If you're billing telehealth for eating disorder therapy in 2026, you're operating in a regulatory minefield. The Public Health Emergency (PHE) ended in May 2023, but Congress extended select flexibilities through 2024, 2025, and into 2027 via the Consolidated Appropriations Acts. The result is a patchwork of permanent changes, temporary extensions, and fully sunsetted rules that most billing guides haven't mapped specifically to eating disorder treatment. This article provides a code-level, payer-by-payer breakdown of telehealth billing for eating disorder therapy post-PHE, so you can audit your claims practices before a payer does it for you.
Eating disorder clinicians, dietitians, and program operators are getting burned by outdated assumptions. What worked in 2021 doesn't work now. What's billed correctly for Medicare may trigger denials from Medicaid or commercial payers. And the documentation standards have quietly tightened in ways that are generating retroactive audits of 2023-2025 claims.
What Actually Ended When the PHE Expired vs. What Congress Extended
The PHE officially ended on May 11, 2023, but not all telehealth flexibilities disappeared overnight. Congress stepped in with the Consolidated Appropriations Acts of 2023, 2024, and 2025, extending specific provisions while letting others sunset. Understanding which is which is critical for post-PHE telehealth mental health billing.
Here's what matters for eating disorder therapy billing specifically. Through December 31, 2027, an extended range of practitioners may bill for Medicare telehealth services including outpatient therapy services, diabetes self-management training and medical nutrition therapy services furnished remotely by hospital staff. This means CPT codes 90834, 90837, 90853 (psychotherapy codes) and 97802, 97803 (medical nutrition therapy codes) remain covered via telehealth for Medicare beneficiaries through 2027.
What fully sunsetted after the PHE: the blanket waiver that allowed all providers to bill telehealth from any location without geographic restrictions. What was extended: the ability for Medicare beneficiaries to receive behavioral health services via telehealth from their home. What changed permanently: audio-only coverage for mental health services became a codified benefit, not just an emergency measure.
For eating disorder programs, this means your RDs can still bill 97802 and 97803 via telehealth for Medicare patients through 2027, but the rules around originating site, modifiers, and documentation have shifted. If you're still billing like it's 2021, you're at risk.
Medicare Telehealth Coverage for Eating Disorder Therapy in 2026
Medicare's telehealth eating disorder therapy coverage in 2026 is more generous than pre-pandemic rules but more restrictive than the PHE period. Here's the code-level breakdown.
Individual psychotherapy (90834, 90837): Covered via telehealth for Medicare beneficiaries through December 31, 2027, with the patient's home qualifying as the originating site. No geographic restrictions apply during this extension period. However, payment for behavioral health telehealth services from home requires an in-person visit prior, effective after December 31, 2027, signaling that geographic and originating site restrictions will return for non-FQHC providers in 2028.
Group psychotherapy (90853): Covered via telehealth through 2027. This is critical for eating disorder programs running virtual IOP or PHP groups. The modifier requirements for group therapy telehealth are where most denials are happening, covered in detail below.
Medical nutrition therapy (97802, 97803): Through December 31, 2027, hospitals may bill for outpatient therapy services, diabetes self-management training and medical nutrition therapy services remotely, aligning with Medicare telehealth policies. This is a lifeline for eating disorder RDs who provide virtual nutrition counseling. These codes are covered via telehealth with the same originating site flexibilities as psychotherapy codes.
Audio-only coverage: Medicare now covers audio-only telehealth for behavioral health services, a permanent change that eating disorder patients with severe video avoidance or limited internet access depend on. The CPT codes are the same (90834, 90837), but the documentation requirements differ. More on this below.
For FQHC and RHC providers, the rules are different. Any behavioral health service furnished by an RHC or FQHC through telecommunications technology is paid under AIR or PPS; through December 31, 2027, RHCs and FQHCs may bill non-behavioral health services via telehealth using G2025, with home as distant site. If you're an FQHC-based eating disorder program, you have broader latitude than non-FQHC providers.
Medicaid Telehealth Coverage by State Post-PHE
Medicaid telehealth policy is a state-by-state patchwork, and Medicaid telehealth eating disorder state rules vary wildly. Some states made pandemic flexibilities permanent for behavioral health and nutrition counseling. Others reverted to pre-pandemic restrictions the moment the PHE ended.
Here's a comparison of the five highest-volume eating disorder states:
California: Made telehealth flexibilities permanent for behavioral health services, including individual therapy, group therapy, and dietitian services. Audio-only coverage remains available for Medi-Cal beneficiaries. No originating site restrictions for behavioral health. If you're billing eating disorder therapy via telehealth in California, you're operating under some of the most flexible rules in the country.
Texas: Extended telehealth flexibilities for behavioral health through September 2025, then reverted to requiring an established patient relationship and in-person visit within the prior 12 months. Audio-only coverage for behavioral health is available only for established patients. RD nutrition counseling via telehealth is covered, but with stricter documentation requirements than during the PHE.
