Telehealth Billing for Mental Health: POS 02 vs POS 10, and Modifier 95 vs GT

For telehealth mental health visits, the place of service says where the patient was: POS 10 when the patient is at home, POS 02 when the patient is somewhere else. The modifier (95, GT, 93 or none) depends on the payer’s current policy, not on a single national rule. Get both right and the claim pays at the expected rate; get either wrong and it is denied or paid at a lower rate.

Telehealth is now a normal part of therapy and psychiatry, but billing rules still differ from payer to payer. Most telehealth denials we see come from three things: the wrong place of service, a missing or outdated modifier, or a provider who is not licensed or credentialed where the patient was.

Place of service: 02 vs 10

POS	Official name	Use it when
10	Telehealth provided in patient’s home	The patient is at home (or another private location they consider home)
02	Telehealth provided other than in patient’s home	The patient is at a clinic, hospital, school or other non-home location
11	Office	In-person office visits. Some payers have told providers to use the in-person POS with a telehealth modifier instead of 02 or 10.

Most outpatient therapy and psychiatry telehealth is POS 10, because most patients join from home.

Payment can differ between POS 02 and POS 10 for some payers, since the place of service affects which rate applies. That is one more reason to use the one that matches the visit, not the one that pays better.

Modifiers: 95, GT, 93 and FQ

Modifier	Meaning	Where it is used
95	Synchronous telemedicine via real-time audio and video	Required or accepted by many commercial payers and Medicaid plans
GT	Via interactive audio and video telecommunication systems	An older modifier. Medicare stopped using it for most claims years ago; some commercial and Medicaid plans still accept it
93	Synchronous telemedicine via audio only	Audio-only visits, where the payer covers them
FQ	Service furnished using audio-only communication	Used by some programs, such as certain Medicare and FQHC/RHC claims

The practical rule: keep a payer-by-payer table of which place of service and modifier each payer wants, and update it when payers change their telehealth policies. That is exactly what our billing team does for each client.

Medicare notes

• Medicare uses POS 02 and POS 10 for telehealth, and generally does not use modifier GT.
• Medicare covers telehealth for mental health services from the patient’s home.
• Medicare has a rule requiring an in-person visit before or during tele-mental health care. Its start date has been delayed several times, so check the current status before relying on it either way.
• Medicare Advantage plans can have their own telehealth rules, separate from original Medicare.

Licensing and credentialing for multi-state telehealth

The rule that matters is where the patient is located during the visit.

• License: you need a license, or a compact privilege, valid in the patient’s state. Counseling, psychology, social work and nursing each have their own interstate compacts, and not every state has joined each one.
• Credentialing: you need to be in-network with the patient’s plan in that state. Being in-network with a plan in one state does not automatically make you in-network with the same company in another.
• Prescribing: prescribers also need to follow federal and state rules for prescribing controlled substances by telehealth, including DEA registration in the patient’s state where required.

Our client case study shows what this looks like at scale: a telehealth psychiatry practice seeing patients in 23 states, with more than 100 payer enrollments.

Checklist before a telehealth claim goes out

• The note says the visit was by telehealth, audio-video or audio-only
• The note records where the patient was (home or another location) and the state
• POS matches the patient’s location
• The modifier matches this payer’s current policy
• The provider is licensed in the patient’s state and credentialed with the plan

Payer telehealth policies change often. We check each payer’s current policy before submission. If telehealth claims are being denied or paid at the wrong rate, a free claims audit will show where.

Frequently asked questions