Telehealth Billing Rules in 2026: What Changed and What to Watch

Telehealth billing has evolved dramatically since 2020, moving from a narrow set of rural Medicare codes to a nearly universal delivery method covered by most major payers. But "universal coverage" doesn't mean "uniform billing rules." In 2026, telehealth billing remains a patchwork of Medicare regulations, state Medicaid policies, and commercial payer requirements — each with distinct modifiers, place of service codes, and covered service lists.

This guide covers everything you need to know to bill telehealth correctly in 2026, including what changed at the start of the year and what compliance risks to watch.

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The Current State of Telehealth Coverage (2026)

Medicare Telehealth

Medicare's telehealth expansion, first authorized under COVID-19 public health emergency (PHE) waivers, has been gradually made permanent through statute and extended year-by-year for provisions still pending full permanence.

What is permanent as of 2026:

• Mental/behavioral health telehealth services (no rural/geographic restriction for mental health)
• Federally qualified health centers (FQHCs) and rural health clinics (RHCs) as distant sites
• Coverage in any setting, including patient's home (POS 10)
• Audio-only mental health services for established patients in limited circumstances via HCPCS code G2252

Extended through 2026 (subject to future Congressional action):

• Telehealth for non-mental health services regardless of geographic location
• Hospital outpatient departments as distant sites
• Expanded list of telehealth providers (physical therapists, occupational therapists, speech-language pathologists, audiologists)
• Audio-only services when patient lacks video capability

Expiration risk: Congressional telehealth extensions have been renewed continuously but in short windows. Practices that have built substantial telehealth revenue should monitor CMS announcements in Q3–Q4 2026 for potential changes to non-mental health telehealth geographic restrictions.

Commercial Payer Telehealth

As of 2026, all major commercial payers (UnitedHealthcare, Aetna, Anthem BCBS, Cigna, Humana) cover telehealth services. The practical differences are in:

• Specific services covered (some limit to E/M visits; others cover therapy, testing, etc.)
• Modifier requirements (modifier 95 standard; some use GT)
• Platform requirements (must be HIPAA-compliant; some payers reject consumer apps)
• Parity laws (35+ states now require payment parity for telehealth)

State Medicaid Telehealth

State Medicaid programs vary significantly. Key 2026 updates:

• California Medi-Cal: Expanded synchronous audio-visual and audio-only coverage, including store-and-forward for dermatology and ophthalmology
• Texas Medicaid: Covers telehealth for behavioral health; limited for primary care
• New York Medicaid: Strong telehealth parity; covers audio-only for behavioral health
• Florida Medicaid: Expanded managed care plan telehealth requirements post-2024 legislation

Always verify current Medicaid telehealth rules through your state Medicaid provider portal — they update frequently.

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Telehealth Place of Service (POS) Codes

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.

POS Code	Description	When to Use
POS 02	Telehealth, patient not at home	Patient at FQHC, RHC, medical facility, school, etc.
POS 10	Telehealth, patient at home	Patient receiving service from their home — most common for 2026
POS 11	Office	In-person at provider location; NEVER used for telehealth
POS 22	Outpatient Hospital	In-person at hospital outpatient; not telehealth

The POS 10 default: For the vast majority of telehealth visits since 2022, the patient is at home. POS 10 should be the default for patient-at-home telehealth.

Reimbursement impact (Medicare):

• POS 10 and POS 02 claims are reimbursed differently for some services
• For most E/M services, Medicare pays the lower "non-facility" rate regardless of POS when delivered via telehealth — which is actually HIGHER than the facility rate in most cases
• Verify reimbursement rates in the Medicare Physician Fee Schedule for your specific codes

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Telehealth Modifiers

Different payers use different modifiers to identify telehealth services:

Modifier	Meaning	Who Uses It
95	Synchronous telemedicine service via real-time audio-video	Most commercial payers; AMA standard
GT	Via interactive audio and video telecommunications	Medicaid programs; some commercial payers
GQ	Via asynchronous telecommunications (store-and-forward)	Limited telehealth; dermatology, radiology reads
CR	Catastrophe/disaster related	Legacy COVID waiver modifier; largely retired
FQ	Audio-only service (Medicare, limited)	Medicare audio-only when appropriate
G0	(HCPCS) Unrelated to telehealth but sometimes confused	Do not use for telehealth

Medicare rule: Medicare uses POS 02 or POS 10 rather than modifiers to identify telehealth for MOST services. Modifier 95 is not typically used for Medicare fee-for-service — but it IS required for most commercial/Medicare Advantage payers.

