ISSUE 12 · WEEK 12 · MONTH 3
Coding, Compliance & Audit Defense
Telehealth consultation

Telehealth billing in 2026: what’s changed, what’s at risk, and what to do now

Telehealth billing rules keep changing. Here’s what’s current and what’s at risk.

THIS WEEK IN PRACTICE

Twelve weeks in. This week we’re covering telehealth billing — a topic that has had more regulatory changes in the past four years than almost any other area of physician practice billing, and that remains a top OIG audit priority in 2026. If your practice does telehealth visits, this issue is for you.

 

DEEP DIVE

Telehealth Billing in 2026 — The Rules That Are Currently in Effect

Telehealth billing has gone through three distinct phases since 2020: the COVID-era expansion that waived most geographic and originating site restrictions; a series of temporary extensions that maintained those waivers through 2024 and into 2025; and the current period, in which some expansions have been made permanent and others have reverted or changed.

Here is what this looks like in practice. A 3-provider psychiatry practice was billing all telehealth visits with POS 11 (office) instead of POS 02 (telehealth) and omitting modifier -95. They had been doing this since the COVID-era flexibility period ended, not realizing the rules had changed. An internal audit of 40 telehealth claims found 100% had the wrong POS code. While no claims had been denied yet, the practice was at significant audit risk — incorrect POS codes on telehealth claims are an active OIG and MAC audit target. They corrected their billing templates in one afternoon and retrained providers on documenting patient location. Cost to fix: zero dollars and 2 hours. Cost of not fixing: potential recoupment of every telehealth claim billed incorrectly, plus civil penalties.

3 phases

of telehealth billing rules since 2020: COVID expansion, partial rollback, 2026 stabilization.
Practices still billing under 2020 rules are at significant audit risk.

Element 2026 Rule Common Error How to Verify
Place of Service POS 02 (telehealth) for real-time video; POS 10 (patient home) if applicable Using POS 11 (office) for telehealth visits Check every telehealth claim before submission
Modifier -95 Required for synchronous telehealth on some payers Omitting modifier = denial or underpayment Verify payer-specific modifier requirements
GT modifier Deprecated by Medicare but still required by some commercial payers Using GT for Medicare (no longer accepted) Check each payer’s current telehealth policy
Patient consent Must be documented before first telehealth visit Consent not in chart = compliance risk Add consent checkbox to telehealth intake form
Audio-only visits Medicare: 99441–99443 with modifier -93; commercial varies Billing audio-only as video visit Separate audio-only workflow with correct codes
Patient location Must be documented: state where patient is located at time of visit Not documented = licensure + billing risk Template field: “Patient located in [State] at time of visit”
Originating site Medicare geographic restrictions reinstated for most services Assuming COVID-era flexibilities still apply Verify current Medicare telehealth eligible services list

Telehealth billing rules change frequently. Verify this table against current CMS and payer policies quarterly. Last verified: March 2026.

Here is what is currently in effect for Medicare telehealth as of 2026:

Geographic restrictions are largely suspended for most telehealth services. The pre-COVID requirement that patients be located in rural or health professional shortage areas has been waived through at least 2026 for most services. Patients can receive most telehealth services from their home.

Place of service codes have been standardized. POS 02 is used for telehealth services where the patient is not in their home. POS 10 is used for telehealth services where the patient is in their home — which covers the majority of telehealth visits for most independent practices.

Modifier -95 is required on telehealth claims to indicate that the service was provided via real-time audio and video interactive telecommunication system. Claims without this modifier are subject to denial.

Audio-only visits have separate rules. Modifier -93 is used for audio-only synchronous telehealth services when video technology is not available to the patient or is not medically appropriate. Not all CPT codes are covered under audio-only; the list is more restricted than for audio-video telehealth.

Medicare Advantage plans may have different requirements than traditional Medicare. MA plans set their own telehealth policies and may require prior authorization, impose geographic restrictions, or use different modifier requirements even for the same patient population. Verify telehealth rules directly with each MA plan.

