Telehealth Billing 2026: New Modifiers, Virtual Consult Codes & Medicare Updates | 247 MBS

Telehealth has shifted from a pandemic emergency tool to a permanent pillar of American healthcare delivery. In 2026, providers face a more structured but increasingly complex telehealth billing landscape. CMS has refined which CPT codes are reimbursable, introduced new place-of-service distinctions, and clarified modifier requirements that directly affect payment. Meanwhile, the AMA's new 98000-series codes create a dual-track system where Medicare and commercial payers diverge on accepted codes for the same virtual visit.

This guide breaks down every modifier, code set, and reimbursement rule you need to bill telehealth services correctly in 2026. Whether you manage a multi-provider practice or a solo telehealth clinic, understanding these changes is critical for clean claims and optimal revenue. For a foundational overview of telehealth CPT codes and their modifier pairings, see our complete reference on Telehealth CPT Codes for 2025-2026: Updated List with Modifiers.

1. The 2026 Legislative Foundation: What Congress Extended

The bipartisan spending legislation signed into law extended Medicare telehealth flexibilities through December 31, 2027, providing a two-year runway for providers to plan. This extension preserved several pandemic-era provisions that would have otherwise expired, including geographic and originating-site waivers, audio-only coverage for behavioral health, and FQHC/RHC telehealth billing authority.

Key Provisions Extended Through 2027

• Geographic restrictions waived: Medicare beneficiaries can receive telehealth services regardless of whether they reside in a rural or urban area

• Originating-site flexibility: Patients can receive telehealth from their homes (POS 10), not just designated healthcare facilities
• Audio-only coverage: Non-behavioral telehealth services can still be delivered via audio-only platforms, though with specific modifier and documentation requirements
• FQHC and RHC billing: Federally Qualified Health Centers and Rural Health Clinics retain authority to serve as distant-site providers for telehealth services using HCPCS code G2025
• In-person visit requirement suspended: The requirement for an in-person visit within six months of a mental health telehealth service remains waived

Providers should treat this extension as planning time, not a permanent guarantee. CMS has signaled that future rulemaking may tighten eligibility criteria. For detailed CMS policy guidance, review our analysis of CMS Telehealth Billing Guidelines 2026: Complete Medicare Policy & Reimbursement Guide.

2. The Dual-Track CPT Code System: Medicare vs. Commercial Payers

The most significant billing complexity in 2026 is the divergence between Medicare and commercial payer code acceptance. The AMA introduced a dedicated telehealth E/M code series (98000-98016) in 2025, but CMS determined these codes are duplicative of existing E/M codes with modifiers and declined to reimburse most of them under Medicare. This creates two parallel billing tracks that every practice must navigate.

Track 1: Medicare Telehealth Billing

For Medicare Fee-for-Service claims, providers continue using standard office E/M codes (99202-99215) with appropriate place-of-service codes and modifiers. Medicare identifies telehealth delivery through POS and modifier combinations rather than telehealth-specific CPT codes.

Medicare-accepted telehealth codes: 99202-99215 (office E/M), 99421-99423 (e-visits), 98016 (brief virtual check-in, replacing G2012), G2025 (FQHC/RHC telehealth)

Track 2: Commercial and Medicaid Payer Billing

Commercial insurers and many state Medicaid programs accept the new 98000-series codes. These codes explicitly describe the telehealth modality in their descriptors, eliminating the need for Modifier 95.

Audio-Video Codes (98000-98007) — New Patient

CPT Code	MDM Level	Time Threshold	Description
98000	Straightforward	15 min	New patient audio-video visit, straightforward MDM
98001	Low	30 min	New patient audio-video visit, low complexity MDM
98002	Moderate	45 min	New patient audio-video visit, moderate MDM
98004	High	60 min	New patient audio-video visit, high complexity MDM

 

Audio-Video Codes (98004-98007) — Established Patient

CPT Code	MDM Level	Time Threshold	Description
98005	Low	20 min	Established patient audio-video visit, low MDM
98006	Moderate	30 min	Established patient audio-video visit, moderate MDM
98007	High	40 min	Established patient audio-video visit, high MDM

 

Audio-Only Codes (98008-98015)