Practical crosswalk:

• Medicare FFS: POS 10 (no modifier needed for real-time A/V)
• Medicare Advantage: Varies by plan — most require modifier 95
• UnitedHealthcare commercial: Modifier 95 required
• Aetna commercial: Modifier 95 required
• Anthem/BCBS: Modifier 95 required (GT accepted in some states)
• Medi-Cal: GT modifier required

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Key Telehealth CPT Codes in 2026

Evaluation & Management (E/M) Telehealth

Standard E/M codes (99202–99215, 99241–99245) are used for telehealth visits, with the appropriate POS and modifier. No special code is needed — the POS and modifier signal telehealth to the payer.

Telephone-Only (Audio-Only) Services

When video is not available or appropriate:

Code	Description	Coverage
99441	Telephone E/M, 5–10 minutes	Commercial payers (dropping coverage)
99442	Telephone E/M, 11–20 minutes	Commercial payers
99443	Telephone E/M, 21–30 minutes	Commercial payers
G2252	Audio-only follow-up (Medicare, established patient)	Medicare — limited to mental health
G2010	Remote evaluation of pre-recorded images/video	Asynchronous "store and forward"

Key 2026 warning: Many commercial payers are reducing or eliminating reimbursement for telephone-only codes (99441–99443) as video capability becomes more widely available. Verify coverage per payer before billing. Cigna and Aetna have restricted audio-only codes.

Mental/Behavioral Health Telehealth

Mental health telehealth is the most robustly covered telehealth category. Standard psychotherapy codes (90832, 90834, 90837, 90791, 90792) are all covered via telehealth with appropriate POS and modifier.

Special Medicare rule for mental health telehealth: Medicare requires that for mental health telehealth services, the patient must have had an in-person visit with the provider or a member of the same group within 12 months prior to the telehealth visit (or within 6 months of initiating telehealth services per 2024 regulation). This in-person requirement is one of the most frequently misunderstood rules.

Exception: Rural patients (in a Health Professional Shortage Area for mental health) may receive mental health telehealth without the in-person requirement.

Remote Patient Monitoring (RPM)

RPM codes are sometimes confused with "telehealth" but are governed by different rules:

Code	Description
99453	Device setup and patient education
99454	Data transmission device supply (16+ days/month)
99457	Remote monitoring management, first 20 minutes/month
99458	Remote monitoring management, each additional 20 minutes
99091	Collection and interpretation of digital data stored remotely

RPM does NOT require real-time audio-video — it is asynchronous by definition. Do not add telehealth modifiers to RPM codes.

Chronic Care Management (CCM) and Behavioral Health Integration (BHI)

CCM codes (99490, 99491, 99487, 99489) and Collaborative Care Model codes (99492, 99493, 99494) can be provided via phone, patient portal, or other non-face-to-face methods. These are NOT telehealth codes and should NOT receive telehealth modifiers or POS.

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What Changed in 2026

1. Permanent Mental Health Telehealth Geographic Freedom

As of January 1, 2026, mental health telehealth services no longer require the patient to be in a rural area for Medicare coverage. Any Medicare patient receiving mental health services can receive them via telehealth from their home (POS 10). This was made permanent by the Advancing Mental Health Act provisions.

2. Expanded OT/PT/SLP Telehealth Services

Physical therapists, occupational therapists, and speech-language pathologists now have permanently authorized telehealth services for evaluation (97161, 97162, 97163, 97165–97167) and select therapeutic procedures via Medicare. Prior extensions required yearly renewal.

3. Audio-Only Narrowing

Several commercial payers reduced audio-only (telephone) code reimbursement in 2026 as real-time video capacity improved. UnitedHealthcare and Cigna have narrowed audio-only to behavioral health-specific situations. Monitor your ERA data — if 99441–99443 claims are suddenly denying, this may be why.