Documentation requirements for telehealth are the most common source of audit findings. The note must include: the patient’s location at the time of service, the provider’s location at the time of service, documentation that real-time audio and video communication was used (or the reason audio-only was appropriate), patient consent for telehealth, and the same clinical content required for an in-person visit at the coded level.

 

THREE ACTION STEPS THIS WEEK

Complete each step before next Tuesday.

1

Audit a random sample of 20 telehealth claims from the past 12 months. For each claim: confirm POS 02 or POS 10 is correct based on the patient’s location; confirm modifier -95 (or -93 for audio-only) is present; confirm the note documents the patient’s location, the provider’s location, and the modality used; and confirm that patient consent for telehealth is documented in the record. Note any claims that fail any of these checks and calculate the error rate.
2

Review your telehealth documentation template. Ensure it includes mandatory fields for: patient location at time of service, provider location at time of service, confirmation of real-time audio-video connection, patient consent for telehealth (or reference to a consent form on file), and the reason for audio-only if applicable. If these fields are not in your template, they are not in your notes — and those notes will not survive a telehealth audit.
3

Verify telehealth policies with each of your top 5 Medicare Advantage plans. Contact each MA plan’s provider relations line or check their provider manual for: whether telehealth services are covered, what place of service codes they use, whether prior authorization is required for telehealth visits, and whether their covered telehealth code list differs from traditional Medicare. Document what you find. Update your scheduling and billing protocols accordingly.
 

FIVE THINGS WORTH KNOWING

1

The CMS telehealth flexibilities extended through the Consolidated Appropriations Act include coverage of telehealth from the patient’s home (POS 10), coverage of audio-only services under modifier -93, and suspension of geographic originating site requirements — currently extended through December 31, 2026 for most services.
2

Telehealth billing errors are the third most common finding in CMS Targeted Probe and Educate (TPE) reviews of physician practices in 2025, behind E&M coding and evaluation of documentation to support billed procedures. The most common telehealth error: missing documentation of the patient’s location at the time of service.
3

Medicare Advantage plans cover more than 50% of Medicare beneficiaries as of 2026 — and each MA plan has its own telehealth coverage policies. A patient enrolled in an MA plan may have different telehealth benefits than a patient in traditional Medicare, even within the same practice’s patient population. Assuming MA telehealth rules mirror traditional Medicare is one of the most common and costly telehealth billing mistakes.
4

The audio-only modifier (-93) is valid for telehealth services when video is not available to the patient or when the patient is unable to use video technology. Using modifier -93 on a visit where video was available but not used — because it was easier — is a compliance violation, not a billing option.
5

Telehealth consent documentation — confirming that the patient agreed to receive care via telehealth — is required by most payers and is a frequent finding in audits. A signed consent form on file is sufficient if it covers all future telehealth visits; a note in the chart saying ’patient consented to telehealth’ on the date of service is also acceptable. An absence of any consent documentation is not.
 

BILLING CORNER

The Telehealth Billing Quick Reference — POS

Place of Service Codes: POS 02 — Telehealth provided other than in patient’s home (e.g., patient is at a clinic, office, or other non-home location). POS 10 — Telehealth provided in patient’s home. Use POS 10 for the vast majority of telehealth visits in independent practice.

Your billing team and telehealth providers needs this.

FORWARD TO YOUR TEAM →

Modifiers: -95 — Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system. Required on telehealth claims for most payers. -93 — Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. Use only when video is not available or medically appropriate.

What must be in every telehealth note: (1) Patient’s location at the time of service. (2) Provider’s location at the time of service. (3) Statement that the service was provided via real-time audio and video telehealth (or audio-only with reason). (4) Reference to patient consent for telehealth. (5) All clinical content that would be required for an equivalent in-person visit.

Common telehealth billing mistakes: Using POS 02 when the patient is in their home (should be POS 10). Omitting modifier -95. Missing patient location documentation. Using audio-only when video was available. Billing telehealth for services not on the covered telehealth code list. Failing to check MA plan requirements separately from traditional Medicare.

For Medicare, the full list of covered telehealth services is at cms.gov under the Telehealth Services list. Review this list annually — codes are added and removed with each fee schedule update.

