Behavioral Health Telehealth Billing: POS, Modifiers, CoCM and the In-Person Rule

Medicare behavioral health telehealth billing runs on three rule sets in 2026 and 2027: telehealth billed with standard codes and POS 02 or 10, Collaborative Care billed monthly with 99492, 99493, 99494 or G2214, and crisis psychotherapy with 90839 and 90840. Under current law, CMS says an in-person visit requirement for mental health telehealth applies after 31 December 2027, so plan for it now.

This post covers the program-level rules. For session-level psychotherapy coding, including the 90837 time threshold and the prescriber add-ons, see CPT 90837 vs. 90834: why psychotherapy claims get downcoded.

Medicare telehealth for behavioral health through 2027

CMS’s Telehealth FAQ (updated October 2026) sets out where things stand under current law:

• Behavioral health telehealth is permanent. The Consolidated Appropriations Act, 2021 permanently removed geographic and place-of-service restrictions for behavioral health telehealth, including substance use disorder services. Patients in rural or urban areas can be treated at home, and two-way audio-only technology is permitted (CMS Telehealth FAQ, Q11).
• Broader flexibilities run through 31 December 2027. Until then, any Medicare beneficiary can receive telehealth anywhere in the United States. From 1 January 2028, patients will generally need to be in a medical facility in a rural area to receive telehealth, except for behavioral health services (CMS Telehealth FAQ, Q1).

Which codes Medicare uses. CPT 2025 added a separate series of telemedicine E/M codes beginning at 98000, which AAPC’s Codify describes as visits furnished by synchronous audio-video or audio-only technology, but Medicare did not adopt them. In the CY2025 PFS final rule (Federal Register 2024-25382, 9 December 2024), CMS finalized not paying separately for the 98000-series visit codes and paying separately only for 98016, which it pays in place of HCPCS G2012 (AAPC describes 98016 as a brief virtual check-in). Prescribers seeing Medicare patients by telehealth still bill the office E/M codes: 99202, 99203, 99204, 99205, 99212, 99213, 99214 and 99215. Therapists bill the psychotherapy codes. Commercial and Medicaid plans decide for themselves whether to accept the CPT telemedicine series, so check each payer’s policy.

Place of service 02 vs. 10

These definitions come from CMS’s Telehealth & Remote Monitoring booklet (MLN901705, December 2025), which tells professional billers to use POS 02 or 10. The booklet lists modifier 95 only for institutional outpatient therapy claims. Commercial and Medicaid plans set their own telehealth rules, including whether they want modifier 95 or modifier 93 on professional claims. That’s a payer-by-payer setting in your billing rules, not a single national one.

For Medicare, CMS’s Telehealth FAQ (Q17 and Q18) says telehealth modifiers BB (services furnished through a virtual platform the practitioner contracts with or pays for) and BC (telehealth services furnished incident to a practitioner’s professional service) are required beginning 1 January 2027 and do not change payment.

Check your practice-management defaults. A system that stamps POS 11 (office) on every visit will mislabel the sessions a therapist runs by video to a patient at home.

The 2028 in-person rule

CMS’s Telehealth FAQ (Q5) explains the requirement in section 1834(m) of the Social Security Act, which takes effect after 31 December 2027:

• New telehealth mental health patients from 1 January 2028 need an in-person, non-telehealth visit within 6 months before the first telehealth service in the home.
• After that, an in-person visit is required within 12 months of each mental health telehealth service, with limited exceptions.
• Existing patients are grandfathered in part. A beneficiary who began mental health telehealth on or before 31 December 2027 is considered established. They don’t need the 6-month prior visit, but they do need at least one in-person visit every 12 months after 31 December 2027.
• Who can do the in-person visit: a physician or practitioner of the same specialty in the same group, if the treating practitioner isn’t available.
• Audio-only after 2028 remains allowed for behavioral health at home if the practitioner can do video but the patient can’t or doesn’t consent to it (CMS Telehealth FAQ, Q6).

What to do now: build a list of Medicare behavioral health patients who have been seen only by telehealth, with the date of their last in-person visit. Every one of them needs an in-person visit scheduled during 2028. A patient added in January 2028 needs one before their first home telehealth session.

Collaborative Care Model: 99492, 99493, 99494 and G2214

CPT, as described in AAPC’s Codify, reports psychiatric Collaborative Care (CoCM) by calendar month:

• 99492: the initial 70 minutes of CoCM in the first calendar month.
• 99493: the first 60 minutes in a subsequent month.
• 99494: each additional 30 minutes, added to 99492 or 99493.

CMS’s Behavioral Health Integration Services booklet (MLN909432, January 2026) sets the Medicare requirements:

• A team of three: the treating (billing) practitioner, a behavioral health care manager, and a psychiatric consultant.
• An initiating visit by the billing practitioner, such as an AWV, IPPE, TCM or a comprehensive E/M visit.
• Consent: verbal is fine, documented in the chart, including notice that cost sharing applies.
• The model’s core: a registry, validated rating scales and weekly caseload review with the psychiatric consultant.
• G2214 is Medicare’s HCPCS code for the first 30 minutes of care manager time in a month. CMS’s example is a patient you see and then hospitalize or refer before the 99492 or 99493 minutes are reached.
• General BHI (99484) can’t be reported in the same month as CoCM for the same patient. CPT time rules apply to both.
• New for 2026: the CY2026 PFS final rule (fact sheet, 31 October 2025) created optional add-ons for practices billing Advanced Primary Care Management. The booklet lists G0568 and G0569 for CoCM and G0570 for general BHI, billed with an APCM base code (G0556, G0557 or G0558) in the same month. These are not time-based.

CoCM is not on the Medicare telehealth list because it isn’t a face-to-face service, and the telehealth restrictions don’t apply to it (CMS Telehealth FAQ, Q13).

Psychotherapy for crisis: 90839, 90840, G0017, G0018

CMS’s Psychotherapy for Crisis page (last modified 25 February 2026) lists 90839 for the first 60 minutes of psychotherapy for crisis and 90840 for each additional 30 minutes, and sets the Medicare rules:

• Time doesn’t have to be continuous on the date of service.
• When the service is furnished in an “applicable site of service,” meaning any place where the non-facility rate applies other than the office, bill G0017 and G0018 instead. Medicare pays those at 150% of the non-facility fee schedule amount. Because the office is excluded, G0017 and G0018 don’t belong on a claim with POS 11.
• Don’t bill the crisis codes with 90791, 90792, 90832, 90833, 90834, 90836, 90837 or 90838. CMS’s list also excludes billing them with the other codes in CPT’s psychiatric services and procedures section.

Pre-2028 checklist

1. Audit POS on every telehealth claim: 10 for home, 02 for elsewhere.
2. Load payer-specific modifier 95 and 93 rules into the claim scrubber.
3. Build the telehealth-only patient list and schedule 2028 in-person visits.
4. For CoCM, confirm consent, registry entries and care manager minutes each month before billing.
5. Route crisis sessions outside the office to G0017 and G0018.

More behavioral health context is in behavioral health billing challenges and fixes and our resources library.

If telehealth, CoCM and the 2028 transition are more than your team can track alongside the daily claims, AMS Solutions, Inc., physician-founded in 1992, offers mental health billing services with AAPC-certified coders. To see where your telehealth claims stand, request a Free Billing Analysis or call 866-973-2221.