Florida: Did not make pandemic telehealth flexibilities permanent. Florida Medicaid reverted to pre-pandemic rules, which require the patient to be at a qualified originating site (not the home) for most services. Behavioral health services have limited exceptions, but eating disorder RD services via telehealth face significant restrictions. If you're billing Florida Medicaid for telehealth eating disorder therapy, audit every claim.
New York: Made telehealth flexibilities permanent for behavioral health and nutrition services. Audio-only coverage remains available. No originating site restrictions for behavioral health. New York Medicaid is one of the more permissive payers for eating disorder telehealth post-PHE.
Illinois: Extended telehealth flexibilities for behavioral health through December 2025, with permanent rules still under review. Audio-only coverage is available for behavioral health services. RD nutrition counseling via telehealth is covered, but the state requires documentation of the technology used and patient location.
For more on how Medicaid rules vary by state, see our guide on how Washington Medicaid covers mental health treatment, which illustrates the state-specific nuances that apply to eating disorder billing.
Commercial Payer Telehealth Coverage for Eating Disorder Therapy
Commercial payers have landed in different places on telehealth billing changes for eating disorder 2026, and this is where the most dangerous billing assumptions are happening. Unlike Medicare, commercial payers are not bound by CMS rules. Each has its own post-PHE telehealth policy.
UnitedHealthcare: Covers individual therapy (90834, 90837) via telehealth with no originating site restrictions. Group therapy (90853) is covered via telehealth, but UHC requires modifier 95, not GT. Audio-only coverage is available for behavioral health services, but UHC requires documentation that video was attempted and failed. RD nutrition counseling (97802, 97803) is covered via telehealth, but only for established patients with a documented eating disorder diagnosis.
Aetna: Covers individual and group therapy via telehealth with no originating site restrictions. Aetna requires modifier 95 for all telehealth claims. Audio-only coverage is available for behavioral health services, but Aetna's documentation requirements are stricter than UHC's. RD nutrition counseling via telehealth is covered, but Aetna requires prior authorization for 97803 (follow-up nutrition counseling) if more than six sessions are billed in a calendar year.
BCBS: Coverage varies by state plan. Most BCBS plans cover individual and group therapy via telehealth, but some require the patient to be established with the provider before telehealth can be used. Modifier requirements vary by plan (95 vs. GT). Audio-only coverage is inconsistent across BCBS plans. RD nutrition counseling via telehealth is covered by most plans, but documentation requirements are strict. If you're billing BCBS for eating disorder telehealth, verify the specific plan's policy before submitting claims.
Cigna: Covers individual and group therapy via telehealth with no originating site restrictions. Cigna requires modifier 95 for telehealth claims. Audio-only coverage is available for behavioral health services, but Cigna requires documentation of the patient's inability to access video. RD nutrition counseling via telehealth is covered, but Cigna limits coverage to patients with a documented eating disorder or metabolic condition.
The most common billing error eating disorder programs are making with commercial payers: assuming that because a service is covered via telehealth, it's covered the same way across all payers. It's not. For more on how to navigate these payer-specific rules, see our guide on how to bill for telehealth mental health services.
Modifier GT vs. 95 vs. No Modifier: The Eating Disorder Group Therapy Trap
This is where eating disorder programs are getting burned the most. Modifier 95 and GT for eating disorder telehealth are not interchangeable, and using the wrong one generates denials.
Here's the breakdown by payer type in 2026:
Medicare: Requires modifier 95 for telehealth claims. Modifier GT is no longer accepted for most telehealth services. If you're still using GT for Medicare telehealth claims, you're generating denials.
Medicaid: Varies by state. Some states require modifier 95, some require GT, some require both. California Medicaid requires modifier 95. Texas Medicaid requires GT for some services and 95 for others. Florida Medicaid requires GT. If you're billing Medicaid for eating disorder telehealth, verify the state-specific modifier requirement.
Commercial payers: Most require modifier 95, but some BCBS plans still require GT. UHC, Aetna, and Cigna all require modifier 95. If you're billing commercial payers for telehealth, default to modifier 95 unless the payer specifies otherwise.
The eating disorder group therapy telehealth modifier trap: many billing systems default to no modifier for group therapy (90853), which worked during the PHE but generates denials now. If you're billing 90853 via telehealth, you must append modifier 95 (or GT, depending on the payer). This is generating widespread denials that eating disorder programs aren't catching until months later.
For more on the nuances of behavioral health billing codes, see our guide on H-codes vs. CPT codes for behavioral health billing.
Audio-Only Telehealth for Eating Disorder Patients
Audio-only telehealth eating disorder billing is a critical access issue. Many eating disorder patients avoid video due to body image concerns, and rural patients often lack reliable internet access. Post-PHE, audio-only coverage has tightened, but it hasn't disappeared.
