medicare’s convention. Its provider manual asked for the place of service the visit would have had in person, POS 11, with modifier 95 to flag the visit as telehealth. Same visit, same codes, different payer expectation.
Nothing in the denial said “use POS 11.” The remittance pointed to an inconsistency between the procedure and the place of service, and the team spent weeks resubmitting with tweaks before anyone opened the payer’s telehealth policy.
That is the pattern we see most often. Telehealth claims rarely fail because of clinical documentation. They fail because the claim tells the payer a story about location and technology that doesn’t match what that payer has decided to accept. And because a practice usually starts telehealth billing with Medicare’s rules, those rules quietly become the default for every payer, whether they apply or not.
Telehealth Billing Basics: POS 02 vs POS 10 and the Modifiers That Go With Them
Telehealth billing is the process of coding and submitting claims for services delivered through real-time telecommunications, with a place of service code that says where the patient was and a modifier that says how they connected. For Medicare, those two choices decide whether the claim is accepted and which payment rate applies.
POS 02 vs POS 10 at a Glance
| POS 02 | POS 10 | |
|---|---|---|
| Name | Telehealth provided other than in patient’s home | Telehealth provided in patient’s home |
| Use when | The patient joins from somewhere other than home, such as a clinic, a workplace, or a facility | The patient joins from home, or another location where they receive care in a private residence |
| Medicare payment rate | Facility rate (lower) | Non-facility rate |
| Typical modifier for Medicare | 95 for audio-video, 93 for audio-only | 95 for audio-video, 93 for audio-only |
Modifier 95 for Telehealth, and When Modifier 93 Replaces It
Modifier 95 tells the payer the service was delivered through a real-time, synchronous audio and video connection. Modifier 93 tells the payer the service was delivered through a real-time, audio-only connection. Neither one changes the payment rate under Medicare. They exist so the payer can confirm the service was eligible to be furnished that way.
Audio-only is not a convenience option. For Medicare, it applies when the patient is at home, your practitioner had video capability, and the patient either couldn’t use video or didn’t consent to it. Your note should say which.
Is Modifier 95 Still Required With POS 10?
This is where online advice contradicts itself. Some sources say Medicare no longer needs modifier 95 once POS 02 or POS 10 is on the claim. CMS’s own claims processing instructions say POS 02 or POS 10 must be paired with the appropriate telehealth modifier: 95 for audio-video, 93 for audio-only. Our working rule is to follow the CMS instruction, append 95 or 93 on every Medicare telehealth line, and confirm your Medicare Administrative Contractor’s current guidance once a year. An extra modifier the payer ignores costs nothing. A missing one can cost the claim.
Why Telehealth Billing Rules Keep Shifting Under Your Feet
Medicare Runs on Temporary Extensions
Most of the Medicare telehealth flexibilities your practice relies on, such as patients being seen at home anywhere in the country, a broad list of eligible practitioner types, and audio-only care under the conditions above, are not permanent law. They have been extended in short increments, they have briefly lapsed more than once, and the current extension runs through December 31, 2027. Behavioral health telehealth has its own permanent rules, with additional requirements that begin in 2028.
Each extension changes what a correct claim looks like for a given date of service. That is why a claim that was right last year can be wrong this year, and why your billing team needs a dated record of which rules applied when.
Every Other Payer Writes Its Own Rules
Medicare’s rules are only one column. Every other payer decides its own POS convention, modifier requirements, covered telehealth codes, and audio-only policy.
| Payer type | What to confirm before billing telehealth |
|---|---|
| Original Medicare | POS 02 or 10 with modifier 95 or 93; the code is on the Medicare telehealth services list; the practitioner type is eligible for the date of service |
| Medicare Advantage | The plan’s own telehealth policy; many plans offer broader telehealth benefits than Original Medicare but set their own POS and modifier rules |
| Medicaid | Your state program’s telehealth manual; POS, modifiers, audio-only coverage, and covered codes vary by state and sometimes by managed care plan |
| Commercial plans | The payer’s telehealth reimbursement policy and your contract; some follow Medicare’s POS 02 and 10, others expect the in-person POS with modifier 95, and some use the GT modifier |
What Your POS Choice Is Really Worth
The difference between POS 02 and POS 10 is more than labeling. Under Medicare, POS 02 is paid at the facility rate and POS 10 at the non-facility rate. The non-facility rate is higher, because it assumes your practice carries the practice expense of delivering the service. If your team defaults to POS 02 for every telehealth visit, every visit with a patient at home is being paid at the lower rate.
