If you launched telehealth mental health services during the pandemic, your billing playbook is probably obsolete. The public health emergency flexibilities that made virtual care easy to bill have expired, CMS has made permanent only select telehealth provisions, and commercial payers have diverged sharply from Medicare rules. What worked in 2021 will get you denied in 2026.
Understanding how to bill telehealth mental health services today requires precision at the code level: the right CPT codes, the right modifiers, the right place of service codes, and the right documentation standard for each payer type. This guide delivers the current, code-specific breakdown you need to submit clean claims and avoid the retroactive denials that are spiking across behavioral health right now.
The Telehealth Billing Modifier Landscape in 2026
Modifiers tell payers that a service was delivered via telehealth rather than in person. But which modifier you use depends entirely on the payer, and using the wrong one triggers an automatic denial.
Modifier 95 is the standard for most commercial payers and Medicare for services delivered via real-time audio-video. It appends to the standard CPT code (e.g., 90834-95) and signals that the service was synchronous telehealth. CMS guidance confirms modifier 95 remains the primary telehealth modifier for Medicare in 2026.
Modifier GT was historically used for telehealth but has been largely replaced by modifier 95. Some Medicaid programs and a shrinking number of commercial plans still require GT instead of 95. Check your state Medicaid manual and your commercial contracts before defaulting to 95.
Modifier FQ applies only to audio-only services when allowed by the payer. It pairs with specific CPT codes (discussed below) and is not interchangeable with 95 or GT. Misusing FQ for video visits or 95 for audio-only will result in denial or recoupment.
The most common error: using modifier 95 for a Medicaid claim in a state that requires GT, or vice versa. Always verify payer-specific modifier requirements before submitting claims. When in doubt, call the payer's provider line and document the answer.
Which CPT Codes Are Permanently Approved for Telehealth by Medicare
Not all CPT codes that were temporarily approved for telehealth during the PHE remain billable via telehealth in 2026. The CMS Physician Fee Schedule final rule clarifies which codes are permanently on the telehealth list and which have reverted to in-person only.
Permanently approved for Medicare telehealth:
- 90832, 90834, 90837 (individual psychotherapy)
- 90846, 90847 (family psychotherapy with and without patient present)
- 90853 (group psychotherapy, with restrictions discussed below)
- 99202-99205, 99212-99215 (E/M codes for psychiatric diagnostic evaluations and medication management when billed by physicians or NPPs)
- 90791, 90792 (psychiatric diagnostic evaluation, with and without medical services)
Reverted to in-person only or subject to new restrictions:
- Many group therapy codes for intensive outpatient programs (IOP) are no longer universally covered via telehealth by Medicare. Check the current telehealth list quarterly.
- Certain psychological testing codes that were temporarily added during PHE have been removed from the permanent telehealth list.
Commercial payers often mirror Medicare's telehealth list but not always. Some Blues plans and national commercial payers have broader telehealth coverage than Medicare, while others have narrower policies. Review your contracts and fee schedules annually, and track which codes are being paid versus denied.
For a comprehensive breakdown of behavioral health billing fundamentals, see our guide to behavioral health billing in 2026.
Telehealth Mental Health Billing Codes: CPT Codes for Therapy and Psychiatry
The core telehealth mental health billing codes you will use most frequently are the psychotherapy CPT codes: 90832 (30 minutes), 90834 (45 minutes), and 90837 (60 minutes). Append modifier 95 (or GT, depending on payer) to indicate telehealth delivery.
For psychiatric evaluations and medication management, use 90791 or 90792 for initial evaluations, and 99212-99215 for follow-up medication management visits. These codes are all approved for telehealth by Medicare and most commercial payers when delivered via real-time audio-video.
For group therapy, use 90853 with modifier 95. Be aware that Medicare and many commercial payers have stricter documentation and attendance requirements for group telehealth than for individual sessions. We cover those requirements in detail below.
If your state Medicaid program uses HCPCS codes instead of CPT codes for behavioral health services (common in addiction treatment settings), check whether codes like H0004, H0005, or H0015 are approved for telehealth in your state. H0004 individual counseling billing rules vary significantly by state, and telehealth policies for HCPCS codes are not uniform.
How Medicaid Telehealth Billing Rules Vary by State
Medicaid telehealth policies are not federal. Each state sets its own rules, and those rules vary dramatically. Some states have full telehealth parity laws that require Medicaid to reimburse telehealth at the same rate and under the same conditions as in-person care. Other states restrict telehealth to specific service types, require an in-person intake before any telehealth billing, or exclude audio-only services entirely.
