Direct Answer
Telehealth billing has undergone significant changes since the COVID-19 PHE flexibilities were introduced in 2020 and subsequently modified through Congressional action. For Medicare, many PHE-era telehealth expansions have been extended through legislative action (most recently through 2026), including: allowing telehealth regardless of patient location (home as an eligible originating site), allowing audio-only visits for behavioral health, and permitting telehealth for established Medicare patients without a prior in-person visit. Commercial payer telehealth coverage varies substantially — practices should verify each payer's current telehealth coverage policy rather than assuming PHE-era rules still apply.
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Telehealth CPT Codes
Medicare telehealth services are billed using standard CPT E&M codes (99202–99215 for office/outpatient visits) with the GT modifier (via interactive audio and video telecommunications systems) or the 95 modifier for synchronous telehealth. E&M code selection follows the standard 2021 guidelines based on either MDM or total time — the same documentation and coding rules apply regardless of whether the visit is in-person or via telehealth. Telephone E&M codes (99441–99443) were temporarily covered during the PHE but their continued coverage depends on current CMS policy. Virtual check-in (G2012), e-visits (99421–99423), and remote physiologic monitoring (RPM) codes are additional telehealth-adjacent services with specific coverage and documentation requirements. The AMA's CPT telehealth appendix and CMS's Medicare telehealth services list are the authoritative references for which services can be furnished via telehealth under Medicare.
Place of Service Codes for Telehealth
Place of service (POS) coding for telehealth directly affects payment rates. POS 02 (Telehealth provided other than in patient's home) is used when the patient receives the telehealth service at a location other than their home. POS 10 (Telehealth provided in patient's home) is used when the patient is at home during the telehealth visit. The distinction matters because Medicare pays the office rate (not the facility rate) when POS 02 or POS 10 is used and the provider's location is their office — ensuring that telehealth visits receive payment rates equivalent to in-person office visits. Using incorrect POS codes for telehealth is a billing error that can result in payment at the wrong rate (typically lower facility/hospital-based rates) and should be audited regularly as practices expand telehealth services.
Audio-Only Telehealth
Audio-only telehealth (telephone visits without video) has more restricted coverage than audio-video telehealth. Medicare covers audio-only visits for behavioral/mental health services (under PHE extensions and now in permanent policy for certain services), and for patients who lack access to or ability to use video technology. Audio-only visits for general E&M services (non-behavioral health) remain subject to changing CMS policy and may have different CPT code requirements. The billing code for audio-only visits may differ from the standard E&M codes used for audio-video telehealth — check current CMS guidance for the applicable codes. Commercial payers vary significantly in their audio-only coverage — some cover audio-only visits the same as audio-video, others require audio-video capability for telehealth coverage.
Commercial Payer Rules
Commercial payer telehealth coverage is payer-specific and policy-specific. Key variables to check for each payer: which CPT codes are covered via telehealth (not all codes covered by Medicare telehealth are covered by commercial payers); patient location requirements (some payers require the patient to be in a designated originating site or rural area even after PHE); whether prior established relationship requirements apply; required modifiers and POS codes; parity laws (many states have telehealth payment parity laws requiring commercial payers to reimburse telehealth at the same rate as in-person services, but not all states have parity laws and they apply differently to fully-insured vs. self-funded plans); and credentialing requirements for providers furnishing telehealth across state lines. Practices providing high-volume telehealth should verify coverage rules for their top payers at least annually, as policies continue to evolve.
Telehealth Documentation Requirements
Telehealth documentation requirements are largely consistent with in-person visit documentation — the same E&M code selection criteria (MDM or time) apply. Additional telehealth-specific documentation: the type of telehealth technology used (audio-video, audio-only); that the patient consented to telehealth (many states and payers require documented consent for telehealth); the patient's location at the time of the visit (required for place of service accuracy and licensure compliance — the provider must be licensed in the state where the patient is physically located); and for audio-only visits, why audio-only was used (patient lacks technology, patient preference, clinically appropriate). Documentation of telehealth modality and consent protects against billing compliance audit findings and ensures the clinical record accurately reflects the service furnished.
FAQ
Do providers need to be licensed in the state where the patient is located for telehealth?
Generally, yes — providers must hold a license in the state where the patient is physically located at the time of the telehealth visit, not just in the state where the provider is located. This is the longstanding medical licensing principle: the practice of medicine occurs where the patient is. During the PHE, CMS waived certain Medicare provider enrollment requirements, but state licensure is a separate issue that was not federally waived. The Interstate Medical Licensure Compact (IMLC) facilitates expedited multi-state licensure for physicians, allowing practices serving patients across state lines to obtain licenses in multiple states more efficiently. PSYPACT and similar compacts exist for psychologists and other licensed professionals. Practices should audit their patient geographic distribution and ensure providers hold licenses covering the states where their telehealth patients are located.
How do Federally Qualified Health Centers (FQHCs) bill for telehealth?
FQHCs have a different billing structure than physician practices — they receive a per-visit Prospective Payment System (PPS) rate rather than fee-for-service rates. FQHC telehealth billing follows specific rules: the FQHC bills on a UB-04 with specific revenue codes for telehealth visits, and the PPS rate applies. Under PHE extensions, FQHCs can serve as distant sites for telehealth (providing the telehealth service) and receive the PPS rate. FQHCs are subject to state telehealth laws and federal FQHC program rules that may affect telehealth coverage and billing — FQHC revenue cycle staff should verify current CMS telehealth guidance specific to FQHCs, as the rules differ from standard physician billing in several important respects.
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