CPT Code	Patient	MDM Level	Time	Description
98008	New	Straightforward	10+ min	Audio-only, new patient, straightforward MDM
98009	New	Low	30+ min	Audio-only, new patient, low MDM
98010	New	Moderate	45+ min	Audio-only, new patient, moderate MDM
98011	New	High	60+ min	Audio-only, new patient, high MDM
98012	Established	Low	20+ min	Audio-only, established patient, low MDM
98014	Established	Moderate	30+ min	Audio-only, established patient, moderate MDM
98015	Established	High	40+ min	Audio-only, established patient, high MDM

 

Brief Virtual Check-In: CPT 98016

CPT 98016 replaced HCPCS code G2012 as the universal brief virtual check-in code accepted by both Medicare and commercial payers. This code covers 5-10 minute technology-based communications (audio or audio-video) with established patients. The service cannot relate to an E/M visit within the prior 7 days or result in an E/M visit within 24 hours. Medicare reimburses 98016 at approximately $16.50 nationally. For a deeper understanding of how modifier rules apply to these codes, refer to our detailed guide on Modifiers for Telehealth and Telemedicine Services.

3. Telehealth Modifier Requirements in 2026

Modifier usage in telehealth billing has become more nuanced in 2026. The correct modifier depends on the payer, the code set used, and the communication modality. Incorrect modifier application is one of the top causes of telehealth claim denials.

Modifier 95 — Synchronous Audio-Video

Modifier 95 indicates a service was rendered via real-time audio-video communication. For commercial payers using traditional E/M codes (99202-99215), Modifier 95 remains required to flag the visit as telehealth. However, Modifier 95 is NOT required when billing the new 98000-98007 audio-video codes, since these codes already describe the telehealth modality in their descriptors. Medicare does not require Modifier 95 because it relies on POS codes to identify telehealth.

Modifier 93 — Audio-Only Services

Modifier 93 identifies services provided exclusively through audio communication without video capability. Medicare requires Modifier 93 on all audio-only telehealth claims when billing traditional E/M codes. This modifier distinguishes telephone-based visits from video-enabled telehealth and is critical for accurate reimbursement tracking.

Modifier GT — Legacy Consideration

Modifier GT (via interactive audio and video telecommunications systems) is largely obsolete for most payers in 2026. Medicare no longer requires it. The one exception is Critical Access Hospitals billing under Method II, where GT remains necessary. Providers should check individual commercial payer policies, as a small number still require GT.

Modifier FQ — FQHC/RHC Audio-Only

Modifier FQ is reserved for Federally Qualified Health Centers and Rural Health Clinics providing audio-only telehealth services. It can be used alongside Modifier 93 when required by the payer.

Quick-Reference: Modifier Selection Matrix

Scenario	Modifier	POS Code	Notes
Medicare video visit (patient at home)	None required	POS 10	POS 10 identifies telehealth to home
Medicare video visit (patient at clinic)	None required	POS 02	POS 02 identifies telehealth to facility
Medicare audio-only visit	93	POS 10 or 02	Modifier 93 mandatory for audio-only
Commercial payer — E/M codes + video	95	POS 02 or 10	Check payer-specific POS policy
Commercial payer — 98000-98007 codes	None required	POS 02 or 10	Modality built into code descriptor
Commercial payer — audio-only 98008-98015	None required	POS 02 or 10	Modality built into code descriptor
FQHC/RHC audio-only	FQ (+ 93)	Per payer	G2025 covers all telehealth at $97.53
CAH Method II	GT	POS 02	Only scenario where GT is still required

 

4. Place of Service Codes: POS 02 vs. POS 10

The distinction between POS 02 (Telehealth Provided Other Than in Patient's Home) and POS 10 (Telehealth Provided in Patient's Home) directly affects reimbursement rates. CMS pays the nonfacility rate for POS 10 claims, which is typically higher than the facility rate applied to POS 02 claims.

