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Medical Billing8 min read

Telemedicine Billing: How to Actually Get Paid for Virtual Visits

Telehealth is a real revenue opportunity — but only if you bill it correctly. The codes, modifiers, place of service rules, and payer requirements for virtual visits are different from in-person care and change frequently. Here's what you need to know.

M
Medbillytics Team
July 1, 2024

Telemedicine has moved from pandemic-era necessity to permanent fixture in most practices. The convenience for patients is real. The clinical value for chronic disease management, behavioral health, and follow-up care is documented. And for practices that bill virtual visits correctly, the revenue opportunity is substantial.

The problem is that telehealth billing is genuinely more complex than in-person billing — and the rules change more frequently than almost any other area of medical billing. Practices that don't stay current with telehealth-specific coding requirements, place of service rules, and payer policies leave money on the table or generate denials on claims they should be collecting.

Here's what you need to know to bill telemedicine correctly in 2026.

The Difference Between Telehealth, Telemedicine, and Virtual Check-Ins

These terms are used interchangeably in practice but have specific billing meanings:

Synchronous telehealth (traditional telemedicine) — a real-time audio-video visit between provider and patient. Billed using standard E/M CPT codes with specific place of service codes and modifiers.

Audio-only visits — a real-time telephone visit without video. Has a separate set of CPT codes (99441–99443) and payer-specific coverage rules. Medicare covers audio-only for behavioral health; coverage for other services varies.

Virtual check-ins (G2012) — a brief, patient-initiated check-in with an established patient to determine whether a visit is needed. 5–10 minutes. Not the same as a synchronous telehealth visit.

E-visits / online digital evaluation and management (99421–99423) — asynchronous, patient-initiated communication through a patient portal. Provider reviews and responds within 7 days. Distinct from synchronous visits and has its own documentation and coverage rules.

Billing the wrong code type for the service rendered is one of the most common telehealth billing errors — and it produces denials that are preventable with the right code selection.

Place of Service Codes for Telehealth

Place of service (POS) codes tell payers where the service was rendered. For telehealth, this is both technically specific and frequently misunderstood.

POS 02 — Telehealth, patient not in their home. Used when the patient receives services via telehealth at a location other than their home — for example, a telehealth visit conducted from a rural health clinic or federally qualified health center.

POS 10 — Telehealth, patient in their home. This is the code for the vast majority of telehealth visits in 2026 — patients connecting from their homes. CMS adopted POS 10 permanently following the COVID-19 public health emergency flexibilities.

The POS-reimbursement relationship matters: POS 02 is reimbursed at the facility rate (lower). POS 10 is reimbursed at the non-facility rate (higher). Using POS 02 when the patient is at home means you're accepting the facility rate when you're entitled to the non-facility rate. This is a systematic underpayment error that affects every virtual visit it touches.

The GT Modifier and When It's Still Required

Modifier GT (via interactive audio and video telecommunications systems) was widely required during and after the public health emergency. As of 2024, Medicare no longer requires GT on claims when POS 10 or 02 is used — the POS code itself communicates the telehealth nature of the service.

However: many commercial payers still require modifier GT or 95 (synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system) on telehealth claims. Check each payer's current telehealth billing requirements — don't assume what Medicare requires (or doesn't require) applies to your commercial contracts.

E/M Coding for Telehealth Visits

Synchronous telehealth visits billed to Medicare use the same E/M CPT codes as in-person visits (99202–99215) under the same MDM or time-based coding rules that apply in-office. There is no separate "telehealth E/M" code.

The documentation requirements are identical to in-person visits. The medical decision making, time documentation, and clinical specificity standards don't change because the visit happened virtually. A telehealth 99215 requires the same documentation as an in-person 99215.

For time-based coding during telehealth: the time documented includes all the usual activities — reviewing records, documenting, ordering — plus the real-time interaction. Total time is calculated the same way.

Audio-only E/M codes are separate:

  • 99441: 5–10 minutes of medical discussion
  • 99442: 11–20 minutes
  • 99443: 21–30 minutes

These are specifically for telephone services without video. Medicare covers these with restrictions (established patients, specific qualifying circumstances for some services). Commercial payer coverage varies — verify before billing.

Behavioral Health Telehealth: Different Rules Apply

Mental health and behavioral health telehealth has its own coding landscape. The primary codes used for individual psychotherapy via telehealth are 90832–90838, with add-on codes for E/M services when combined with psychotherapy.

For Medicare behavioral health telehealth specifically:

  • Audio-only psychotherapy is covered for established patients when video isn't technically feasible and the patient is in their home
  • The provider must document the patient's inability to use video in the note
  • POS 10 applies when the patient is at home

For commercial payers, mental health carve-outs (where behavioral health coverage is managed by a separate entity from the medical plan) create additional billing complexity. The billing entity may be different from the primary payer, and telehealth-specific policies may differ from the commercial plan's general telehealth rules.

Common Telehealth Billing Mistakes That Generate Denials

Using POS 02 when the patient is at home. Results in facility-rate reimbursement instead of non-facility rate. Systematic underpayment.

Missing or incorrect modifier. Commercial payer requires modifier 95 or GT, claim submitted without it. Immediate denial.

Audio-only visit billed as synchronous telehealth. The service type doesn't match the code. Denial.

Billing new patient E/M codes for established patients via telehealth. For many telehealth services, payers require the patient to have had an in-person visit before virtual-only visits qualify for new patient E/M code levels. Check payer-specific rules.

Credentialing not updated for telehealth services. Some payers require specific telehealth enrollment or credentialing updates. Billing telehealth before confirming your credentialing covers it produces denials that aren't about the coding — they're about provider enrollment.

The Revenue Opportunity Is Real — If You Bill It Right

A practice that sees 10 telehealth patients per day, correctly codes each as 99214 with POS 10 instead of POS 02, and has the correct modifiers in place for each payer is collecting meaningfully more on those visits than one that's making systematic errors. Over a full year, the compounding effect is significant.

More importantly, practices that manage telehealth billing correctly retain the flexibility to offer virtual care as a genuine service line rather than a logistical workaround — which improves patient access, reduces no-shows, and supports the kind of chronic disease management that builds long-term patient relationships.


Having issues with telehealth claim denials or want to make sure your virtual visit billing is optimized? Talk to our billing team — we manage telehealth billing across all major payers and can audit your current telehealth claims to find what's being lost.

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