20-Claim Telehealth Billing Audit Checklist

Pull: 20 random telehealth claims from the past 90 days.

For each claim, check:

• POS code is 02 or 10 (not 11)

• Appropriate modifier applied (-95 or payer-specific)

• Patient consent documented in chart before first telehealth visit

• Patient location (state) documented in the visit note

• Audio-only visits billed with correct phone E&M codes (99441–99443), not video codes

• Visit note includes technology platform used and confirmation of audio/video connection

Target error rate: Below 5%. If higher, update templates and retrain before next billing cycle.

 

COMPLIANCE WATCH

Telehealth Fraud Enforcement — DEA and Controlled Substances. For practices prescribing controlled substances via telehealth, the Ryan Haight Online Pharmacy Consumer Protection Act’s in-person exam requirement was waived during the COVID public health emergency. As of 2026, DEA telehealth prescribing rules for controlled substances remain in a regulatory transition period, with temporary flexibilities in effect but final rules not yet implemented. If your practice prescribes controlled substances to patients seen only via telehealth, you must stay current with DEA guidance. Prescribing controlled substances via telehealth without meeting current DEA requirements — whatever they are at the time of the prescription — is a federal violation that can result in DEA registration suspension and criminal referral. Check DEA.gov for current telehealth prescribing guidance before each prescription.

 

PEOPLE & PRACTICE

Managing a Hybrid Telehealth and In-Person

The operational challenge most practices underestimate with telehealth is scheduling. A practice that offers both in-person and telehealth visits needs a scheduling system that captures the visit type at the time of booking, triggers the correct insurance verification workflow (telehealth coverage is not the same as in-person coverage for all payers and all plan types), and routes the patient to the correct check-in process.

The most common scheduling failure in hybrid practices: a telehealth visit is booked as a standard appointment type, the insurance is verified for in-person visits, and nobody checks telehealth coverage specifically until after the visit is complete and the claim is denied.

The fix: create a separate appointment type for telehealth visits in your EHR, associate that appointment type with a separate pre-visit insurance verification checklist that includes telehealth coverage verification, and train your scheduling staff that telehealth and in-person are not interchangeable from a billing standpoint.

It takes about 30 minutes to configure in most EHR systems and eliminates the most predictable category of telehealth-related denials.

 

ASK THE PULSE

From a reader managing a psychiatry practice: ’We’ve been billing telehealth under POS 02 since 2021. I just realized we should have been using POS 10 for patients who are at home. How far back can we go to correct this, and is this going to create an audit problem?’

Our answer: This is a common issue, and it is correctable — here is how to think about it.

POS 02 versus POS 10 affects reimbursement rates for some payers (Medicare pays facility rates for POS 02 and non-facility rates for POS 10), so correcting the POS code may actually result in higher reimbursement for the corrected claims, not lower. This makes correcting the error straightforwardly in the practice’s financial interest.

You can file corrected claims for up to 12 months from the date of service for most payers. For Medicare, the timely filing limit for corrected claims is typically 12 months from the original claim date. Pull a sample of the affected claims, determine the correct POS, and file corrected claims for any within the timely filing window.

On the audit risk question: proactively correcting a billing error is not an audit trigger — it is what a compliant practice does when it identifies an error. Document why you’re filing the corrections (discovered POS coding error during internal audit, corrected to reflect patient’s actual location), keep the documentation, and proceed. Proactive correction is evidence of a functioning compliance process, not evidence of fraud.

Hit reply with your question.

Quick picks — tap one to vote for a future topic:

Audio-only billing Multi-state licensing
Telehealth consent RPM billing
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ONE MORE THING

Telehealth billing is genuinely complex right now — the rules have changed repeatedly, the CMS guidance is detailed and evolving, and Medicare Advantage plans add another layer of variation on top of traditional Medicare rules.

The practices that manage it well are not the ones that have memorized every regulation. They are the ones that have built a reliable documentation template, verified their rules with each major payer, and set a calendar reminder to re-verify annually. Systematic over smart, every time.

 

COMING NEXT TUESDAY

3 months in: the billing improvements that move the needle most

A look back at what we’ve covered and what your peers are implementing.

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