POS Code	Description	Payment Rate	When to Use
POS 02	Telehealth Other Than Home	Facility rate	Patient at clinic, nursing facility, or other healthcare site
POS 10	Telehealth in Patient's Home	Nonfacility rate	Patient connects from their residence

 

Billing Tip: Since most telehealth patients connect from home, POS 10 is the more commonly used code and yields the higher nonfacility payment. However, documentation must support the patient's location. If the patient is at a satellite clinic or SNF receiving a telehealth consult, POS 02 applies regardless of the higher reimbursement available under POS 10. Ensuring accurate eligibility verification and benefits confirmation before the visit helps confirm payer-specific POS requirements.

5. Medicare Telehealth Reimbursement Rates and Rules

Medicare telehealth reimbursement in 2026 follows the Physician Fee Schedule with specific adjustments for virtual delivery. Understanding the payment structure helps practices forecast revenue and identify underpayment.

Key Reimbursement Benchmarks

Service	CPT/HCPCS	Approximate National Rate	Notes
New patient E/M (moderate, video)	99203 + POS 10	$110-130	Nonfacility rate, varies by GPCI
Established patient E/M (moderate, video)	99214 + POS 10	$130-150	Most common telehealth visit level
Brief virtual check-in	98016	~$16.50	Replaced G2012; 5-10 min
E-visit (online digital eval)	99421	~$18.00	5-10 min cumulative patient portal
E-visit (online digital eval)	99422	~$36.00	11-20 min cumulative
E-visit (online digital eval)	99423	~$55.00	21+ min cumulative
FQHC/RHC all telehealth	G2025	$97.53	Flat rate regardless of E/M level
Originating site facility fee	Q3014	$31.85	Paid to facility hosting patient

 

Audio-Only Reimbursement Considerations

While Medicare continues to cover audio-only telehealth through 2027, reimbursement rates for audio-only visits may be lower than audio-video equivalents, depending on how the MAC processes the claim. Commercial payers are increasingly restricting audio-only reimbursement: Cigna and Aetna have narrowed coverage to behavioral health and specific chronic disease management scenarios. Practices relying heavily on audio-only delivery should verify payer policies quarterly.

6. Common ICD-10 Codes for Telehealth Encounters (Connector-Verified)

Telehealth encounters span virtually every specialty, but certain diagnoses appear most frequently in virtual visits. The following codes have been verified through the ICD-10 diagnostic code connector and are HIPAA-valid for billing. Selecting the most specific code supported by documentation remains essential for clean claims. For an in-depth reference on diagnosis coding for virtual visits, see our guide on Most Common ICD-10 Codes for Telemedicine Service Providers.

Behavioral Health (Top Telehealth Category)

ICD-10 Code	Description	Telehealth Relevance
F32.1	Major depressive disorder, single episode, moderate	Most common telehealth behavioral health diagnosis
F33.1	Major depressive disorder, recurrent, moderate	Ongoing medication management via video
F41.1	Generalized anxiety disorder	High-volume telehealth visits for therapy/med checks
F41.0	Panic disorder [episodic paroxysmal anxiety]	Acute management and follow-up via telehealth
F41.9	Anxiety disorder, unspecified	Initial evaluation pending diagnostic workup
F43.22	Adjustment disorder with anxiety	Situational counseling well-suited to virtual care

 

Chronic Disease Management

ICD-10 Code	Description	Telehealth Use Case
I10	Essential (primary) hypertension	RPM follow-up, medication titration via video
E11.65	Type 2 diabetes mellitus with hyperglycemia	Glucose review, insulin adjustment, diet counseling
E11.21	Type 2 DM with diabetic nephropathy	Specialist e-consult and care coordination
J45.20	Mild intermittent asthma, uncomplicated	Asthma action plan review, refill management
G47.33	Obstructive sleep apnea (adult/pediatric)	CPAP compliance review, sleep study follow-up

 

Acute/Episodic Care

ICD-10 Code	Description	Telehealth Use Case
J06.9	Acute upper respiratory infection, unspecified	Virtual urgent care triage and treatment
Z00.00	Encounter for general adult medical exam without abnormal findings	Wellness check-in, preventive counseling

 

7. Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) Code Updates

The 2026 Medicare Physician Fee Schedule introduced significant changes to RPM and RTM billing that expand access while adding new code options. These changes directly impact practices that combine telehealth visits with ongoing remote monitoring programs. For implementation guidance, review our guide on Billing for Remote Patient Monitoring (RPM)  and our analysis of Remote Patient Monitoring Technology: RPM and RTM.

