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Telehealth Billing for Mental Health: Place of Service and Modifiers

POS 02 or 10? Modifier 95, 93 or none? A practical guide to billing behavioral health telehealth sessions correctly.

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Telehealth is a normal part of behavioral health care now, but telehealth billing is still not uniform. The CPT code for the session usually stays the same. What changes is how you tell the payer it was delivered by telehealth.

Key takeaways

  • Use POS 10 when the client is at home and POS 02 when they are somewhere else, unless the payer says otherwise.
  • Modifier 95 is for audio-video visits. Audio-only visits use payer-specific modifiers such as 93 or, for Medicare, FQ.
  • Telehealth rules change often. Keep a written rule for each payer and review it at least yearly.

Place of service: 02 or 10

  • POS 10: telehealth delivered while the patient is in their home.
  • POS 02: telehealth delivered while the patient is somewhere other than their home.

Medicare and many commercial plans use these two codes. Some payers still want the place of service you would have used in person, such as 11 for office, along with a telehealth modifier. Do not guess: check each payer.

Modifiers

  • 95: synchronous audio-video telehealth. Required by many commercial plans and, in some cases, Medicare.
  • 93: audio-only services, used by payers that cover phone sessions.
  • FQ: the Medicare modifier for audio-only behavioral health services.

Check before you assume

A claim with the right code but the wrong place of service or modifier can deny, or pay at a different rate than you expected. Payer policies change, so review them regularly.

Documentation that supports the claim

Your note should show that the visit was delivered by telehealth, whether it was video or audio only, where the client was and where you were. If a payer requires telehealth consent, document that as well.

Licensing and network status across state lines

You generally need to be licensed in the state where the client is located during the session. A client who travels or relocates can put you outside your license, and outside your in-network status, without anyone noticing. Ask clients to confirm their location at the start of each session.

Telehealth claims denying?

We maintain place-of-service and modifier rules for each payer our clients bill, and work denials until they are resolved.

A short telehealth billing checklist

  • Does the claim carry the right POS and modifier for this payer?
  • Does the note record the technology used and both locations?
  • Was the client’s state confirmed, and are you licensed there?
  • Is the client’s plan in-network for telehealth with you?

Learn more about our mental health billing services, or how psychiatry billing handles telehealth E/M visits.

This article is general information. Check current Medicare telehealth rules at cms.gov and each payer’s policy before you bill.

About the author

The Cure MB billing team

Cure MB is a medical billing and revenue cycle team that works claims, denials and credentialing for independent US practices every day. These guides are written to be practical, and they are general information, not legal or coding advice for your situation.

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