AI-generated ICD-10 and CPT codes from clinical notes — Medical Coding Online
Telehealth Place of Service Codes
The Place of Service (POS) code on a telehealth claim tells the payer where the patient was located during the visit. This directly affects the payment rate — Medicare pays facility rates for telehealth, not the higher non-facility office rate.
| POS Code | Description | When to Use |
|---|---|---|
| 02 | Telehealth — patient at home | Most Medicare telehealth visits post-PHE |
| 10 | Telehealth — patient not at home | Patient at office, clinic, or other location |
| 95 | Telehealth (legacy) | Some commercial payers still require; Medicare deprecated |
| 11 | Office | Do NOT use for telehealth — common billing error |
Telehealth Modifiers
In addition to POS codes, some payers require modifiers to identify telehealth services. Requirements vary by payer and state.
- Modifier 95 — synchronous telemedicine service (audio/video) — required by some commercial payers
- Modifier GT — via interactive audio and video — legacy Medicare modifier (replaced by POS 02/10)
- Modifier 93 — synchronous telemedicine service rendered via telephone or other real-time interactive audio-only
- Modifier GQ — asynchronous telemedicine (store-and-forward) — Alaska/Hawaii federal programs
- Check each payer's billing guidelines — modifier requirements are not standardized
Audio-Video vs. Audio-Only Telehealth
Audio-video telehealth (real-time video connection) is covered more broadly than audio-only (telephone). Medicare has specific rules for each, and coverage for audio-only is more restricted.
| Type | Coverage | CPT Codes |
|---|---|---|
| Audio-video (synchronous) | Broadest coverage — most E/M and many specialty codes | 99202–99215, 99421–99423 online digital E/M |
| Audio-only | Limited — Medicare covers for mental health (modifier 93) | 99441–99443 telephone E/M |
| Asynchronous (store-and-forward) | Very limited — Alaska and Hawaii only for Medicare | Specialty-specific codes |
| Remote patient monitoring | Separate program — not considered telehealth | 99453, 99454, 99457, 99458 |
Medicare Telehealth Eligible Services
Medicare maintains an approved list of telehealth services. Services not on the list cannot be billed as telehealth to Medicare regardless of how they were delivered. The list has expanded significantly since 2020.
- Office or other outpatient E/M visits (99202–99215) — approved
- Psychiatric evaluation and psychotherapy (90791, 90832–90838) — approved
- Preventive care visits — expanded approval
- Diabetes self-management training — approved
- Substance use disorder treatment — approved
- NOT approved for Medicare: most surgical follow-ups, physical/occupational therapy (state Medicaid may differ)
State Medicaid Telehealth Rules
State Medicaid programs have their own telehealth rules that may be more or less generous than Medicare. Many states expanded coverage permanently after the PHE and require different billing codes than Medicare.
- Coverage varies by state — check your state Medicaid bulletin
- Some states require originating site code (Q3014) — others do not
- Audio-only may be covered by state Medicaid but not Medicare
- Some states require special provider enrollment for telehealth
- Mental health telehealth coverage often more extensive than medical
- FQHCs and RHCs have unique telehealth billing rules
How AI Streamlines Telehealth Billing
AI-powered billing tools automatically detect when a visit was delivered via telehealth and apply the correct POS code, modifiers, and payer-specific rules — preventing the most common telehealth billing errors.
- Auto-detect telehealth from appointment type or note headers
- Apply correct POS 02 vs. POS 10 based on patient location documentation
- Flag payer-specific modifier requirements
- Validate telehealth CPT codes against Medicare approved list
- Alert when audio-only visit requires different coding than audio-video
- Ensure documentation confirms real-time interactive communication
Frequently Asked Questions
- What Place of Service code should I use for Medicare telehealth in 2025?
- For Medicare telehealth visits where the patient is at home, use POS 02 (Telehealth — patient home). For telehealth where the patient is at a location other than home (office, clinic, etc.), use POS 10. Do not use POS 11 (office) or the legacy modifier GT/95 for Medicare — POS 02/10 replaced these. Using the wrong POS code can result in overpayment and audit risk.
- Can I bill audio-only telephone visits to Medicare?
- Medicare covers audio-only telehealth in limited circumstances. For mental health services, Medicare allows audio-only with modifier 93 when the beneficiary does not have access to or is not capable of using two-way audio/video technology. For other services, audio-only telephone visits (99441–99443) are not covered by Medicare as telehealth. Commercial payers vary widely — check each payer's policy.
- Is remote patient monitoring (RPM) the same as telehealth?
- No. Remote patient monitoring (RPM) is a separate program from telehealth. RPM uses connected devices (blood pressure monitors, glucose meters, pulse oximeters) to collect patient data between visits. RPM has its own CPT codes (99453, 99454, 99457, 99458) and billing rules. RPM can be billed alongside telehealth visits but requires specific documentation of device use, data review, and time spent on RPM activities.
- Do I need a patient consent form for telehealth billing?
- Most payers and state regulations require documented patient consent for telehealth services, specifically acknowledging that they understand the nature of virtual care and any limitations. For Medicare, consent must be documented in the medical record for behavioral health telehealth. Check state law for additional consent requirements — many states have specific telehealth consent statutes. This documentation is required during audits.
- What documentation is required to support a telehealth claim?
- Required documentation for telehealth visits includes: (1) confirmation that the visit was conducted via real-time interactive audio-video (or audio-only with appropriate justification), (2) patient location (to confirm correct POS code), (3) provider location, (4) type of technology platform used, and (5) all standard E/M documentation (chief complaint, HPI, assessment, plan). Without clear telehealth documentation, a payer audit can convert the telehealth claim to a non-covered service.