Telehealth POS Codes and Modifiers for Behavioral Health (2026)

For Medicare the POS code sets the payment rate and the modifier tells the payer how the visit happened. Get either one wrong and you risk a denial or an underpayment.

POS 10 vs POS 02 changes what Medicare pays

Since January 1, 2024 Medicare pays telehealth to patients at home at the non-facility rate. The CMS manual puts it plainly: "The payment rate for POS 02 is the facility payment rate (F); the payment rate for POS 10 is the non-facility rate (NF)" (Medicare Claims Processing Manual ch. 26 §10.5). So the wrong POS on a home session can change the payment.

Audio-only visits come with conditions

Through December 31, 2027 Medicare patients can keep getting audio-only telehealth at home. From January 1, 2028 audio-only behavioral health at home needs a practitioner who can use video and a patient who can't or doesn't consent to it (CMS Telehealth FAQ, updated 10/8/26). HHS ties modifier 93 to that same situation (Telehealth.HHS.gov). So note why each audio-only visit didn't use video.

Payer rules conflict

Medicare, UnitedHealthcare and Cigna don't agree on POS. UnitedHealthcare commercial accepts POS 02 or 10. Cigna's behavioral health section asks for POS 02. A rule that works for one payer can trigger a denial at the next one.

So one EHR default won't fit every payer listed here. If you'd rather hand this off, see how we handle telehealth billing for behavioral health practices.

POS describes where the patient is, not where the provider is. POS 10 means the patient is at home. POS 02 means the patient is somewhere else.

Definitions come from the CMS Place of Service code set. Rates come from the Claims Processing Manual ch. 26.

POS 10: telehealth provided in the patient's home

CMS defines POS 10 as care where the "Patient is located in their home (which is a location other than a hospital or other facility where the patient receives care in a private residence)" (CMS POS code set).

POS 02: telehealth provided other than in the patient's home

POS 02 covers telehealth when the "Patient is not located in their home" (CMS POS code set). That includes a school, a workplace or a clinic that serves as the originating site.

When should you use POS 11 instead?

Use POS 11 for in-person sessions only. For Medicare the manual names POS 02 and POS 10 as "the only two valid POS codes for Medicare telehealth billing" (Claims Processing Manual ch. 26).

What if the patient's location changes between sessions?

A client who logs in from home one week and from work the next needs a different POS each time. Ask where the patient is at every check-in and record it in the note.

Modifier 95 means real-time audio and video. Modifier 93 means real-time audio-only. On Medicare GT now applies only to CAH Method II institutional claims and FQ only to RHCs and FQHCs.

Novitas puts the base rule simply: "Telehealth modifiers must be submitted with distant site telehealth services." It also says the patient "must be present and actively participating in the telehealth visit" (Novitas JH).

Modifier 95: synchronous audio-video

Novitas defines 95 as "synchronous telemedicine service rendered via real-time Interactive audio and video telecommunications system" (Novitas JH). On Medicare professional claims POS 02 or 10 "must be paired with the appropriate telehealth modifier (modifier 93 for audio-only and modifier 95 for audio/video)" (Claims Processing Manual ch. 26).

Modifier 93: synchronous audio-only

The AMA describes Appendix T as "a CPT code list that may be used for reporting audio-only services when appended with Modifier 93" (AMA). The CMS manual adds that 93 or 95 "does not change rate of payment, only the POS code determines the non-facility or facility payment rate."

Modifier GT: CAH Method II only on Medicare

Novitas says GT is "Only allowed on institutional claims billed by CAH method II providers." The CMS telehealth booklet says the same for distant site practitioners billing under CAH Method II (MLN901705). Some commercial plans still take it. Cigna lists GT among its accepted modifiers.

Modifier FQ: audio-only for RHCs and FQHCs

FQ means the service "was furnished using audio-only communication technology." Novitas adds that "This modifier can only be used by RHCs and FQHCs" (Novitas JH). Novitas also says RHCs and FQHCs "can report either modifier 93 or FQ" for audio-only services, so their audio-only line carries one of the two. For mental health visits CMS tells RHCs and FQHCs to "Use new service-level modifier FQ or 93" for audio-only (MLN Matters SE22001).

New for Jan 1, 2027: modifiers BB and BC

CMS says BB and BC "are required beginning January 1, 2027." BB covers telehealth furnished through a virtual platform the practitioner contracts with or pays to use. BC covers telehealth furnished incident to a practitioner's service. CMS also says "these modifiers do not have payment implications" (CMS Telehealth FAQ Q17–Q18). BB and BC cover only those two situations. As of October 2026 the manual's rule that pairs POS 02 or 10 with 93 or 95 hasn't changed.

Pick the code for the service you gave, set the POS from where the patient is, add the modifier the payer wants and then document it. The steps below follow Medicare. Check each commercial plan's policy for its own version.

1. Confirm the service is on the payer's telehealth list. For Medicare that's the CMS List of Telehealth Services. For CY 2026 CMS added multiple-family group psychotherapy to the list (MLN MM14315). HHS notes the Medicare list has more than 250 codes and changes generally happen once a year, so recheck it each January (Telehealth.HHS.gov).
2. Choose the code for the service. Use the same time and service rules you'd use for an in-person visit. Our guide to psychotherapy CPT codes covers the time windows for the individual therapy codes.
3. Record where the patient is. That sets POS 10 or POS 02.
4. Add the modifier. Use 95 for video and 93 for audio-only on Medicare professional claims. RHCs and FQHCs follow their own rules (see below).
5. From January 1, 2027 add BB or BC on Medicare claims where they apply.
6. Document the visit. Record the modality and the patient's location. On audio-only visits note why video wasn't used.