4. DOGE-Related Medicare Telehealth Review Scrutiny

In early 2026, CMS signaled increased program integrity focus on telehealth billing, particularly for high-volume telehealth prescribers and practices with unusually high telehealth visit ratios. Practices billing 90%+ of visits via telehealth will face higher audit probability. Maintain strong documentation.

5. New Behavioral Health Telehealth Add-On Requirements

CMS finalized the requirement that most Medicare behavioral health telehealth services must include an in-person visit at least once per 12 months. The 2026 final rule clarified that:

• The in-person visit doesn't need to be with the SAME therapist, but must be with a provider at the same practice
• Group therapy via telehealth requires the in-person visit if individual therapy also requires it
• Existing patients who began telehealth before the rule was enacted have a 6-month grace period

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Telehealth Documentation Requirements

Every telehealth visit documentation must include:

1. Mode of communication: "Patient seen via synchronous audio-video telehealth" or specifics of platform
2. Patient location: "Patient located at home" or specific address/city/state
3. Provider location: Where the provider was at time of service
4. Patient consent: Documentation that the patient consented to telehealth service (first telehealth visit)
5. Clinical content: Same content required for in-person visit of the same type
6. Technical issues: Note if any technology limitations affected the visit

Sample telehealth attestation (add to every note):

"This visit was conducted via synchronous, real-time audio-video telecommunication. Patient was located at their home in [City, State]. Patient verbally consented to telehealth services at the onset of this visit. The clinical content of this visit meets the same standard as an in-person equivalent."

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Common Telehealth Billing Compliance Risks in 2026

Risk 1: Billing Telehealth When the Encounter Doesn't Qualify

A phone call to check on a patient's prescription refill is NOT a telehealth E/M visit. Telehealth E/M visits must meet the same level-of-service documentation requirements as in-person visits. Quick phone check-ins should not be billed as 99214.

Risk 2: Reusing In-Person Encounter Templates for Telehealth

If a practice uses the same template for in-person and telehealth visits without adding telehealth-specific documentation, they're creating audit exposure. The note must reflect that an in-person examination was NOT performed and substitute documentation supports the medical decision making.

Risk 3: Provider in a Different State Than the Patient's License Requires

Telehealth across state lines triggers licensure issues. A physician licensed in California seeing a patient who is temporarily in Nevada via telehealth must be licensed or operating under a valid exception in Nevada. The Interstate Medical Licensure Compact (IMLC) helps multi-state practices, but requires separate enrollment per state.

Risk 4: Missing the Annual In-Person Mental Health Visit (Medicare)

As noted above, the annual in-person visit requirement for Medicare mental health telehealth is now enforced more strictly. Document the in-person visit in the record. If the patient is non-compliant with the in-person requirement, document the clinical rationale for the exception if applicable, or advise the patient to come in.

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Frequently Asked Questions

Q: Do I need to use modifier 95 for Medicare fee-for-service telehealth? No. For original Medicare FFS, use POS 10 (patient at home) or POS 02 (patient not at home) to designate telehealth. Modifier 95 is for commercial payers and Medicare Advantage. Adding modifier 95 to FFS Medicare claims is not required and may cause confusion.

Q: Can I conduct a new patient telehealth visit for Medicare? Yes. New patient visits (99202–99205) can be conducted via telehealth under current Medicare rules (through 2026 extension). Document medical decision making thoroughly, as new patient records with only telehealth documentation face higher audit scrutiny.

Q: What is the reimbursement difference between in-person and telehealth for Medicare E/M? Medicare pays the same for in-person and telehealth E/M visits (non-facility rate) when the patient is at home (POS 10). There is no telehealth discount for non-facility rate codes. This makes telehealth financially equivalent to in-person for most E/M services.

Q: Can a LCSW provide telehealth services independently and bill Medicare? Yes. Licensed clinical social workers (LCSWs) are authorized to bill Medicare for telehealth services including 90791, 90832, 90834, and 90837. They must comply with the annual in-person visit requirement like all Medicare mental health telehealth providers.