CMS telehealth FAQs provide a high-level overview, but you must consult your state Medicaid provider manual for binding guidance. Key state-level variations include:
- Audio-only coverage: Some states (e.g., California, Oregon) continue to reimburse audio-only therapy via telephone. Others (e.g., Texas, Florida) require video for all telehealth claims except in documented cases of patient technology barriers.
- In-person intake requirements: Some states require the first visit to be in person before any telehealth services can be billed. Others allow fully virtual care from intake onward.
- Originating site restrictions: Some states require the patient to be at a qualified originating site (e.g., a clinic, school, or hospital) rather than their home. Most states have relaxed this rule post-PHE, but not all.
- Consent documentation: Some states require a separate signed telehealth consent form before billing any telehealth service. Others accept a general treatment consent that includes telehealth language.
If you operate in multiple states or serve Medicaid patients across state lines (via interstate licensure compacts), you need a state-by-state billing matrix. Do not assume that what works in one state Medicaid program applies to another. For example, MassHealth telehealth billing rules differ significantly from New York Medicaid rules, even though both states have telehealth parity laws.
Telehealth Billing for Group Therapy and IOP
Group therapy and intensive outpatient program (IOP) services delivered via telehealth have stricter billing requirements than individual therapy. Payers want proof that the group was interactive, that attendance was verified in real time, and that the service met the clinical and time standards for the billed code.
CMS guidance on telehealth and remote monitoring clarifies that group telehealth services must be delivered via real-time audio-video, and that providers must document each participant's attendance and active participation. Roster billing (billing for multiple patients in a single group session) is allowed, but each patient's chart must include:
- Date and time of the group session
- Duration of the session and the patient's participation
- Names of other participants (or a reference to a group roster)
- Clinical content and therapeutic interventions delivered
- Verification that the patient was present and engaged (not just logged in)
Many commercial payers and state Medicaid programs do not cover telehealth IOP billing at the same rate as in-person IOP, or they limit the number of virtual group sessions allowed per week. Some payers require a hybrid model where at least one group per week is in person. Check your contracts and Medicaid manuals before launching a fully virtual IOP program.
The most common denial reason for group telehealth claims: insufficient documentation of individual participation. Generic group notes that do not specify each patient's engagement will not survive an audit. If you are building or refining a telehealth model, see our guide to hybrid telehealth for behavioral health.
Audio-Only vs. Video: What Payers Reimburse in 2026
Audio-only therapy (telephone-based counseling without video) was widely reimbursed during the PHE. In 2026, coverage has narrowed significantly. Medicare does not cover audio-only therapy except in limited circumstances where video is not possible due to patient technology or bandwidth constraints, and even then, documentation must justify the use of audio-only.
When audio-only is allowed, it is typically billed using CPT codes 99441, 99442, or 99443 (telephone E/M services), not the standard psychotherapy codes. These codes are time-based: 99441 for 5-10 minutes, 99442 for 11-20 minutes, and 99443 for 21-30 minutes. Append modifier FQ if required by the payer.
CMS telehealth guidance specifies that audio-only services must be documented with the same rigor as video services, including the reason video was not used, the clinical content of the session, and the patient's response to treatment. Post-payment audits are targeting audio-only claims, so your documentation must be airtight.
Commercial payers vary widely. Some Blues plans and Medicaid programs continue to cover audio-only therapy using the standard psychotherapy codes (90832, 90834, 90837) with modifier 95 or FQ. Others do not cover audio-only at all. Always verify coverage before delivering audio-only services, and document the patient's inability to access video in the clinical record.
Place of Service Codes for Telehealth: POS 02 vs. POS 10
Place of service (POS) codes tell the payer where the service was delivered. For telehealth, the correct POS code depends on the payer and the type of service. Using the wrong POS code is one of the most common reasons clean claims are auto-denied by clearinghouses before they even reach the payer.
POS 02 (Telehealth) is used when the service is delivered via telehealth and the patient is at home or another non-clinical location. This is the standard POS code for most telehealth mental health services in 2026.
POS 10 (Telehealth provided in patient's home) is used by some payers to indicate that the patient was at home during the telehealth visit. Medicare and some commercial payers treat POS 02 and POS 10 as interchangeable for telehealth, but others do not. Check your payer contracts and remittance advice to see which POS code is expected.
Some payers still require POS 11 (office) for telehealth claims, with the telehealth modifier (95 or GT) indicating the virtual delivery method. This is less common in 2026 but still occurs with some legacy commercial contracts.
The safest approach: when credentialing with a new payer or submitting your first telehealth claim, call the payer's provider line and ask which POS code to use for telehealth mental health services. Document the answer and the date of the call. If claims are denied for incorrect POS, you have a record to support your appeal.