2026 RPM Code Changes

CPT Code	Service	Rate (Approx.)	Key Requirement
99453	RPM device setup and patient education	~$22.00	One-time per device; requires education
99454	RPM device supply, 16+ days data/30 days	~$64.00	Minimum 16 days of transmitted data
99445 (NEW)	RPM device supply, 2-15 days data/30 days	~$32.00	New lower-tier; cannot bill with 99454
99457	RPM treatment management, first 20 min	~$52.00	Interactive communication required
99458	RPM treatment management, add'l 20 min	~$41.00	Each additional 20-min increment
99470 (NEW)	RPM treatment management, <20 min	~$26.00	New lower-tier management code

 

Critical Change: The data transmission threshold has been restructured. Practices can now bill CPT 99445 for patients who transmit 2-15 days of data in a 30-day period, capturing revenue from patients with lower compliance who previously generated no reimbursement. However, 99445 and 99454 cannot be billed concurrently for the same patient in the same 30-day period.

8. Behavioral and Mental Health Telehealth Billing

Behavioral health remains the highest-volume telehealth specialty, accounting for over 60% of all telehealth claims. The 2026 billing framework includes specific provisions that affect mental health providers. Practices managing virtual therapy and psychiatric services should also reference our guide on Teletherapy and Virtual Mental Health Billing for specialty-specific workflows, and our overview of Navigating Mental Health Billing Challenges [Link: https://www.247medicalbillingservices.com/blog/navigating-mental-health-billing-challenges] for denial-reduction strategies.

Key 2026 Behavioral Health Provisions

• In-person visit waiver extended: The requirement for an in-person visit within 6 months of a mental health telehealth encounter remains waived through December 31, 2027

• Audio-only behavioral health: Fully covered under Medicare when Modifier 93 is applied; audio-only is appropriate for established patients where video adds minimal clinical value
• Psychiatric diagnostic evaluation (90791/90792): Billable via telehealth with POS 10 and appropriate modifier; some payers require video for initial evaluations
• Psychotherapy add-on codes (90833/90836/90838): Can be appended to telehealth E/M codes when psychotherapy is provided during the same session
• Collaborative care management (99492-99494): CMS continues to support billing these codes for telehealth-delivered psychiatric consultations within the CoCM model

9. Top Telehealth Claim Denial Reasons and Prevention Strategies

Telehealth claims carry a higher denial rate than in-person visits, primarily due to modifier and POS errors. Proactive denial prevention starts with understanding the most common rejection reasons. For a comprehensive approach to managing denials and appeals across all service types, see our resource on Billing Guidelines for Telehealth Clinics.

Denial Reason	Root Cause	Prevention Strategy
Missing or incorrect modifier	Modifier 95/93 omitted or misapplied	Build payer-specific modifier rules into EHR/PM system
Invalid POS code	POS 02 used when patient is at home (should be POS 10)	Verify patient location at every telehealth encounter
Service not on payer telehealth list	CPT code not eligible for telehealth with that payer	Maintain updated payer telehealth code matrices
Medicare 98000-98015 rejection	Billing new CPT codes that Medicare does not reimburse	Use 99202-99215 for Medicare; reserve 98000-series for commercial
Audio-only not covered	Payer does not reimburse audio-only for the diagnosis	Verify audio-only eligibility before scheduling; use video when possible
Missing documentation of modality	Chart note does not specify audio-video vs audio-only	Template telehealth notes to capture platform, modality, and patient location
Timely filing exceeded	Telehealth claims processed without urgency	Set 48-hour telehealth claim submission targets
Duplicate claim (98016 vs G2012)	Billing retired G2012 instead of 98016	Update charge master to replace G2012 with 98016 effective Jan 1, 2026

 

10. Telehealth Billing Compliance Checklist for 2026

Maintaining billing compliance requires systematic processes that adapt to regulatory changes. The following checklist addresses the most critical compliance areas for telehealth billing in 2026. Practices should also ensure that all telehealth providers complete proper credentialing and enrollment with each payer before rendering virtual services.