Here's what payers still cover:
Medicare: Covers audio-only telehealth for behavioral health services (90834, 90837, 90853) as a permanent benefit. The CPT codes are the same as video telehealth, but Medicare requires documentation that the service was provided via audio-only and that the patient consented to this modality. No separate modifier is required for audio-only, but the claim must include place of service 02 (telehealth) and modifier 95.
Medicaid: Varies by state. California, New York, and Illinois cover audio-only telehealth for behavioral health services. Texas covers audio-only only for established patients. Florida does not cover audio-only telehealth for most services. If you're billing Medicaid for audio-only eating disorder therapy, verify the state-specific policy.
Commercial payers: UHC, Aetna, and Cigna cover audio-only telehealth for behavioral health services, but all require documentation that video was attempted and failed or that the patient has a documented barrier to video access. BCBS coverage varies by plan. If you're billing commercial payers for audio-only eating disorder therapy, document the clinical rationale and the patient's inability to access video.
The documentation trap: many eating disorder programs are billing audio-only sessions without documenting why video wasn't used. This is generating retroactive audits and denials. Every audio-only session note must include: (1) confirmation that the service was provided via telephone, (2) documentation that video was attempted or why video was not clinically appropriate, and (3) patient consent to audio-only treatment.
The Documentation Requirements That Have Tightened Post-PHE
During the PHE, payers were lenient on telehealth documentation. That leniency has ended. Post-PHE, payers are requiring documentation elements that weren't enforced during the emergency period, and missing these fields is generating retroactive audits of 2023-2025 telehealth claims.
Here's what payers now require in telehealth progress notes for eating disorder therapy:
Patient location attestation: Every telehealth note must document where the patient was located during the session (city and state at minimum). This is required by Medicare, most Medicaid programs, and most commercial payers. If your notes don't include patient location, you're at risk for retroactive denials.
Technology confirmation: Every telehealth note must document the technology used (video, audio-only, specific platform). Medicare and most commercial payers require this. If you're billing video telehealth but your note says "telehealth session completed" without specifying video, you're at risk.
Session medium documentation: Every telehealth note must explicitly state that the session was conducted via telehealth. This seems obvious, but many eating disorder clinicians are writing notes that don't distinguish between in-person and telehealth sessions. Payers are flagging these notes in audits.
Consent documentation: Most payers require documentation that the patient consented to telehealth treatment. This doesn't need to be in every note, but it must be documented at the start of telehealth treatment and periodically thereafter. If you don't have telehealth consent forms on file, you're at risk.
Audio-only rationale: If you're billing audio-only telehealth, every note must document why video wasn't used. This is required by most commercial payers and many Medicaid programs. If your notes say "telephone session" without explaining why, you're at risk for denials.
The retroactive audit risk: payers are auditing 2023-2025 telehealth claims and denying claims that lack these documentation elements, even if the claims were initially paid. If you billed telehealth for eating disorder therapy during or immediately after the PHE and your notes don't include these elements, you're at risk for recoupment. Audit your 2023-2025 telehealth claims now, before a payer does it for you.
For a broader look at how reimbursement rules have shifted post-PHE, see our guide on mental health reimbursement 2026 for clinicians and IOP/PHP operators.
What This Means for Your Eating Disorder Program in 2026
If you're billing telehealth for eating disorder therapy in 2026, you need to audit your current practices against the post-PHE rules immediately. The PHE flexibilities that made telehealth billing simple are gone. The rules are now a payer-by-payer, state-by-state, code-by-code patchwork that requires constant vigilance.
Here's your action plan:
Audit your modifier usage: Are you appending modifier 95 (or GT, depending on the payer) to every telehealth claim, including group therapy? If not, you're generating denials.
Review your documentation: Do your telehealth notes include patient location, technology used, session medium, and (for audio-only) rationale for why video wasn't used? If not, you're at risk for retroactive audits.
Verify payer-specific policies: Are you billing Medicare, Medicaid, or commercial payers? Each has different rules for telehealth coverage, modifiers, and documentation. Don't assume that what works for one payer works for all.
Train your clinicians: Are your eating disorder therapists and RDs documenting telehealth sessions correctly? If not, you're at risk for denials and audits. Provide them with a telehealth documentation checklist and audit their notes regularly.
Monitor legislative changes: The telehealth rules are still evolving. Congress may extend or modify the current flexibilities before they sunset in 2027. Stay updated on telehealth policy updates from HHS to ensure you're billing correctly.
The post-PHE telehealth landscape is complex, but it's navigable if you're precise and proactive. Don't wait for a payer to audit your claims. Audit them yourself, correct any errors, and train your team on the 2026 rules. The cost of getting this wrong is too high to ignore.
Need help auditing your eating disorder program's telehealth billing practices or training your team on the post-PHE rules? Reach out to our team at Forward Care for a billing compliance review tailored to eating disorder therapy. We'll help you identify risk areas, correct billing errors, and implement documentation standards that protect your program from audits and denials.
