What place of service code is required for telehealth?

Place of Service 02 (telehealth—patient home) is used when the patient is located at home. POS varies by state and patient location, but POS 02 is most common for remote patient telehealth visits.

What is modifier 95 used for?

Modifier 95 indicates synchronous telemedicine service (two-way real-time video/audio). It is appended to the primary service code to identify the visit as telehealth rather than in-person.

Are audio-only visits covered by Medicare?

Audio-only visits are covered for behavioral health services, certain evaluation codes, and specific services. Video-only telemedicine is generally required for other services, though exceptions exist for audio-based therapy and counseling.

CMS Telehealth Billing Rules and Requirements

What Are CMS Telehealth Billing Rules

CMS telehealth billing rules govern how providers must bill for remote patient care delivered via video, audio, or both. The rules require Place of Service 02 for home-based patient encounters and modifier 95 for synchronous telemedicine. CMS maintains a comprehensive list of 250+ covered telehealth services. Extended flexibilities allow audio-only visits for behavioral health and certain evaluation services, enabling broader access to care regardless of technology availability.

Who It Affects

Physicians, nurse practitioners, physician assistants, mental health professionals, therapists, and all telehealth providers must follow these rules. Healthcare organizations, medical practices, behavioral health providers, and practice management companies must ensure compliant billing. Medicare beneficiaries receive the benefit of these rules through expanded access to covered services regardless of location. Insurance plans and payers must maintain systems to adjudicate telehealth claims accurately.

Key Requirements

Use Place of Service 02 when the patient is located at home during the telehealth visit
Apply modifier 95 to the service code to identify it as synchronous telemedicine
Bill only services on the Medicare-approved telehealth list
Verify the patient's geographic location meets any applicable restrictions
Document the type of technology used (video, audio, store-and-forward)
Maintain informed consent from the patient regarding the telehealth modality
Ensure compliance with HIPAA privacy and security requirements
Submit clean claims with all required telehealth-specific documentation

Timeline and Enforcement

CMS telehealth rules became effective in March 2020 during the COVID-19 public health emergency. Extended flexibilities remain in effect with periodic review. State-level geographic restrictions have been relaxed for Medicare beneficiaries. Enforcement occurs through medical review, audit activities, and recovery auditor programs. Improper telehealth billing can result in claim denials, overpayment recoupment, and sanctions for patterns of non-compliance.

How to Comply

Review the current Medicare telehealth services list and identify eligible service codes
Train providers and billing staff on modifier 95 and Place of Service 02 requirements
Update electronic health record systems to capture telehealth service type
Implement pre-visit verification of patient location and geography when applicable
Document patient consent to receive telehealth services in the medical record
Create workflows to ensure only services on the CMS approved list are billed as telehealth
Audit a sample of telehealth claims monthly to verify correct coding

Frequently Asked Questions

Can providers bill telehealth services to non-Medicare plans?

Yes. While CMS rules set the standard, commercial plans, Medicaid plans, and other payers also cover telehealth services with similar requirements. Plans may have different telehealth service lists and reimbursement levels.

What happens if a provider forgets to apply modifier 95?

Claims without modifier 95 may be processed as in-person services, resulting in incorrect reimbursement. Providers should resubmit with the correct modifier to receive appropriate payment. Patterns of missing modifiers may trigger audits.

Are there geographic restrictions for telehealth in rural areas?

Medicare removed most geographic restrictions for telehealth during the public health emergency. Current rules allow telehealth for Medicare beneficiaries regardless of location, making care accessible in rural and underserved areas.

Related Resources

Modifier 95 Documentation | Telehealth Coding Guide | CO-6 Not Covered

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This content is provided for informational purposes only and does not constitute medical or compliance advice. Consult with your billing and compliance teams regarding specific telehealth billing requirements. Altair by S7 Lab is not responsible for changes in CMS rules or their interpretation.