Q: What platform can I use for telehealth? For Medicare, any HIPAA-compliant audio-video platform is acceptable. CMS confirmed in 2023 that it will not enforce HIPAA penalties for use of non-HIPAA-compliant consumer platforms (FaceTime, Zoom non-Business) through the end of the COVID-related extension periods. For 2026, use a HIPAA-compliant platform with a BAA. Commercial payers increasingly require this.

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Specialty-Specific Telehealth Billing Rules

Not all specialties use telehealth the same way. Understanding the nuances for your clinical area prevents both denials and compliance failures.

Mental and Behavioral Health Telehealth

Mental health is the most telehealth-friendly specialty in terms of payer coverage, but it comes with unique compliance requirements.

Medicare permanent rules (as of 2026):

• No geographic restriction — any Medicare patient anywhere in the U.S. can receive mental health telehealth
• Patient home (POS 10) is always valid as the originating site
• In-person visit requirement: the patient must have had a face-to-face visit with the provider (or another provider in the same group) within the prior 12 months
• Audio-only (G2252) is permanently authorized for established mental health patients when video is not available or clinically appropriate

In-person visit requirement — practical implications:

• New patients who have never been seen in person must be seen in-person first before ongoing Medicare telehealth mental health is billed
• The in-person visit can be with any provider in the same group practice — not necessarily the telehealth treating provider
• Document the date of the most recent in-person visit in every telehealth mental health note

Commercial payer rules: Most commercial payers do NOT have an in-person visit prerequisite for mental health telehealth. This is a Medicare-specific rule. Verify per-payer policy.

Primary Care Telehealth

Primary care is well-suited to telehealth for follow-up and chronic disease management. Key billable services via telehealth:

• Annual Wellness Visits (G0438, G0439): CMS allows telehealth for AWVs for established patients. New patient AWVs still require in-person.
• Chronic disease management E/M: Follow-up visits for hypertension, diabetes, COPD, and similar conditions bill as standard office E/M (99213–99215) via telehealth with POS 10.
• Transitional Care Management (99495, 99496): Face-to-face visit component can be satisfied via telehealth for established patients.
• Chronic Care Management (99490–99491): NOT telehealth — CCM is non-face-to-face and billed separately. Do not add telehealth modifiers to CCM codes.

Preventive care limitation: Many preventive services (screening tests, vaccinations, physical exams) cannot be delivered via telehealth. The telehealth visit can generate a referral, but not the service itself.

Physical Therapy and Occupational Therapy Telehealth

Congress permanently authorized PT/OT/SLP telehealth services for Medicare in the 2026 Consolidated Appropriations Act. Covered via telehealth:

CPT Code	Description	Telehealth Coverage
97161	PT evaluation, low complexity	Covered
97162	PT evaluation, moderate complexity	Covered
97163	PT evaluation, high complexity	Covered
97165	OT evaluation, low complexity	Covered
97166	OT evaluation, moderate complexity	Covered
97167	OT evaluation, high complexity	Covered
97110	Therapeutic exercise	Limited — requires clinical judgment
97530	Therapeutic activities	Limited — requires clinical judgment

Limitations: Hands-on manual therapy, ultrasound, electrical stimulation, and other modality-dependent procedures cannot be delivered via telehealth. Telehealth PT/OT is most appropriate for evaluation, exercise instruction, home program review, and progress assessment.

Modifier requirement: Same as all Medicare telehealth — POS 10 or POS 02. Commercial payers require modifier 95.

Dermatology: Store-and-Forward Teledermatology

Dermatology has a unique telehealth model: store-and-forward (asynchronous) rather than live video. A patient or referring clinician captures images, and the dermatologist reviews them asynchronously.

Billing store-and-forward:

• Modifier GQ is used for asynchronous store-and-forward telehealth services
• Geographic restriction: Medicare store-and-forward is only covered when originating site is in a federal telemedicine demonstration project area (Alaska, Hawaii, or specific rural areas)
• California Medi-Cal covers store-and-forward dermatology statewide — one of the most permissive states
• Most commercial payers cover store-and-forward teledermatology; verify per payer

Reimbursement: Store-and-forward visits typically reimburse at the same rate as a comparable E/M visit. A teledermatology consultation may bill 99243 or 99244 with modifier GQ, depending on complexity.

