Key takeaways
- Many Medicare telehealth flexibilities run through December 31, 2027, but some remain temporary.
- Codes, modifiers, and place of service vary by payer.
- Providers usually need a license where the patient is located.
Telehealth billing has been a moving target since 2020. Medicare relaxed many rules during the public health emergency, and Congress has extended those flexibilities several times since, sometimes after short lapses. Commercial plans and state Medicaid programs set their own rules. The result is that the same virtual visit can be billed differently depending on the payer.
Where Medicare stands now
In February 2026, Congress extended many Medicare telehealth flexibilities through December 31, 2027. These include allowing patients to receive many telehealth services from home, regardless of where they live, and continued eligibility for providers such as physical therapists, occupational therapists, and speech language pathologists. Some flexibilities are permanent and some are temporary, so check current CMS guidance before relying on any of them.
What to check before you bill
- Payer coverage. Confirm the payer covers the service by telehealth and whether it has its own list of allowed codes.
- Place of service. Use the place of service code the payer requires for telehealth, which may differ between a patient at home and a patient elsewhere.
- Modifiers. Some payers want a telehealth modifier such as 95, and others do not. Audio only services may need a different modifier.
- Audio only rules. Check whether the payer covers audio only visits for that service type.
- Provider location and licensing. The provider generally needs to be licensed in the state where the patient is located at the time of the visit.
- Documentation. Record that the visit was conducted by telehealth, the technology used, the patient's location, and consent where required.
Behavioral health has its own rules
Behavioral health telehealth has been treated differently from other services in Medicare, with some protections made permanent and specific rules about in person visits. Many commercial payers also have separate behavioral health telehealth policies, sometimes managed by a separate vendor. Check both.
Credentialing and telehealth
A provider seeing patients across state lines may need licenses and payer enrollment in each state. Some payers also require a telehealth specific enrollment or a practice location on file. Gaps here lead to denials even when the visit itself was billed correctly.
Plan for change
Because many Medicare flexibilities are temporary, build a simple way to update your rules when policy changes. Keep a short payer by payer reference for telehealth codes, modifiers, and place of service, and review it whenever Congress or CMS announces a change.
Telehealth policy changes often. Check current CMS guidance and each payer's policy before billing, and confirm the effective date of any change.
A quick example
A behavioral health practice sees patients at home by video. Medicare claims go out with the place of service and modifier Medicare expects, while one commercial plan requires a different place of service and another requires modifier 95. Keeping a short payer by payer reference means each claim is built correctly the first time, instead of being corrected after a denial.
Where Afiable helps
Afiable bills telehealth with payer specific checks for codes, modifiers, and place of service, and supports credentialing for providers who see patients virtually. Book a free audit and we will review a sample of your telehealth claims.
Questions practices ask
Do commercial plans follow Medicare telehealth rules?
Not always. Each plan sets its own telehealth policy, so check codes, modifiers, and coverage for each payer.
Is audio only telehealth covered?
It depends on the payer and service. Medicare covers some audio only services, and behavioral health has its own rules. Check payer policy.
This article is general information for practice owners and managers. Payer policies and regulations change, so confirm current rules with each payer before acting.