Behavioral Health Telehealth Billing: Codes, Modifiers and Place of Service

Mukesh MakwanaFounder & CEO · Hands-on medical billing & RCM across 11 specialties · Reviewed October 1, 2026

Behavioral health is the one part of Medicare telehealth that does not hang on the next extension. Its geographic and site freedoms are permanent law. What still changes on fixed dates is narrower: audio-only conditions, an in-person visit rule, and who else may bill. Most telehealth denials in mental health billing are not about any of that. They come from the claim describing the visit differently from the note.

Telehealth billing codes for mental health

There is no separate set of telehealth codes for therapy or psychiatry. A telehealth session is billed with the same CPT or HCPCS code as the in-person service, and the claim shows it was remote through the place of service and, where required, a modifier. What matters is whether the code is on the Medicare Telehealth Services List. For calendar year 2026 the behavioral health codes on that list include:

Two groups of codes are commonly misfiled here:

• Collaborative care and behavioral health integration (99492, 99493, 99494, 99484) are not on the list, and they do not need to be. CMS explains that services which are not a substitute for an in-person encounter are not subject to the Medicare telehealth rules at all.
• CPT's telemedicine visit codes 98000 to 98015, the audio-video and audio-only E/M family, carry PFS status indicator I in the 2026 relative value file: not valid for Medicare. A prescriber seeing a Medicare patient remotely bills the ordinary office visit code with telehealth place of service instead. Some commercial payers do accept the 98000 family, so this is a payer-by-payer setting.

Place of service: 02 or 10

For Medicare professional claims, place of service is the primary telehealth signal:

• POS 10, telehealth provided in the patient's home. CMS defines home as a location other than a hospital or other facility where the patient receives care in a private residence.
• POS 02, telehealth provided somewhere other than the patient's home.

Since January 1, 2024, Medicare pays telehealth claims for patients at home at the non-facility rate. For most psychotherapy codes that is the higher rate, so a home session sent with POS 02, or with the office code 11, quietly underpays rather than denying. That is why place of service errors can run for a year before anyone notices.

The clinician's own location matters for enrollment rather than for the claim. CMS confirms practitioners may deliver telehealth from home, and those with a physical practice location bill from that location as if the service were in person. A virtual-only clinician whose only practice location is home must enroll that address, and can mark it as a home office for administrative or telehealth use only so the street address is suppressed on Care Compare.

Telehealth modifiers: 95, 93, FQ, GT and FR

The rule that prevents most modifier denials is simple: the modifier has to describe the technology the note says was used. A phone session with 95 on the line is a claim that says video happened. On review that is a record that contradicts itself.

FR became more relevant this year. From January 1, 2026, CMS permanently allows the presence required for direct supervision to be virtual, through real-time audio and video but not audio only, for services without a 010 or 090 global period. That includes most incident-to services.

Audio-only: what is allowed now and from 2028

For behavioral health, the Consolidated Appropriations Act, 2021 permanently removed geographic and place of service restrictions, and two-way interactive audio-only technology is permitted. Patients in rural and urban areas alike can receive behavioral health telehealth at home.

The detail that changes is the condition attached to audio-only. Under current law, beneficiaries may receive audio-only telehealth in their homes through December 31, 2027. From January 1, 2028, audio-only remains available for behavioral health at home on two conditions: the clinician is technically capable of audio-video, and the patient is not capable of, or does not consent to, video. CMS states that audio-only can be used for both new and established patients.

The practical step for 2026 and 2027 is to start recording the reason a session was audio-only now. When the condition becomes binding, the habit will already be in the template.