Documentation: The clinical note must describe the images reviewed, findings, and the clinical decision made based on asynchronous review — even though no real-time encounter occurred.

Radiology and Teleradiology

Teleradiology is NOT billed like clinical telehealth. It operates under a completely different billing model:

• Radiologists bill the professional component only (modifier 26) for interpretation of imaging studies sent from remote facilities
• The originating facility bills the technical component (modifier TC) for the equipment and staff
• Teleradiology does NOT use modifier 95, GT, or GQ — these modifiers are not applicable to radiology professional reads
• No POS 02 or POS 10 is used; standard POS applies based on where the reading was ordered

Teleradiology-specific compliance issues:

• State licensure: the radiologist must be licensed in the state where the patient received the imaging service
• Medicare requires radiologists to be enrolled in the state where they read from AND the state where the patient is located in some circumstances — verify with your MAC
• Nighthawk radiology services (offshore reads) have specific Medicare enrollment requirements

Ophthalmology: Store-and-Forward for Diabetic Eye Care

Ophthalmology uses store-and-forward telehealth for diabetic retinopathy screening — a high-value, high-volume application:

• Retinal images are captured at the primary care office or endocrinologist's office by a technician using a fundus camera
• Images are transmitted to an ophthalmologist for asynchronous interpretation
• CPT 92227: Remote imaging for detection of retinal disease, unilateral or bilateral, with physician interpretation and report
• CPT 92228: Remote imaging for monitoring and management of active retinal disease (for established patients with known diabetic eye disease)

Coverage: Medicare covers diabetic retinopathy telehealth screening under store-and-forward rules as a preventive benefit. Commercial payer coverage varies — verify before implementing a store-and-forward diabetic eye screening program.

Reimbursement: 92227 reimburses approximately $20–$35 Medicare; volume makes this model work. PCPs typically receive a per-screen fee from the ophthalmology practice in direct-to-employer or managed care arrangements.

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Telehealth Credentialing and Licensure

One of the most overlooked compliance requirements in telehealth is the licensure and credentialing obligation. Billing a telehealth claim does not require different billing credentials — but practicing telehealth absolutely requires proper licensure.

The Foundational Rule: Patient Location Governs Licensure

When a provider delivers telehealth, the governing licensure requirement is the state where the PATIENT is located at the time of service — not where the provider is sitting.

A psychiatrist licensed in New York who conducts a telehealth session with a patient who is physically in New Jersey must hold a valid New Jersey medical license (or qualify for an exception). This applies even if the session is 10 minutes and the patient is just visiting family.

This is the single most common telehealth compliance trap for multi-state practices.

Interstate Medical Licensure Compact (IMLC)

The Interstate Medical Licensure Compact streamlines the process of obtaining licenses in multiple states:

• As of 2026, 40+ states plus Washington DC and Guam participate in the IMLC
• Physicians with a principal license in a member state can apply for licenses in other member states through a streamlined process — single application, faster review, lower fees
• IMLC does not eliminate the requirement to hold a license in each state — it just makes getting those licenses easier
• Processing time: typically 4–8 weeks per state, compared to 4–6 months through individual state applications
• Cost: approximately $700–$1,200 per state in fees (varies)

IMLC does not cover: Nurse practitioners, physician assistants, therapists, or other non-physician providers. Each profession has its own compact:

• Nurse Licensure Compact (NLC): covers RNs and LPNs in 40+ states
• NP Compact: still limited adoption
• Counseling Compact: covers LPCs/LMFTs, currently 20+ states
• Psychology Interjurisdictional Compact (PSYPACT): covers psychologists, 40+ states

State Telehealth Prescribing Requirements

Telehealth prescribing — especially for controlled substances — adds another layer of requirement:

• Ryan Haight Act (federal): Controlled substances cannot be prescribed via telehealth without an in-person evaluation UNLESS an exception applies (DEA special registration, public health emergency, or qualifying telemedicine program)
• In 2026, the DEA's proposed telemedicine prescribing rules for controlled substances remain in flux — check DEA.gov for the current regulatory status
• Non-controlled medications have no federal prescribing restriction for telehealth
• Many states have additional prescribing-via-telehealth laws that are MORE restrictive than federal law — check your state medical board

