Telehealth Billing in 2025: POS, Modifiers, Cross-State Nuances

Your Go-To Guide for Accurate Reimbursement and Compliance

Telehealth is now a permanent part of healthcare delivery—but billing it correctly in 2025 still requires navigating a mix of federal rules, payer policies, and state-specific laws. Using the wrong Place of Service (POS) code, omitting a modifier, or misunderstanding licensure requirements across state lines can cost your practice time, money, and compliance credibility.

At ACCORDPRO, we help clinics streamline and simplify their telehealth billing workflows. Here’s your quick-reference guide to billing telehealth services accurately in 2025.

1. Know Your Telehealth POS Codes

POS 02 – Telehealth Provided Other than in Patient’s Home Used when the patient receives telehealth services outside their home (e.g., in a clinic, facility).

POS 10 – Telehealth Provided in Patient’s Home Used when the patient is located at home during the virtual visit.

What to Do:

• Use POS 10 for most virtual visits in 2025 unless the patient is in a facility.

• Confirm payer-specific POS requirements (some still default to POS 02).

• Double-check documentation to support location for audit protection.

2. Don’t Skip the Modifiers

Modifier 95 Used to indicate synchronous telemedicine services rendered via real-time interactive audio and video. Most widely accepted.

Modifier GT Used by certain payers (like Medicaid in specific states) for synchronous telehealth. Still required in limited contexts.

Modifier GQ Used for asynchronous (store-and-forward) telehealth in certain states or for specific programs.

What to Do:

• Use Modifier 95 on E&M and behavioral health codes unless your payer requires otherwise.

• Review Medicaid and commercial payer policies monthly for updates.

• Apply modifiers to all appropriate line items—not just the first code.

3. Use the Right CPT Codes for Telehealth

Common E&M and behavioral health CPTs billable via telehealth:

• 99202–99215 (Office/outpatient visits)

• 99421–99423 (Online digital E/M for established patients)

• 99441–99443 (Telephone E/M visits—payers vary on acceptance)

• 90832, 90834, 90837 (Psychotherapy)

• 99453, 99454, 99457 (Remote monitoring)

What to Do:

• Maintain a telehealth-approved code set by payer.

• Don’t assume all in-person codes are reimbursed virtually.

• Track denials and payer trends monthly.

4. Understand Cross-State Licensing & Billing Rules

Telehealth billing isn’t just about codes—it’s about provider licensure and payer jurisdiction.

What to Do:

• Confirm that your providers are licensed in the state where the patient is located.

• For multi-state groups, track licensure and payer enrollment state by state.

• Medicaid rules differ significantly by state—use state-specific billing portals and code sets.

• Consider enrolling in Interstate Medical Licensure Compact (IMLC) if available.

5. Don’t Forget Audio-Only Telehealth Nuances

Audio-only services (e.g., phone visits) remain billable in 2025—but with more restrictions.

What to Do:

• Use Modifier 93 (introduced in 2022) to indicate audio-only telehealth when applicable.

• Check whether specific CPTs are approved for audio-only by Medicare and commercial payers.

• Document time spent and clinical relevance to support reimbursement.

6. Track Denials and Payment Lag by Payer

Even when codes and modifiers are correct, payers may delay or deny telehealth claims due to:

• POS/modifier mismatches

• Invalid patient location

• Missing prior authorization

• Out-of-network status in patient’s state

What to Do:

• Analyze denial reasons by payer and code monthly.

• Set alerts for common telehealth denial trends.

• Use a denial dashboard to track and appeal quickly.

How ACCORDPRO Can Help

We help practices:

• Build payer-specific telehealth billing cheat sheets

• Standardize POS + modifier workflows across providers

• Monitor licensure and credentialing compliance across states

• Track and appeal denials related to telehealth

• Integrate telehealth claims into your RCM system without manual gaps

Final Thoughts

In 2025, telehealth billing requires precision, flexibility, and constant updates. The right codes and modifiers are just the beginning—compliance, documentation, and cross-state logistics matter more than ever.

ACCORDPRO helps practices simplify telehealth billing with expert RCM support, denial prevention, and cross-state credentialing guidance.

Need help optimizing your telehealth billing strategy?

 📞 Call 425-215-0517 or visit www.accordpros.com to schedule a quick billing workflow review.