Telehealth’s COVID-era flexibilities are gone. In 2026, family practice telehealth billing is governed by a fragmented set of permanent rules plus state-by-state nuances plus payer-specific policies. Here’s how AMS Solutions bills telehealth cleanly in 2026 — without leaving revenue on the table or triggering audit risk.
What changed vs PHE-era rules
Three big shifts. (1) The CMS waiver that allowed telehealth from patient homes for non-mental-health services largely expired end of 2024. (2) Audio-only coverage for E/M is narrower in 2026 — primarily limited to mental/behavioral health and specific behavioral integration codes. (3) Many commercial payers have followed Medicare’s lead and reduced telehealth coverage outside of mental health.
Permanent vs temporary additions to the telehealth services list
Permanent (Medicare): Behavioral health services, including codes 99202-99215 when provided by mental health professionals, 96156-96161 (health behavior assessment), and 90832-90838 (psychotherapy). Plus eligible chronic disease management services (CCM, RPM) and Federally Qualified Health Center / Rural Health Clinic services.
Expired (Medicare, end of 2024): General E/M from patient home for non-mental health visits. PT/OT/SLP from home. Audio-only E/M outside of behavioral health.
Audio-only billing (99441-99443, G2012)
Limited use cases in 2026: (1) Mental/behavioral health services billed with modifier 93 (audio-only) and POS 02 or 10; (2) Brief check-in services (G2012, 5-10 minutes) for established patients; (3) Some state Medicaid programs still cover audio-only broadly. Verify per payer.
Modifier 95 vs modifier 93
Modifier 95: Synchronous audio-video telehealth. Use for video-based E/M visits. Required for Medicare and most commercial payers.
Modifier 93: Audio-only synchronous telehealth (no video). Required for behavioral health audio-only services and any other audio-only telehealth where the payer permits. Started 2024 — Medicare now requires this on permitted audio-only claims.
POS 10 (patient home) vs POS 02 (other) — billing implications
POS 10: Patient at home receiving telehealth. Lower facility fee. Use for at-home patients regardless of provider location.
POS 02: Telehealth provided other than home (e.g., patient in clinic exam room receiving telehealth consult from specialist). Higher facility fee may apply.
Pick the wrong POS and you lose 20-30% of reimbursement. Verify the patient’s actual location each visit.
Mental/behavioral health telehealth — the exemption
Mental health services remain broadly covered: E/M for mental health diagnosis, psychotherapy, substance use disorder treatment. Originating-site requirements are waived. Audio-only is permitted (with modifier 93). Most family practices have substantial mental health visits — this is one of the few areas where telehealth remains revenue-positive at 2024 levels.
Commercial payer telehealth coverage 2026
- Anthem BCBS: Follows Medicare for E/M. Broader for behavioral health.
- UnitedHealthcare: Reduced general telehealth coverage in 2025. Verify benefits per plan.
- Cigna: Maintains broader telehealth coverage than Medicare for established patients.
- Aetna: Aligned with Medicare; permanent telehealth for behavioral health only.
- Medicare Advantage plans: Variable by carrier. Check plan documents per patient.
E/M coding when patient is remote
Use the same E/M codes (99202-99215) with modifier 95 or 93. MDM-based level selection works identically to in-person. Time-based selection can include all clinically relevant time on the date of encounter (review of records, documentation, etc.). Document the time clearly.
5 common telehealth billing errors that get denied
- Missing modifier 95 or 93
- Wrong place-of-service code
- Billing telehealth for a service that’s no longer eligible (e.g., general E/M for at-home Medicare patient in 2026)
- Not documenting the patient’s consent to telehealth
- Coding from chart review rather than billing for the actual video visit time
Documentation checklist for clean telehealth claims
- Patient consent to telehealth on file (annual recertification ok)
- Provider and patient locations documented in the note
- Mode of communication (video, audio-only) explicitly noted
- MDM or time documented per 2021 E/M rules
- Modifier 95 (video) or 93 (audio-only) on the claim
- Correct POS (10 = patient home, 02 = other)
- For Medicare: provider must be physically located in the U.S.
Need help auditing your telehealth claims workflow? Our team has helped family practices avoid telehealth billing pitfalls — we can pull a sample of your recent telehealth claims and identify documentation/modifier issues. Call (214) 571-6317 or book a 30-minute review. Grab our free 2026 Family Practice CPT Cheat Sheet for additional code references. State-specific: Texas family practice billing | New York family practice billing.