Payer Telehealth Credentialing

Credentialing for telehealth with commercial payers is a separate issue from clinical licensure:

• Most payers require a provider to be credentialed with them before billing telehealth services — even if the provider is already credentialed for in-person care
• Some payers (UnitedHealthcare, Aetna) automatically extend telehealth billing rights to credentialed providers
• Others require a separate telehealth enrollment or attestation form
• Medicare does NOT require separate telehealth enrollment — if you are enrolled in Medicare for in-person care, you can bill telehealth

Group practice credentialing: When a group practice adds a new telehealth provider, the credentialing timeline (90–180 days at many payers) can delay revenue. Use a provisional credentialing process where patients are treated during the pending period only when the provider is registered as a provisional applicant.

Pre-Billing Telehealth Licensure Checklist

Before billing telehealth across state lines:

• Identify which states your patient panel is physically located in during telehealth sessions
• Confirm your provider holds a current, active license in each patient state
• Verify the license type is appropriate for telehealth in that state (some states have "telehealth-only" licenses)
• For prescribing providers: confirm controlled substance prescribing rules in each patient state
• For each commercial payer: confirm telehealth billing authorization is in place for each state
• Document the patient's physical location in the clinical note for every telehealth session

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Revenue Strategies for Telehealth-Heavy Practices

Practices that have embraced telehealth as a primary delivery model can substantially increase revenue beyond simply billing the same services remotely. Here's how.

Structuring a Hybrid Practice for Maximum Reimbursement

A hybrid practice (in-person + telehealth) optimizes revenue when structured intentionally:

High-value in-person visits:

• New patient evaluations (required for Medicare mental health; preferred by many payers)
• Procedures that cannot be delivered via telehealth (injections, biopsies, testing)
• Annual wellness visits for new Medicare patients
• Physical examinations required for certain conditions or programs

Telehealth-optimal visits:

• Established patient follow-up for chronic conditions
• Medication management (psychiatry, primary care)
• Therapy sessions (all psychotherapy, OT/PT evaluation for established patients)
• Care plan review, results review, patient education
• CCM/RPM check-in calls (documented as non-face-to-face care management)

Revenue optimization rule: Maximize in-person volume for high-complexity new patients (99205 = $297 Medicare non-facility rate) and telehealth volume for high-frequency established follow-ups (99213/99214). This preserves provider capacity while maximizing per-patient yield.

Remote Patient Monitoring (RPM) as a Telehealth Complement

RPM generates monthly recurring revenue between telehealth visits and is often overlooked by telehealth-heavy practices:

RPM Code	Description	Medicare Rate (est.)
99453	Initial device setup	~$19 (one-time)
99454	Device supply, 16+ days/month	~$55/month
99457	First 20 min monitoring management/month	~$51/month
99458	Each additional 20 min	~$41/month

Revenue example: A primary care practice with 100 RPM patients (hypertension monitoring with a blood pressure cuff) billing 99454 + 99457 monthly generates approximately $10,600/month in recurring RPM revenue — approximately $127,200/year — without additional face-to-face visits.

RPM is not telehealth — no video platform is required. Data is transmitted asynchronously from the patient's device to the practice system. Do not apply telehealth modifiers.

Chronic Care Management and Behavioral Health Integration Alongside Telehealth

These codes can be billed in addition to telehealth E/M visits (not on the same day, but in the same month):

Code	Description	Monthly Rate (est.)
99490	CCM, first 20 min/month	~$63/month
99491	CCM, provider time, 30 min/month	~$85/month
99487	Complex CCM, 60 min/month	~$132/month
99492	CoCM, initial month (behavioral health)	~$316/month
99493	CoCM, subsequent months	~$254/month
96160	Patient-focused health risk assessment	Per assessment

Combined revenue model: A telehealth-based primary care practice billing a monthly E/M via telehealth + 99490 (CCM) + 99454 (RPM device supply) + 99457 (RPM monitoring) for 200 chronic care patients earns approximately $33,800/month in care management revenue alone — before E/M visit billing.