How do RHCs and FQHCs bill telehealth?

RHCs and FQHCs bill behavioral telehealth differently. CMS pays behavioral health services furnished through telecommunications technology under the AIR for RHCs and the PPS for FQHCs (CMS Telehealth FAQ Q4).

For non-behavioral services the coding changed on October 1, 2026. For dates of service on or after October 1, 2026 RHCs and FQHCs "must bill the individual CPT or HCPCS codes" instead of G2025. They also report modifier 93 or 95 (MLN MM14468).

What about CPT 98000–98015?

Medicare doesn't pay them. CMS says these codes "are currently assigned status indicator I (Not valid for Medicare purposes)" and it didn't add them to the telehealth list for CY 2026 (CY 2026 PFS final rule). CMS also "finalized the replacement of HCPCS code G2012 with CPT 98016." Commercial handling varies. UnitedHealthcare for example points to its separate Replacement Codes Policy for 98000–98015 (UHC policy 2026R0046A).

Behavioral telehealth at home with no geographic limit is permanent in Medicare. What ends after December 31, 2027 is the pause on the in-person visit rule and the broader non-behavioral flexibilities.

Permanent rules

The Consolidated Appropriations Act 2021 "permanently removed geographic and place of service restrictions for behavioral health telehealth services" (CMS FAQ Q11). Patients in rural and urban areas can get behavioral telehealth at home. Two-way audio-only is allowed for behavioral health.

From January 1, 2028 audio-only for behavioral health at home continues when the practitioner can use video and the patient can't or won't (CMS FAQ Q6). CMS also lists marriage and family therapists and mental health counselors as distant site practitioners (MLN901705).

Temporary through December 31, 2027

The Consolidated Appropriations Act 2026 Sec. 6209 "extends Medicare telehealth flexibilities … through December 31, 2027" (Senate Finance section-by-section). Through that date patients can get Medicare telehealth "anywhere in the United States and territories." An extended range of practitioners can bill too (CMS FAQ Q1–Q2). RHCs and FQHCs can keep billing non-behavioral telehealth through the same date.

From January 1, 2028: the in-person rule

CMS says the law requires "an in-person, non-telehealth visit within 6 months prior to the first mental health telehealth service, effective after December 31, 2027." After that the patient needs an in-person visit within 12 months of each mental health telehealth service, with limited exceptions (CMS FAQ Q5).

Patients who started before 2028 get a break. CMS says they "will be considered established and will instead be required to have at least one in-person visit every 12 months after December 31, 2027."

Can you bill telehealth from your own home?

If you see clients from a home office, CMS says practitioners "can provide telehealth services from their home and in many cases do not need to report their home address." If you also have a physical practice location you can enroll and bill from it. Virtual-only practitioners whose only location is home need to enroll that address and can mark it as a home office for administrative or telehealth use only (CMS FAQ Q15).

What happened during the 2025 shutdown lapse?

Medicare paid shutdown-period claims as if nothing lapsed. CMS says it "will continue to pay telehealth claims in the same way they had been paid before October 1, 2025" and the flexibilities "will apply retroactively" (CMS FAQ Q16).

These dates come from CMS's FAQ as updated October 8, 2026. We'll update this post when the CY 2027 final rule is out. For how these telehealth rules fit into the rest of the claim cycle, from eligibility to denials, see our behavioral health billing guide.

Medicare's rules aren't the default for everyone. UnitedHealthcare commercial accepts POS 02 or 10 and doesn't require modifier 95. Cigna asks for POS 02 with a modifier. Medicaid differs by state.

UnitedHealthcare commercial

UHC policy 2026R0046A considers telehealth "reported with either place of service POS 02 or 10." It says "Modifiers 95, GT, GQ and G0 are not required to identify Telehealth services but are accepted as informational." For audio-only UHC wants Appendix T codes "appended with modifier 93" (UHC policy 2026R0046A).

Cigna

Cigna's R31 Virtual Care policy was last updated 02/17/2026. For behavioral health plans it wants "Modifier 93 or 95 or FQ or GQ or GT" appended and says "Place of Service 02 should be reported." For medical services it says "Please do not bill place of service 10 … until further notice" (Cigna R31).

Aetna

Aetna's public telemedicine policy PDF is several years old. Don't build rules on it. Check Aetna's current policy for the specific plan before you bill.

Medicaid and Medicaid MCOs

Each state sets its own Medicaid telehealth policy. The Center for Connected Health Policy keeps a state-by-state telehealth policy finder that covers Medicaid. Check your state and each MCO contract.

Cigna's own policy history shows how often these rules move, and a payer-specific coding review can catch mismatches before claims go out.

These errors come straight from the rules above. You can catch them before submission.

• POS 11 on a telehealth line
• POS 10 sent to a payer that wants POS 02
• FQ on a professional claim (FQ is for RHCs and FQHCs)
• GT on a Medicare professional claim (GT is for CAH Method II)
• 95 on an audio-only visit
• No reason for audio-only in the note
• Service not on the payer's telehealth list
• Patient location not recorded at check-in
• BB or BC missing on Medicare claims from January 2027

Not sure how many of these are in your claims? Start with a free revenue audit.

Telehealth rules vary by payer, plan and date of service. Check your payer policy before you bill. This isn't legal or coding advice.