Telehealth reimbursement has never been more important to get right, and in 2026, it has also never been more complex. The pandemic-era flexibility that made billing virtual visits relatively straightforward has given way to a layered system of Medicare rules, commercial payer variations, and state Medicaid policies that every practice must navigate carefully. Missing a modifier, applying the wrong place-of-service code, or using a CPT code that one payer accepts and another rejects are among the most common causes of denied telehealth claims today.
This guide covers the current reimbursement landscape so your practice can bill virtual visits accurately and confidently.
The Dual-Track Problem: 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. SecureVideo
In practice, this means:
- For Medicare: continue billing standard office E/M codes (99202-99215) with the appropriate place-of-service code and modifier. Medicare identifies telehealth delivery through POS and modifier combinations, not telehealth-specific CPT codes
- For commercial payers and many state Medicaid programs: the new 98000-series codes may be accepted, but coverage varies significantly by plan. Verify with each payer before submitting
- The one exception is CPT 98016, which replaced G2012 as the universal brief virtual check-in code accepted by both Medicare and commercial payers, covering 5-10 minute technology-based communications with established patients. SecureVideo
Place-of-Service Codes: Where Patients Connect Determines Your Payment Rate
Place of service is the single most critical element in correct telehealth billing. Using the wrong POS code results in either denied claims or overpayment audit liability. SecureVideo
- POS 10: patient is connecting from their home or residence. This pays at the higher non-facility rate and should be the default for most telehealth encounters
- POS 02: patient is connecting from a healthcare facility, clinic, or non-home location. This pays at the lower facility rate
- The most common mistake is applying POS 02 to every telehealth visit regardless of patient location. Documenting where the patient was located at the time of service is a billing requirement, not optional detail SecureVideo
Modifiers: Getting Them Right by Payer
Modifier requirements differ by payer and modality:
- Modifier 95: identifies a service delivered via real-time audio and video. Used primarily with commercial payers billing traditional E/M codes (99202-99215). Do not use for Medicare or audio-only visits
- Modifier 93: identifies audio-only services. Required by Medicare for telephone-based telehealth visits. Documentation should confirm that audio-video was available but not used due to patient limitations or preference
- Medicare no longer requires Modifier GT. The only remaining exception is Critical Access Hospitals billing under Method II Enghouse Video
Audio-Only Telehealth: What Is Still Covered
Audio-only telehealth coverage has narrowed but not disappeared:
- Medicare extended audio-only telehealth coverage through December 31, 2027. Some commercial payers have restricted audio-only reimbursement to behavioral health only, so payer-specific verification is essential before billing audio-only for other visit types SecureVideo
- Documentation must confirm why audio-video was not used and that it was available to the patient
- Behavioral health services retain expanded audio-only eligibility under Medicare with fewer restrictions than other specialties
Medicare Behavioral Health: The In-Person Requirement
Medicare mental health telehealth requires an in-person visit before initiating ongoing telehealth, meaning the first mental health visit must be in-person for Medicare patients, with rural and HPSA exceptions. Some Medicare Advantage plans and Medicaid programs also restrict new patient telehealth visits. Behavioral health providers seeing Medicare patients must verify this requirement and document the in-person visit accordingly before beginning a virtual care relationship. SecureVideo
Congressional Extensions: What Is Protected Through 2027
A congressional extension locked key Medicare telehealth flexibilities in place through December 31, 2027. This includes: SecureVideo
- Elimination of geographic restrictions for most telehealth services
- Patient home as an eligible originating site
- Continued coverage for audio-only visits where clinically appropriate
- Expanded behavioral health telehealth access
These extensions remove the year-to-year uncertainty that made long-term telehealth planning difficult and signal that virtual care reimbursement is a permanent part of the Medicare landscape.
Documentation Requirements That Protect Your Claims
Clean telehealth billing requires documentation that goes beyond what an in-person visit note typically captures:
- Patient and provider location at the time of service
- Patient consent for the telehealth encounter, documented in the chart
- Communication modality used (audio-video or audio-only) and reason if video was not used
- Medical necessity that supports the level of service billed
A HIPAA-compliant telehealth platform like SecureVideo provides the session audit trail that supports these documentation requirements. Session records, timestamps, and access logs are stored securely and available if a claim is audited.
Staying Current as Rules Evolve
Telehealth billing rules are evolving faster than almost any other area of medical billing. CMS is required under the Consolidated Appropriations Act 2026 to establish new billing codes or modifiers by 2027 to identify telehealth services delivered through third-party virtual platforms. Practices that proactively track these changes will be better positioned to maintain compliance and protect reimbursement as the regulatory landscape continues to shift. SecureVideo
The best foundation is a platform that is already built for compliance, already integrated with your workflow, and already generating the session documentation your billing team needs. Explore SecureVideo’s features or start a free trial to see how the right platform supports accurate telehealth billing.