Direct-to-Employer Telehealth Arrangements

Large employers increasingly contract directly with telehealth-capable provider groups to provide covered services to their employees at negotiated rates (bypassing insurance):

• Advantages: Higher per-visit rates than commercial insurance, no prior auth, faster payment
• Structure: Monthly per-employee-per-month (PEPM) fee or fee-for-service, depending on employer size
• Best suited for: Primary care, behavioral health, occupational health, physical therapy
• Requirements: Providers must be licensed in states where employees are located; a BAA with the employer is required

This model complements traditional insurance billing and provides predictable revenue independent of payer volatility.

Telehealth and Value-Based Care Incentives

Telehealth-heavy practices participating in MIPS or APM programs can leverage telehealth for quality performance:

MIPS telehealth-relevant quality measures:

• Depression screening and follow-up (telehealth well-suited for PHQ-9 administration)
• Diabetes HbA1c monitoring (remote monitoring coordination)
• Controlling High Blood Pressure (pairs with RPM)
• Appropriate Use of Antibiotics (telehealth reduces inappropriate prescription rates in studies)
• Advance Care Planning (99497, 99498 — billable via telehealth)

Improvement Activities credit: CMS awards MIPS Improvement Activities credit for implementing telehealth programs, particularly for patients in medically underserved areas or HPSAs.

Multi-State Patient Panel Expansion

Telehealth's primary revenue growth lever for established practices is geographic expansion:

• A behavioral health practice licensed in 5 states via IMLC/Counseling Compact can market to patients in all 5 states
• A psychiatry group that adds IMLC licenses in 10 states can see patients across a 10-state region without opening physical offices
• Each new state license adds potential panel capacity without the overhead of a physical location

Practical expansion steps:

1. Identify highest-demand states for your specialty (psychiatry demand is highest in rural states)
2. Apply for IMLC/Compact licenses in target states
3. Update credentialing with payers in target states (plan for 90–180 day timeline)
4. Update your website, Google Business profile, and marketing for multi-state reach
5. Verify malpractice coverage extends to all states where you practice telehealth

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Telehealth Platform Requirements

The platform you use for telehealth is not just a technology decision — it is a compliance decision that affects your billing legitimacy and audit risk.

HIPAA Requirements: Business Associate Agreements

Any telehealth platform that handles protected health information (PHI) must sign a Business Associate Agreement (BAA) with your practice. The BAA:

• Establishes the platform vendor's obligations to protect PHI
• Is required by HIPAA regardless of whether the platform is used for billing purposes
• Must be in place BEFORE you use the platform for patient care
• Applies to video platforms, patient messaging systems, and any app that stores or transmits clinical data

Conducting telehealth on a platform without a BAA — even if the platform is technically secure — is a HIPAA violation. This includes using personal Gmail, personal Zoom (non-healthcare tier), WhatsApp, or standard FaceTime for clinical care.

CMS and HHS Guidance on Acceptable Platforms

CMS does not maintain an "approved platform" list. The standard is:

1. The platform must support real-time audio-video communication
2. The platform vendor must sign a BAA
3. The platform must use appropriate encryption (end-to-end preferred; TLS 1.2+ minimum)
4. The platform must not record sessions without patient consent

Post-PHE enforcement: The COVID-era enforcement discretion that allowed non-compliant platforms (personal FaceTime, personal Zoom) expired for commercial payers before it did for Medicare. For 2026, all payers expect HIPAA-compliant platforms. CMS has signaled it will begin enforcing this requirement for Medicare telehealth.

Consumer Apps: What Is and Isn't Acceptable

Platform	HIPAA BAA Available	Acceptable for Clinical Telehealth
FaceTime (personal Apple account)	No	Not acceptable
FaceTime (Apple Business/healthcare use)	No BAA available	Not acceptable for billing
WhatsApp / Facebook Messenger	No	Not acceptable
Standard Zoom (free/personal)	No	Not acceptable
Zoom for Healthcare	Yes	Acceptable
Google Meet (standard)	No	Not acceptable
Google Meet (Google Workspace Healthcare)	Yes	Acceptable
Microsoft Teams (standard)	No	Not acceptable
Microsoft Teams (Teams for Healthcare)	Yes	Acceptable

Audio-Only Platform Requirements

Audio-only telehealth (telephone) presents unique platform considerations:

