Telehealth stopped being a pandemic workaround years ago, but the billing rules around it are still catching practices off guard, mostly because Medicare and commercial payers haven’t converged on the same rules.
The Core Problem: Two Billing Tracks, Not One
The AMA introduced a dedicated set of telehealth E/M codes, but Medicare largely declined to adopt them, choosing instead to keep standard office visit codes (99202–99215) paired with the correct place-of-service code and modifier. Commercial payers vary, some follow Medicare’s approach, some accept the newer code set. A practice billing both Medicare and commercial telehealth visits needs two different playbooks running at the same time, and using the wrong one for the wrong payer is a routine source of denials.
Place of Service: The Detail Everyone Gets Wrong
Two POS codes matter most: POS 02 (telehealth delivered somewhere other than the patient’s home) and POS 10 (telehealth delivered to the patient’s home). They’re not interchangeable, and using the wrong one affects reimbursement, not just claim formatting.
Modifiers That Actually Matter
Modifier 95 identifies a synchronous telehealth service delivered via real-time audio and video. Modifier 93 is for audio-only telehealth, used when video isn’t available or the patient hasn’t consented to video. Using neither, or using the wrong one, is one of the more common technical rejections on telehealth claims.
What’s Permanent vs. What’s Still Temporary
Some telehealth flexibilities have been made permanent as part of recent Medicare Physician Fee Schedule rulemaking. Others remain tied to periodic extensions, meaning a service billable today could require a policy check again before year-end. The safest approach: verify current-year telehealth coverage for your specific service codes before assuming last year’s rules still apply.
Where This Hits Behavioral Health and PT Practices Specifically
Behavioral health has some of the highest telehealth utilization of any specialty, and audio-only billing rules matter disproportionately here, since many behavioral health encounters don’t require video to be clinically effective. Physical therapy telehealth coverage has had a more uneven history but has been extended further out than in prior years.
The Practical Takeaway
Telehealth billing isn’t a “set it once” configuration. POS codes, modifiers, and payer-specific coverage all shift often enough that a claim template built even a year ago can be quietly wrong today.
What OmniBridge Actually Does
We keep telehealth billing rules current for independent US physician practices, tracking POS code requirements, modifier updates, and payer-specific telehealth coverage so your claims stay clean as the rules shift.
If you want to see where your practice currently stands, request a free billing audit → and we’ll show you your actual clean claim rate and days in A/R before you commit to anything.