• Verify that your EHR/PM system correctly maps POS 02 and POS 10 based on patient location documentation
• Update charge master to replace G2012 with 98016 for brief virtual check-ins
• Configure dual coding pathways: Medicare (99202-99215 + POS) vs. commercial (98000-98016)
• Build automatic Modifier 93 appending for audio-only encounters in your billing software
• Maintain a current telehealth-eligible CPT code list for each contracted payer
• Document patient consent for telehealth in the medical record per state law requirements
• Record the telehealth platform used, communication modality (audio-video or audio-only), and patient location in every encounter note
• Verify provider licensure in the patient's state for interstate telehealth (state licensure compacts vary)
• Monitor RPM data transmission counts to select between 99445 (2-15 days) and 99454 (16+ days) accurately
• Conduct quarterly audits of telehealth claims to identify modifier and POS code error patterns

11. Chronic Care Management (CCM) and Telehealth Integration

Telehealth visits pair naturally with Chronic Care Management services, and CMS allows concurrent billing of CCM and telehealth E/M codes when all service requirements are independently met. For practices managing patients with chronic conditions like hypertension (I10) and diabetes (E11.65), this creates a dual-revenue opportunity. Our guide on Billing for Chronic Care Management (CCM) Services  details the specific documentation and time thresholds required.

CCM Code	Time Requirement	Rate (Approx.)	Telehealth Compatible
99490	20 min clinical staff time/month	~$64.00	Yes — can bill with telehealth E/M
99491	30 min physician/QHP time/month	~$87.00	Yes — requires physician involvement
99439	Each additional 20 min (after 99490)	~$47.00	Yes — track time separately from E/M

 

Frequently Asked Questions

Q: Does Medicare accept the new 98000-98015 telehealth CPT codes in 2026?

A: No. CMS has determined that codes 98000-98015 are duplicative of existing E/M codes with modifiers and does not reimburse them. Medicare providers should continue billing 99202-99215 with POS 02 or POS 10 and Modifier 93 for audio-only visits. The exception is CPT 98016 (brief virtual check-in), which replaced G2012 and is accepted by Medicare.

Q: What is the difference between POS 02 and POS 10 for telehealth billing?

A: POS 02 (Telehealth Provided Other Than in Patient's Home) applies when the patient connects from a healthcare facility, clinic, or non-home location. POS 10 (Telehealth Provided in Patient's Home) applies when the patient connects from their residence. POS 10 pays at the higher nonfacility rate, while POS 02 pays the facility rate.

Q: When should I use Modifier 95 vs. Modifier 93 for telehealth claims?

A: Modifier 95 indicates synchronous audio-video telehealth and is used primarily with commercial payers when billing traditional E/M codes (99202-99215). Modifier 93 indicates audio-only services and is required by Medicare for all telephone-based telehealth visits. If using the new 98000-98015 codes for commercial payers, neither modifier is needed because the modality is built into the code descriptor.

Q: Are audio-only telehealth visits still covered by Medicare in 2026?

A: Yes. Congress extended Medicare audio-only telehealth coverage through December 31, 2027 for both behavioral health and non-behavioral health services. Providers must append Modifier 93 to identify audio-only delivery. However, some commercial payers (notably Cigna and Aetna) have restricted audio-only reimbursement to behavioral health and specific chronic conditions.

Q: What are the new RPM codes for 2026 and how do they differ from existing codes?

A: CMS introduced CPT 99445 for RPM device supply when 2-15 days of data are transmitted (versus 99454 for 16+ days) and CPT 99470 for treatment management under 20 minutes (versus 99457 for 20+ minutes). These lower-tier codes capture revenue from patients with lower monitoring compliance. You cannot bill 99445 and 99454 concurrently for the same patient in the same 30-day period.

Q: How do FQHCs and RHCs bill for telehealth services in 2026?

A: FQHCs and RHCs use HCPCS code G2025 for all telehealth services, which pays a flat rate of $97.53 regardless of the E/M level. This single code covers any of the 280+ services billable via telehealth. For audio-only services, FQHCs/RHCs append Modifier FQ (and Modifier 93 if required by the payer).