Telehealth Billing for Therapists: Complete Guide

Telehealth is no longer a pandemic exception—it's a permanent part of mental health practice. But billing telehealth correctly requires understanding modifiers, place of service codes, and payer-specific rules that don't apply to in-person sessions.

This guide covers everything you need to bill telehealth therapy accurately: the CPT codes stay the same, but the modifiers and place of service codes make all the difference.

Telehealth Billing Basics

Key principle: Telehealth uses the same CPT codes as in-person services. What changes is:

1. Modifiers indicating telehealth delivery
2. Place of Service (POS) codes indicating location
3. Documentation noting telehealth-specific elements

Telehealth Modifiers

Modifier 95 — Synchronous Telemedicine

Use for: Real-time audio-video telehealth (the standard for therapy)

When to use: Any CPT code delivered via live video

Example: 90834-95 (individual therapy, 38-52 min, via telehealth)

Most commercial payers and Medicare recognize modifier 95 for synchronous telehealth.

Modifier GT — Via Interactive Audio and Video

Use for: Same purpose as modifier 95

History: GT was widely used before modifier 95 became standard. Some payers still prefer GT.

Guidance: Check your specific payer requirements. When in doubt, use 95 (more current standard).

Modifier 93 — Audio-Only

Use for: Telephone-only sessions (no video)

Coverage: Limited. Many payers don't cover audio-only at full psychotherapy rates. Some don't cover it at all.

When it may apply:

• Client lacks video capability
• Emergency/crisis contact by phone
• Specific payer allowances during limited circumstances

Place of Service (POS) Codes

POS codes indicate where the service was rendered. For telehealth, two codes matter:

POS 02 — Telehealth Provided Other than in Patient's Home

Use when: The patient is at a qualifying originating site—a clinic, hospital, or other healthcare facility receiving the telehealth service.

Rare for outpatient therapy: Most therapy clients are at home, not at originating sites.

POS 10 — Telehealth Provided in Patient's Home

Use when: The patient is at their home (or other non-clinical location) during the telehealth session.

This is your default for outpatient telehealth. Most therapy clients connect from home.

POS 11 — Office

Use when: Service provided in-person in your office.

Do not use for telehealth—even if you're in your office, the POS reflects where the patient is.

Billing Structure

Complete Telehealth Claim

Claim line: 90834-95, POS 10, F41.1

Multiple Modifiers

If you need multiple modifiers (e.g., telehealth + interactive complexity):

• 90834-95, 90785-95
• Both services get the telehealth modifier

Documentation Requirements

Telehealth documentation includes everything required for in-person sessions, plus:

Telehealth-Specific Elements

1. Mode of delivery: "Service provided via HIPAA-compliant video platform"
2. Platform used: "[Platform name] telehealth platform" (Zoom for Healthcare, Doxy.me, SimplePractice Telehealth, etc.)
3. Client identity confirmed: "Client identity verified"
4. Client location: "Client located at home in [State]"
5. Technology issues: "No technology disruptions" or "Brief audio disruption at [time], resolved within 2 minutes"
6. Appropriateness: "Telehealth appropriate for this session" (implied, but some require explicit statement)

Sample Documentation

HIPAA-Compliant Platforms

Telehealth must use HIPAA-compliant technology. This means:

Required Features

• End-to-end encryption
• Business Associate Agreement (BAA) with the vendor
• Access controls
• Audit logging

Compliant Platforms (Examples)

• Doxy.me
• SimplePractice Telehealth
• TherapyNotes Telehealth
• Zoom for Healthcare (not regular Zoom)
• VSee
• Thera-LINK

Not Compliant

• Regular Zoom (without healthcare plan)
• FaceTime (no BAA available from Apple)
• Skype consumer version
• Google Meet (consumer version)
• Standard SMS/text messaging

Telehealth Parity Laws

Many states have telehealth parity laws requiring insurers to reimburse telehealth at the same rate as in-person services.

What Parity Means

• Same reimbursement rate for 90834-95 as for in-person 90834
• Cannot deny coverage solely because service is via telehealth
• Must cover telehealth for conditions covered in-person

State Variation

Parity laws vary significantly:

• Some states have strong parity mandates
• Some have exceptions or limitations
• Some don't have parity laws

Check your state's requirements and your specific payer contracts.

Medicare and Telehealth

Medicare has expanded telehealth coverage significantly. Key points:

• Most mental health services covered via telehealth
• Geographic restrictions largely removed for mental health
• Patient home is acceptable originating site
• Audio-only allowed for mental health with certain restrictions

Stay current: Medicare telehealth policy continues to evolve.

Licensure Considerations

State Where Client Is Located

You must be licensed in the state where the client is located during the session—not where you are.

Interstate Compacts

PSYPACT (Psychology Interjurisdictional Compact) allows psychologists to practice across participating states.

Counseling Compact allows licensed counselors to practice across participating states (newer, fewer states).

Check whether your profession has compact options and whether relevant states participate.

Documentation

Document client location at each session. If location changes (client travels), this affects your ability to provide care.

Common Telehealth Scenarios

Scenario 1: Standard Video Session

Setup: You and client both on video, client at home

Billing: 90834-95, POS 10

Scenario 2: Client Video Issues

Setup: Session starts as video, client's camera fails, continues audio-only

Options:

• If mostly video: Bill as video session with documentation note
• If mostly audio: May need to bill as audio-only (check coverage)
• Reschedule if substantive session can't occur

Scenario 3: Client Traveling

Setup: Client is in a different state than usual

Action:

• Verify you're licensed in client's current state
• If not licensed there, cannot provide session (with limited exceptions)
• Document client's location

Scenario 4: Multiple Participants (Family Therapy)

Setup: Telehealth family session, family members in different locations

Billing: 90847-95, POS 10 (patient's location)

Documentation: Note all participants and their locations

Scenario 5: Hybrid Practice

Setup: Some sessions in-person, some telehealth with same client

Billing:

• In-person: 90834, POS 11
• Telehealth: 90834-95, POS 10

Documentation: Clearly distinguish session modality

Telehealth Best Practices

Before the Session

• Test technology
• Ensure private, confidential space on your end
• Have backup plan if technology fails
• Verify client's location (for licensure)

During the Session

• Confirm client identity
• Confirm client is in a private space
• Address any technology issues promptly
• Maintain professional environment

After the Session

• Document telehealth-specific elements
• Use correct modifier and POS code
• Note any issues that occurred

For Your Practice

• Use only HIPAA-compliant platforms
• Maintain BAA with telehealth vendor
• Know your state and payer requirements
• Stay current on telehealth policy changes

Troubleshooting Common Issues

Claim Denied: Missing Modifier

Problem: Billed telehealth without modifier 95

Solution: Rebill with correct modifier; update billing process to include modifier for all telehealth claims

Claim Denied: Wrong POS Code

Problem: Used POS 11 (office) instead of POS 10 (home)

Solution: Rebill with POS 10; remember POS reflects patient location

Lower Reimbursement Than Expected

Possible causes:

• Payer doesn't have telehealth parity
• Wrong modifier used
• Audio-only rate applied

Action: Review payer contract; appeal if parity should apply

Payer Doesn't Recognize Modifier 95

Some payers prefer GT modifier

Action: Check payer-specific requirements; rebill with GT if needed

Telehealth billing is straightforward once you know the modifiers and POS codes. Use modifier 95 for video sessions, POS 10 for clients at home, document the telehealth-specific elements, and use HIPAA-compliant platforms. The CPT code itself doesn't change—just how you identify the delivery method.