Mental Health Telehealth Billing Guidelines: POS 02, POS 10, and Modifiers
Two entries on a telehealth claim carry most of the risk: the place of service in box 24B and the modifier beside the procedure code. Place of service changes the Medicare payment rate. The modifier records whether the visit used video or audio only.
The rate difference is easy to measure. Using the 2026 Medicare Physician Fee Schedule's total relative value units and its $33.4009 conversion factor, a 60-minute psychotherapy visit (CPT 90837) has a national amount of $167.00 with place of service 10 and $135.27 with place of service 02.
These mental health telehealth billing guidelines cover that split, the modifiers that go with it, the audio-only conditions, and the in-person visit rule Medicare will begin applying in 2028. Every date below comes from CMS documents or contractor notices published through October 2026.
Mental health telehealth billing guidelines for POS 02 and POS 10
CMS defines POS 02 as telehealth provided other than in the patient's home and POS 10 as telehealth provided in the patient's home. Home means a private residence, not a hospital or other facility where the patient receives care (CMS Telehealth FAQ, updated October 8, 2026). The test follows the patient. The clinician's location does not enter into it.
POS 10 is newer than many billing teams remember. CMS introduced it in Change Request 12427, issued October 13, 2021, effective January 1, 2022 and implemented in claims systems on April 4, 2022. That document also noted that Medicare did not require telehealth place of service codes during the public health emergency. The requirement arrived with Transmittal 12671 to the Medicare Claims Processing Manual, effective January 1, 2024, which made POS 02 and POS 10 the only valid codes for Medicare telehealth billing.
Payment came from the CY 2024 fee schedule final rule: telehealth claims for patients in their homes are paid at the non-facility rate, and POS 02 claims are paid at the facility rate. For psychotherapy, the gap looks like this:
| CPT code | POS 10 (non-facility) | POS 02 (facility) | Difference |
|---|---|---|---|
| 90834 (45 minutes) | 3.41 RVUs, $113.90 | 2.75 RVUs, $91.85 | $22.05 |
| 90837 (60 minutes) | 5.00 RVUs, $167.00 | 4.05 RVUs, $135.27 | $31.73 |
Amounts are national figures before geographic adjustment, calculated from 2026 total RVUs at $33.4009 per RVU.
The facility amount is about 19 percent lower for both codes. A clinician who bills 15 Medicare 90837 sessions a week for 48 weeks (720 visits) and codes every one as POS 02 gives up roughly $22,800 at national rates.
A wrong rate does not always start with the practice. In March 2024, Mirean Coleman, director of clinical practice at the National Association of Social Workers, reported that National Government Services and Novitas Solutions had paid some POS 10 claims at the facility rate because of a system processing issue, and were adjusting affected claims with dates of service from January 1, 2024 forward. Comparing remittances against the fee schedule on a regular basis would catch the same problem sooner.
Consider a patient who joins a Tuesday session from a parked car at her workplace. That visit is POS 02. The same patient on Wednesday, seated in her kitchen, is POS 10. A note recording the patient's location at the start of each session is the only way to tell the two apart later.
Which modifier goes with POS 02 or POS 10
Chapter 26 of the Medicare Claims Processing Manual states that POS 02 or POS 10 "must be paired with the appropriate telehealth modifier": 93 for audio-only and 95 for audio-video. The modifier does not change the payment rate. The place of service does.
Contractors are less uniform than the manual. First Coast Service Options, a Medicare Administrative Contractor, updated its telehealth modifier page on October 7, 2026. It lists modifier 95 for specific situations, including hospital-employed outpatient therapists and opioid treatment programs, rather than for every video visit. Practices should read their own contractor's current article and keep a copy on file.
| Modifier | Meaning | Where it applies |
|---|---|---|
| 95 | Synchronous audio and video | Video visits paired with POS 02 or 10 under the manual |
| 93 | Synchronous audio-only | Patient at home who lacks the technology for video or does not consent to it |
| FQ | Audio-only service | Rural health clinics and FQHCs only |
| GT | Audio and video | Critical access hospital Method II institutional claims only |
| GQ | Asynchronous | Federal telemedicine demonstrations in Alaska and Hawaii |
Descriptions and uses from First Coast Service Options, October 7, 2026.