A three-physician primary care practice we started working with last year had set POS 02 as the default in its telehealth visit template when telehealth first ramped up. Nearly all of their telehealth patients were at home. No claim ever denied, so nobody noticed, and for well over a year every one of those visits was paid at the facility rate. Correcting the template took ten minutes. The underpayment had been compounding the whole time.
There is a compliance side to the POS too. When a practitioner bills Medicare with POS 02 or 10 and a covered telehealth code, they are certifying that the patient was at an eligible location for that date of service. The POS is a statement of fact, and it should come from what the patient told you at check-in, not from a template default.
The Four-Question Telehealth Claim Check
Every telehealth claim has to answer four questions correctly. We build them into check-in, documentation, and charge entry so the answers exist before the claim does.
Question 1: Where Was the Patient?
Capture the patient’s physical location at the start of every telehealth visit, every time: home or somewhere else, and the state they are in. Patients join from their car, their office, a relative’s house, or a hotel two states away, and last month’s answer doesn’t carry over. The location drives the POS, and the state drives licensure.
This is a front-end task, and it is easy to skip when a provider is already running behind and a patient is waiting in the virtual room. Practices that have a telehealth virtual assistant handle virtual check-in get location, consent, and connection details recorded before the provider joins. Our overview of telehealth administration covers how that check-in step fits into the rest of the virtual visit workflow.
Question 2: How Did the Patient Connect?
Video or audio-only, and if audio-only, why. The answer decides modifier 95 or 93 for Medicare, and it decides whether the service is billable at all for payers that don’t cover audio-only.
A two-psychiatrist practice we support had been billing audio-only follow-ups with modifier 95 because the scheduling template labeled every remote visit “video.” When the connection dropped to phone-only, the note said so, but the claim didn’t. We added a single required field to the visit note, “connection type and reason if audio-only,” and mapped it to the modifier at charge entry. The mismatch stopped the following week.
Question 3: Who Provided the Service, and From Where?
Confirm the rendering practitioner is a type eligible to bill telehealth with that payer for the date of service, and that they are licensed in the state where the patient is located. For Medicare, practitioners can furnish telehealth from their home, and those with a physical practice location generally don’t need to enroll their home address. Practitioners whose only location is their home have different enrollment considerations, so check before a fully remote provider starts billing.
Question 4: Which Payer Rule Applies to This Claim?
This is the question that causes most denials, because it is the one teams answer from memory.
Build a Payer Telehealth Matrix
For each of your top payers, record five things in one shared table: the POS convention, the required modifier, audio-only coverage, covered telehealth codes or exclusions, and the date you last confirmed it along with where you confirmed it. Load the matrix into your PM system as payer-specific rules where your system allows it, so the right POS and modifier are applied automatically instead of chosen at charge entry.
Re-Check It When the Rules Change
Review the matrix every January, whenever Medicare’s extensions are renewed or expire, and whenever a payer publishes a telehealth policy update. Date every change. If a payer audits telehealth claims later, you will want to show which rule you were following for each date of service.
Telehealth Billing Mistakes That Lead to Denials and Recoupments
Using POS 02 for Patients at Home
It won’t deny, which is exactly why it lasts. Every Medicare visit with a patient at home billed with POS 02 is paid at the facility rate. Audit your template defaults and a sample of recent claims against the location recorded at check-in.
One Telehealth Setup for Every Payer
Medicare’s POS 02 and POS 10 convention is the most common one, but it isn’t universal. A single global rule in your PM system guarantees that some commercial or Medicaid claims are wrong. Configure by payer, using the matrix.
Audio-Only Without the Documentation
An audio-only claim needs a note that supports it: that video was offered or available, and why it wasn’t used. Without that, the claim is exposed in a post-payment review even if it paid at first.
Billing Codes That Aren’t on the Telehealth List
Medicare only pays telehealth for codes on its telehealth services list. A non-listed code billed with POS 02 or 10 comes back denied, typically with CARC 96 and RARC N776. When the practitioner type isn’t eligible to bill telehealth, the denial usually carries CARC 185. Read the code pair before resubmitting, because the fix for each is different. Our guide to how a medical billing virtual assistant handles claim denials walks through that triage step.
Ignoring the State the Patient Is In
A patient joining from another state can turn a routine follow-up into a licensure problem. An endocrinology practice we work with discovered that several of its winter telehealth follow-ups were with patients staying in Florida, where none of its physicians held a license. Adding “Which state are you in right now?” to the check-in script, and rescheduling to an in-person or in-state option when needed, closed the gap. Licensure rules vary by state and by service, so this is a question for your compliance advisor as well as your billers.
