The COVID-era telehealth flexibilities are mostly gone, and the rules are messier than they were before the pandemic. Place of Service codes that didn’t matter in 2021 matter again. Modifier rules that were waived have come back. Audio-only sessions that were billable everywhere are now restricted by payer. Most practices are still billing telehealth the way they did during the public health emergency, and the denials are starting to pile up.
Here’s the post-PHE telehealth billing landscape, payer by payer, with the specific code combinations that work in 2025 and 2026.
What ended when the PHE ended
The federal Public Health Emergency for COVID-19 ended in May 2023, but the unwinding of telehealth flexibilities has been gradual. The most consequential changes:
- Place of Service codes are back to normal. During PHE, providers billed telehealth with the POS that would have been used for in-person care, plus modifier 95. That ended.
- Audio-only restrictions returned for many payers. During PHE, audio-only was generally reimbursed. Post-PHE, most payers require synchronous video except for specific behavioral health codes.
- Geographic restrictions partially returned for Medicare. Some flexibilities have been extended through legislative action, but the underlying rules differ from in-person care in ways most practices haven’t fully understood.
- Provider-type restrictions tightened. Some payers limited which provider types can bill telehealth.
The current POS rules
Two Place of Service codes apply to telehealth in 2025:
- POS 02: telehealth provided to a patient in any non-home location (clinic, office, school).
- POS 10: telehealth provided to a patient in their home.
The distinction matters because reimbursement rates can differ. Medicare often reimburses POS 10 (home) at the non-facility rate, which is higher than the facility rate sometimes applied to POS 02. Commercial payers vary.
Practices that default to POS 02 for all telehealth (because it was the original telehealth POS) are losing per-claim reimbursement they could be getting with POS 10 when the patient is at home.
The modifier matrix
Three modifiers cover most telehealth billing scenarios. The right one depends on the payer and the modality:
- Modifier 95: synchronous telemedicine with real-time audio AND video. The default for most commercial payers.
- Modifier FQ: audio-only behavioral health (Medicare-specific). Used when video isn’t available or patient declines video. Restricted to behavioral health codes only.
- Modifier 93: synchronous audio-only services (used by some commercial payers and Medicaid). Different from FQ in scope.
Commercial payers vary in which modifiers they accept and require. Medicare uses FQ. Some plans require 95 even for audio-only behavioral health. Medicaid varies state by state.
The most common post-PHE billing mistakes
Mistake 1: Still using PHE-era POS
Some practices kept billing telehealth with POS 11 (office) plus modifier 95, the way they did during the PHE. That’s no longer correct outside of specific exceptions. Claims with the wrong POS get denied or paid at facility rates.
Mistake 2: Audio-only without correct modifier
Practices that conducted phone-only sessions during PHE often default to billing them as if they were synchronous video. Most payers can detect this through audit, and the post-PHE rules are stricter. Audio-only requires the right modifier (FQ for Medicare behavioral health, 93 for some commercial), and many payers don’t reimburse audio-only at all.
Mistake 3: Billing telehealth for non-eligible providers
Some payers restrict which provider types can bill telehealth. A medical assistant or licensed nurse delivering telehealth services may not be a billable provider under the payer’s rules, even if they were during PHE.
Mistake 4: Documentation gaps
Telehealth documentation now has to record:
- The modality (audio-only or audio-video).
- The patient’s location at the time of service.
- The provider’s location.
- For psychotherapy, the start/end times of synchronous interaction.
Payer audits in 2024-2025 have started recouping payments where documentation didn’t support the claimed modality.
Specialty-specific rules
Behavioral health
The biggest beneficiary of permanent telehealth flexibility. Medicare permanently extended audio-only behavioral health (with modifier FQ). Most commercial payers cover synchronous video for psychotherapy (90832, 90834, 90837) at parity with in-person rates.
Primary care and specialty consults
Coverage depends on the payer and the visit type. Routine follow-ups, medication management, and chronic care management often qualify. New-patient visits are sometimes restricted to in-person.
Pediatrics and family practice
Telehealth coverage is widely accepted for sick visits, behavioral consults, and follow-ups. Well-child visits typically require in-person.
Cardiology and chronic-disease management
Remote patient monitoring (RPM) codes (99453, 99454, 99457, 99458) cover device-collected data review and have specific time and frequency requirements that practices often miss.
A telehealth billing checklist for 2025
If your practice does any meaningful telehealth volume, audit your last 30 days of telehealth claims against these criteria:
- Are you using POS 02 vs POS 10 correctly based on patient location?
- Do you have the right modifier (95, FQ, or 93) for each payer?
- Is the modality (audio-only vs audio-video) documented in the chart for every claim?
- Is the patient’s location and the provider’s location documented?
- For psychotherapy, are start/end times in the note?
- Does the billing provider qualify as a telehealth-eligible provider with that payer?
If any of these are missing or inconsistent, the claim is at risk for denial or audit recoupment.
The takeaway
Telehealth post-PHE isn’t telehealth pre-PHE. The flexibilities are gone, the documentation bar is higher, and the audit risk is real. The practices keeping up are auditing their telehealth claims quarterly and updating their templates as payer rules evolve. The practices that haven’t are accumulating preventable denials.
If your telehealth claim mix has gotten complicated and you’re not sure if the billing is keeping up, a specialty medical billing partner familiar with post-PHE rules can audit recent claims and identify the patterns that need fixing before denials accumulate.
