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

POS 10 is used when the patient is at home during the telehealth visit. POS 02 is used when the patient is at a clinic, facility, or any non-home location. POS 10 pays at the non-facility rate, which is typically the same as an in-office visit. POS 02 pays at the lower facility rate. Choosing the wrong code doesn’t just risk a denial — it leaves revenue on the table for every home-based telehealth claim.

Does Medicare require Modifier 95 for telehealth visits?

No. Original Medicare Fee-for-Service uses POS codes — not Modifier 95 — to identify telehealth services. Modifier 95 is required by most commercial payers and Medicare Advantage plans when billing traditional E/M codes for audio-video visits. For Medicare FFS claims, appending Modifier 95 isn’t required and can create processing confusion.

What happened to HCPCS code G2012 in 2026?

G2012 was replaced by CPT 98016, the new universal brief virtual check-in code accepted by both Medicare and most commercial payers. CPT 98016 covers 5-10 minute technology-based communications with established patients. If your charge master still has G2012, update it to 98016. The service reimburses at approximately $16.50 nationally.

Are the AMA 98000-series telehealth codes billable to Medicare?

No. CMS declined to reimburse most of the AMA’s 98000-98015 codes for Medicare, calling them duplicative of existing E/M codes with POS designations. Billing these codes on Medicare claims results in denial with RARC N776. For Medicare telehealth, continue using standard E/M codes 99202-99215. Commercial payers vary — check each payer’s policy on which codes they’ve adopted.

What is the in-person visit requirement for behavioral health telehealth?

CMS finalized a rule requiring most Medicare behavioral health telehealth patients to have an in-person visit at least once per 12 months. The visit can be with any provider of the same specialty at the same group practice — it doesn’t have to be the same therapist. The six-month in-person requirement before an initial behavioral health telehealth service goes into effect after December 31, 2027 under current legislation.

What changed for providers billing telehealth from their home in 2026?

The 2026 PFS Final Rule ended the pandemic-era policy that allowed providers to bill from home using their existing practice location enrollment. Starting January 1, 2026, providers delivering telehealth from home or alternative locations must separately enroll and bill for each location. If you have part-time remote providers who haven’t completed separate location enrollment, address this immediately to avoid claim issues.

Telehealth Billing Rules in 2026: What’s Changed and What Still Trips Up Practices

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