Documentation Standards That Protect You from Post-Payment Audits
Telehealth claims are being audited at higher rates than in-person claims, especially for Medicaid and Medicare. Payers are looking for documentation that proves the service was delivered via real-time audio-video (or audio-only when allowed), that the patient consented to telehealth, and that the clinical content met the standard for the billed code.
Your telehealth progress notes must include:
- Explicit statement that the service was delivered via telehealth (e.g., "Session conducted via secure video platform")
- Confirmation that the patient consented to telehealth and that consent is on file
- Patient's location during the session (city and state, to verify licensure compliance)
- Start and end time of the session, with total duration matching the billed CPT code
- Clinical content: presenting problem, interventions, patient response, plan
- If audio-only: reason video was not used (e.g., "Patient unable to access video due to limited internet bandwidth")
Generic templates that do not specify telehealth delivery will not survive an audit. If your EHR does not automatically populate telehealth-specific fields, add them manually to your note templates. For more on why behavioral health billing requires extra precision, see our article on why behavioral health billing is more complicated.
Common Telehealth Billing Errors That Trigger Denials
Even experienced billing teams are making avoidable errors with telehealth claims. The most common mistakes in 2026:
- Using modifier 95 for a payer that requires GT (or vice versa): This is the number one denial reason. Always verify modifier requirements by payer.
- Billing audio-only services with video CPT codes: If the service was audio-only, use the correct CPT code (99441-99443) or verify that your payer allows audio-only billing with standard psychotherapy codes.
- Wrong place of service code: POS 02 vs. POS 10 vs. POS 11. Check your payer's requirements and update your billing system accordingly.
- Insufficient documentation of group participation: Generic group notes will be denied on audit. Document each patient's individual participation.
- No telehealth consent on file: Some payers require a separate signed consent form before any telehealth billing. Missing consent is grounds for recoupment.
- Billing a CPT code that is no longer on the payer's telehealth list: Just because a code was covered during the PHE does not mean it is covered now. Review the current telehealth list quarterly.
Frequently Asked Questions
What modifier do I use for telehealth therapy billing?
For most commercial payers and Medicare, use modifier 95 appended to the CPT code (e.g., 90834-95). Some Medicaid programs require modifier GT instead. Audio-only services may require modifier FQ. Always verify the correct modifier with your specific payer before submitting claims.
Can I bill Medicaid for telehealth mental health?
Yes, but policies vary by state. Some states have full telehealth parity and reimburse at the same rate as in-person care. Others restrict telehealth to specific service types, require an in-person intake, or exclude audio-only services. Consult your state Medicaid provider manual for binding guidance.
Is audio-only therapy reimbursable in 2026?
It depends on the payer. Medicare covers audio-only therapy only in limited circumstances and requires documentation justifying why video was not used. Some commercial payers and state Medicaid programs continue to cover audio-only therapy using CPT codes 99441-99443 or standard psychotherapy codes with modifier FQ. Verify coverage before delivering audio-only services.
What CPT code is used for telehealth therapy sessions?
Use the standard psychotherapy CPT codes: 90832 (30 minutes), 90834 (45 minutes), or 90837 (60 minutes). Append the appropriate telehealth modifier (95 or GT) to indicate virtual delivery. For audio-only therapy when allowed, some payers require CPT codes 99441, 99442, or 99443 instead.
Do I need a consent form to bill telehealth?
Most payers require documented patient consent before billing telehealth services. Some states and payers require a separate signed telehealth consent form. Others accept a general treatment consent that includes telehealth language. Check your state regulations and payer contracts, and ensure consent is documented in the patient's chart before submitting any telehealth claims.
What are the CPT codes for telehealth therapy in 2026?
The primary CPT codes for telehealth therapy in 2026 are 90832, 90834, and 90837 for individual psychotherapy; 90846 and 90847 for family therapy; and 90853 for group therapy. Psychiatric evaluations use 90791 or 90792, and medication management uses E/M codes 99212-99215. All must be appended with the correct telehealth modifier (typically 95 or GT) and billed with the correct place of service code (typically POS 02).
Get Telehealth Billing Right the First Time
Telehealth billing in 2026 is not forgiving. The rules have changed, payer policies have diverged, and the documentation standards are stricter than ever. One wrong modifier or missing consent form can cost you thousands in denied or recouped claims.
If you are launching or scaling telehealth mental health services and need a billing partner who understands the code-level details, ForwardCare specializes in behavioral health revenue cycle management. We handle credentialing, claims submission, denial management, and compliance for telehealth and in-person services. Let us manage the billing so you can focus on patient care.
Visit ForwardCare.com to learn how we help behavioral health providers get paid correctly and on time.