Audio-only sessions
Medicare allows audio-only mental health telehealth for patients in their homes. The CMS FAQ (Q6) says the practitioner must be technically capable of audio-video, and the patient must be unable to use it or decline it. Audio-only applies to new and established patients. Through December 31, 2027, home audio-only rests on the legislative extension; from January 1, 2028, it continues for behavioral health under those capability and consent conditions.
The claim pairs POS 10 with modifier 93, and the note should show that video was offered and why the patient did not use it. Rural health clinics and FQHCs may report 93 or FQ. Their behavioral health telehealth visits are paid under the all-inclusive rate and prospective payment system (CMS FAQ, Q4), a different method from the fee schedule amounts above.
The in-person visit rule and the January 1, 2028 cutoff
Congress extended most Medicare telehealth flexibilities through December 31, 2027 in the Consolidated Appropriations Act, 2026, signed February 3, 2026 (National Association of Rural Health Clinics). Those flexibilities had lapsed on October 1, 2025 during a federal government shutdown, and CMS later said claims would be paid as if no lapse had occurred (Telehealth FAQ, Q16).
The in-person rule for mental health runs on its own date. Section 1834(m) of the Social Security Act requires an in-person, non-telehealth visit within six months before a patient's first mental health telehealth service at home, effective after December 31, 2027, and at least once every 12 months afterward, with limited exceptions. A patient who began mental health telehealth at home on or before December 31, 2027 is treated as established and needs one in-person visit every 12 months after that date (Telehealth FAQ, Q5). When the treating clinician is unavailable, a practitioner of the same specialty in the same group practice may provide the in-person visit.
Two patients show how sharp the line is. One starts telehealth on December 28, 2027 and the other on January 4, 2028. The first is established. The second needs an in-person visit within the preceding six months. Practices can begin recording the date and clinician of each Medicare patient's last in-person visit now.
Modifiers BB and BC from January 1, 2027
CMS's FAQ (Q17 and Q18) states that modifiers BB and BC will be required on telehealth claims beginning January 1, 2027, with no effect on payment. BB identifies telehealth furnished through a virtual platform by a practitioner who contracts with the entity that owns the platform, or who has a payment arrangement with it. BC identifies telehealth furnished incident to a physician's or practitioner's professional service.
A therapist who sees Medicare patients through a contracted virtual care company falls within the BB wording. Confirm with the platform's billing team and your MAC, before January 1, which claim lines need it.
Medicaid and commercial plans set their own rules
Medicare's pairing is a starting point. UnitedHealthcare Community Plan reimbursement policy 2026R7133H says the plan recognizes but does not require POS 02 or 10, while the Louisiana UnitedHealthcare Community Plan policy 2026R0046A.LA requires one of them. UnitedHealthcare's commercial and individual exchange policy 2024R0046D covers audio-video services reported with either code. One insurer, several policies. Check the policy tied to the plan and the date of service.
A pre-submission check for each claim line
- The patient's location at the start of the session is documented and matches POS 10 or POS 02.
- The modality is documented: video, or audio-only with the reason video was not used.
- The modifier matches the modality (95 or 93; FQ only for rural health clinics and FQHCs).
- The CPT code appears on CMS's List of Telehealth Services for the date of service.
- For Medicare mental health patients, the last in-person visit date is on file ahead of the 2028 rules.
- The Medicaid, Medicare Advantage or commercial plan's own telehealth policy has been checked for that date of service.
Each Medicare claim line needs three matching pieces of information: the patient's location, which determines POS 02 or POS 10; the delivery method, which determines modifier 95 or 93; and a note that documents both. Under current mental health telehealth billing guidelines, the costliest error in the figures above is a home visit coded POS 02, a 19 percent reduction on every psychotherapy session. Reviewing a sample of recent claims for that one pattern can show whether a practice has been underpaid, since the national gap on a single 90837 visit is $31.73.