The in-person visit requirement

Federal law requires an in-person, non-telehealth visit within 6 months before the first mental health telehealth service, but that requirement takes effect only after December 31, 2027. CMS sets out how it will work:

• Patients already in care are established. A beneficiary who began receiving mental health telehealth at home on or before December 31, 2027 does not need the 6-month prior visit. They need at least one in-person visit every 12 months after that date.
• New patients from 2028 need an in-person service within the 6 months before the first home telehealth session, then an in-person service within 12 months of each telehealth service, with limited exceptions.
• Colleagues can cover it. If the treating clinician is unavailable, the in-person visit may be performed by a clinician of the same specialty in the same group practice.
• Rural health clinics and FQHCs: the in-person requirement for their behavioral health visits will not apply until at least January 1, 2028.

A practice that starts tracking each telehealth patient's last in-person date during 2027 will have nothing to scramble for in January 2028.

Rural health clinics and FQHCs

Behavioral health services that a rural health clinic or federally qualified health center furnishes through telecommunications technology have been paid under the all-inclusive rate and the prospective payment system respectively since January 1, 2022. Through December 31, 2027, these clinics may also bill non-behavioral health services delivered remotely by reporting HCPCS G2025. The home and any geographic location may serve as the site for their patients. Audio-only behavioral health visits from these clinics carry modifier FQ.

What else ends on December 31, 2027

Behavioral health is insulated, but the practices around it are not. Through December 31, 2027 any Medicare patient can receive telehealth anywhere in the country. From January 1, 2028, outside behavioral health, patients will generally need to be in a medical facility in a rural area. The same date ends telehealth billing by physical therapists, occupational therapists, speech-language pathologists and audiologists. A multispecialty group that runs therapy and medical telehealth side by side should plan for two different rule sets from that date.

Common telehealth denials and the fix

Documentation checklist for every telehealth session

• Technology used: real-time audio and video, or audio only.
• For audio-only, why video was not used.
• Where the patient was, and whether that was their home.
• Where the clinician was, for your own enrollment records.
• Everything the in-person note would contain: time where the code is timed, the intervention, the diagnosis and progress against the plan.
• For patients you expect to keep treating remotely after 2027, the date of the most recent in-person visit.

Code-specific telehealth details sit on each code guide, starting with 90837, 90834 and the prescriber's add-on 90833. The psychotherapy add-on guide covers how a remote medication visit is coded.

Frequently asked questions

Sources

Centers for Medicare & Medicaid Services, Telehealth FAQ, updated February 26, 2026: dates through December 31, 2027 and from January 1, 2028, audio-only, the in-person visit requirement, place of service, virtual direct supervision, rural health clinics and FQHCs, and practitioner enrollment from home.
Centers for Medicare & Medicaid Services, List of Telehealth Services for Calendar Year 2026: the behavioral health codes on the Medicare telehealth list.
Centers for Medicare & Medicaid Services, CY 2026 PFS Relative Value File RVU26D (October release, published 08/26/2026): PFS status indicator I for CPT 98000 to 98015.
Centers for Medicare & Medicaid Services, HCPCS Level II alpha-numeric file, October 2026 release: descriptors for modifiers FQ, FR and GT.
Centers for Medicare & Medicaid Services, CY 2022 Physician Fee Schedule final rule, CMS-1751-F: audio-only mental health telehealth and the modifiers that identify it.
American Medical Association, CPT 2026 Professional Edition: modifiers 93 and 95.

CPT® is a registered trademark of the American Medical Association. This guide describes Medicare fee-for-service rules. Commercial plans and state Medicaid programmes set their own telehealth policies, and dates in federal law can change, so check the current policy for each payer before submission. How we verify this guidance.

Related reading

• Behavioral health & psychiatric billing. How we scrub session-based claims, track prior authorization and bill collaborative care.
• Psychotherapy add-on coding. How the add-on psychotherapy codes pair with an E/M visit and where the time rules bite.
• 2026 behavioral health code changes. What the CY 2026 fee schedule changed for collaborative care, digital mental health and telehealth.
• Behavioral health prior authorization in 2026. Why authorizations lapse mid-episode and what catching them early is worth.
• Free credentialing for new billing clients. Credentialing with 3 insurance payers at no cost when you start billing with us.