• Standard phone calls over POTS (plain old telephone service) or cellular are generally accepted by CMS for audio-only telehealth — a BAA with the telephone carrier is not required for standard phone calls
• VoIP platforms that transmit audio over the internet DO process PHI — confirm whether your VoIP provider offers a BAA
• Dedicated clinical telephony platforms (Klara, Healow, etc.) are purpose-built for HIPAA-compliant audio contact
• Document in every audio-only note: "Visit conducted by telephone as patient lacks video capability" or similar attestation explaining why audio-only was used

Documentation of Platform Type in Clinical Notes

CMS and commercial payers increasingly expect the type of telehealth platform used to be documented:

Acceptable documentation language:

• "Visit conducted via synchronous audio-video telehealth using [platform name], a HIPAA-compliant video platform."
• "Visit conducted via audio-only telephone call at patient's request; patient lacks video capability."

Do not write: "Telemedicine visit" without specifying audio-video vs. audio-only — this creates ambiguity if the platform type is audited.

Telehealth Platform Comparison

Platform	HIPAA BAA	Audio/Video	EHR Integration	Monthly Cost (est.)	Best For
Zoom for Healthcare	Yes	Yes	Some EHRs	$14.99+/host/mo	Any size practice; widely recognized
Doxy.me	Yes	Yes	Limited	Free tier available; ~$35/mo pro	Solo/small practices; simple
SimplePractice	Yes (embedded)	Yes	Built-in (SimplePractice EHR)	~$79/mo (includes EHR)	Behavioral health practices
Epic Integrated Telehealth	Yes (via Epic BAA)	Yes	Fully integrated	Enterprise pricing	Large health systems
Klara	Yes	Yes	Major EHR integrations	~$50–$150/mo	Practices wanting unified patient messaging

Selection criteria:

1. Does your EHR integrate with the platform? (Reduces duplicate documentation)
2. Does the platform support waiting rooms? (Required by most payers for privacy)
3. Does the platform have a mobile app for patients? (Improves adherence)
4. Does the BAA cover all relevant data, including recordings if you record?

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Frequently Asked Questions (Continued)

Q: Can I bill telehealth if my patient is traveling out of state? Yes, but you must be licensed in the state where the patient is physically located at the time of service — not where they live. If your patient is from California but is vacationing in Florida when they call for a telehealth visit, you must hold a Florida license to provide and bill that service. Best practice: at the start of every telehealth session, confirm and document the patient's physical location ("Patient confirmed they are currently located in [City, State]").

Q: What happens if a telehealth visit is interrupted by technical issues? If the visit is interrupted briefly (connection drops, reconnects within a few minutes), document the interruption and resume. If the visit cannot be completed due to technical failure, you have three options: (1) complete via audio-only if the payer covers it, (2) reschedule and do not bill, or (3) if meaningful clinical work was accomplished before the interruption, bill the appropriate lower-level code with a note explaining the technical interruption. Never bill a full E/M visit for a session that was substantially incomplete. Document everything: time connected, time of interruption, what was accomplished.

Q: Do I need to re-verify eligibility for telehealth visits vs. in-person? Yes — always verify eligibility separately for telehealth, even if you verified recently for in-person. Telehealth coverage is a distinct benefit under many plans; a patient may have full in-person benefits but limited or excluded telehealth coverage, particularly under certain employer-sponsored plans, Medicaid managed care plans, or Medicare Advantage plans with narrow telehealth networks. Run eligibility verification before every telehealth visit, specifically checking the telehealth benefit section.

Q: Can I use telehealth for initial new patient visits across all payers? Not universally. Medicare currently covers new patient telehealth visits (99202–99205) through its 2026 extension. Commercial payers generally cover new patient telehealth visits. However, 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/HPSA exceptions). Some Medicare Advantage plans and Medicaid programs also restrict new patient telehealth visits. Verify new patient telehealth coverage per payer before scheduling — particularly for Medicare behavioral health.

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Stay Ahead of Telehealth Billing Changes

Telehealth billing rules are evolving faster than almost any other area of medical billing. Contact Healix RCM to have our telehealth billing experts review your current telehealth claim submissions for compliance and revenue optimization opportunities. We monitor regulatory changes weekly so your practice is always billing to current standards.