Advanced Telehealth Billing: FQHCs, Supervision, and What Changes in 2027 and 2028
FQHC and RHC Telehealth Billing
Federally qualified health centers and rural health clinics follow separate rules. For non-behavioral telehealth, Medicare currently allows them to bill HCPCS G2025 through December 31, 2026, while behavioral health telehealth is paid under their usual payment methodology. If your organization runs both a clinic and an FQHC or RHC, keep their telehealth setups completely separate.
Virtual Direct Supervision Is Now Permanent
Since January 1, 2026, Medicare permanently allows direct supervision through real-time audio and video for services that don’t carry a 010 or 090 global surgical indicator. That affects incident-to billing and certain diagnostic tests. Update your supervision policy so the supervising practitioner’s virtual presence is documented as clearly as a physical one would be.
Prepare Your Behavioral Health Panel for 2028 Now
Starting January 1, 2028, most Medicare patients receiving mental health services through telehealth will need an in-person visit within six months before their first telehealth service, and then periodically after that, with exceptions. Patients already receiving telehealth before 2028 are expected to follow the ongoing in-person visit requirement. If your practice has built a mostly virtual behavioral health panel, start a list now of Medicare patients who have never had an in-person visit with your practice, and plan how you’ll meet the requirement. Practices weighing that shift will find useful context in our piece on growing a private psychiatric practice in the telehealth era.
Watch the 2027 Physician Fee Schedule
CMS has proposed two new telehealth claim modifiers, BB and BC, for certain contracted arrangements beginning in 2027. They are proposals until the final rule confirms them. Don’t build them into your claim logic until the final rule defines exactly when they apply, and then update your matrix with the effective date.
Telehealth Billing Is a Rules Problem You Can Systematize
Most telehealth billing errors come from the same place: a fact about the visit that was never captured, or a payer rule that was answered from memory. Capture the patient’s location and connection type at check-in, confirm the practitioner’s eligibility and licensure, and let a dated payer matrix decide the POS and modifier. Do those four things consistently and most telehealth denials, underpayments, and audit exposure go away with them.
There is an honest limit to this. No billing process can make a payer cover a service its policy excludes, and payer telehealth policies will keep changing. The matrix has to be maintained by someone who reads those updates when they are published, not after the denials arrive.
For most independent practices, that ongoing maintenance is the hard part: tracking extensions and payer bulletins, configuring PM rules, and checking telehealth claims before submission. That is the work a medical billing virtual assistant from Care VMA takes on inside your own systems, under HIPAA-compliant controls, so your team isn’t relearning telehealth rules every time a deadline moves.
If your telehealth claims are denying or paying less than you expect, book a free consultation with the Care VMA team. We’ll review a sample of your recent telehealth claims against the four-question check and show you where the gaps are.
Frequently Asked Questions
What is the difference between POS 02 and POS 10?
POS 10 is used when the patient receives telehealth at home, and POS 02 when the patient is anywhere other than home. For Medicare, POS 10 is paid at the non-facility rate and POS 02 at the lower facility rate, so the choice affects payment as well as accuracy.
Is modifier 95 still required for Medicare telehealth?
CMS claims instructions pair POS 02 or POS 10 with the appropriate telehealth modifier: 95 for audio-video and 93 for audio-only. Some sources say 95 is optional with POS 10, so the safest approach is to append it and confirm your Medicare Administrative Contractor’s current guidance.
When should modifier 93 be used instead of modifier 95?
Use modifier 93 when the service was delivered through a real-time audio-only connection. For Medicare, the note should show that the patient was at home, that video was available from your practitioner, and that the patient couldn’t use it or didn’t consent to it.
Do commercial payers follow Medicare’s telehealth billing rules?
Not always. Some follow Medicare’s POS 02 and 10 convention, while others want the in-person place of service with modifier 95, or a different modifier entirely. Check each payer’s telehealth reimbursement policy and your contract, and record the answer in a payer matrix.
How long do Medicare’s telehealth flexibilities last?
The current extension runs through December 31, 2027. Starting in 2028, the rural and originating site requirements return for most non-behavioral services, and new in-person visit requirements apply to most mental health telehealth.
What denial codes are common for telehealth claims?
For Medicare, a code that isn’t on the telehealth services list typically denies with CARC 96 and RARC N776, and an ineligible practitioner type with CARC 185. Commercial payers often signal POS problems with a code indicating the procedure is inconsistent with the place of service.
