Telehealth Reimbursements Beyond CPT: How Payers Handle POS, Audio‑Only & Device-Based Services

Telehealth is no longer a temporary solution—it’s a core part of modern care delivery. But while CPT and HCPCS codes form the foundation of telehealth billing, they don’t tell the whole story. Payers—especially commercial insurers—often impose unique rules, limitations, and interpretations regarding how telehealth is reimbursed, particularly for place of service (POS) codes, audio-only visits, and device-based remote care.

In this blog, we explore how telehealth reimbursement works beyond just CPT codes, focusing on what practices need to know about payer-specific expectations, audio-only care, and new trends in technology-based services.

Why Telehealth Billing Is So Complex

At a glance, billing for telehealth might seem straightforward: use the appropriate CPT code, attach a modifier (e.g., 95 or GT), and submit. However, the reality is more nuanced.

Reimbursement depends on:

• The payer’s specific telehealth policies
• Whether the visit was audio-only, video-based, or device-generated
• Place of service (POS) codes used
• Whether the provider is in-network or out-of-network
• State-level parity laws and Medicaid rules

Practices must go beyond coding manuals and understand each payer’s internal guidelines to avoid denials and maximize reimbursement.

Beyond CPT: The Role of POS Codes in Telehealth Billing

Place of Service (POS) codes indicate the location where services are rendered. For telehealth, POS codes determine whether the payer sees the service as equivalent to in-person care—and how much they’ll reimburse.

Key POS Codes for Telehealth:

What to Watch:

• Medicare generally requires POS 10 for home-based telehealth.
• Some private payers prefer POS 11 + modifier 95 to reimburse at in-office rates.
• Billing the wrong POS can result in lower payments or outright denials.

Understanding Modifiers for Telehealth

Modifiers are critical to signal that the service was provided virtually.

Payer Variability:

• Medicare accepts modifier 95 and FQ (for audio-only).
• Some commercial plans require GT, especially for older systems.
• Not all payers reimburse audio-only, even with modifier FQ.

Audio‑Only Telehealth: Who Pays and How

Since the pandemic, audio-only visits (e.g., phone calls) have become an essential way to reach elderly, rural, or tech-limited patients.

What Medicare Covers:

• CPT codes 99441–99443 were temporarily covered but expired under Medicare in 2022.
• Now, Medicare allows audio-only services when indicated—with modifier FQ—but only for select behavioral health and primary care services.

What Private Payers Do:

• Varies widely. Some:
  • Still pay 99441–99443
  • Reimburse based on standard E/M codes (99212–99214) with modifier FQ
  • Refuse to pay without video unless under behavioral health exception

Pro Tip:

Always verify payer policy for audio-only claims. Use call logs or documentation showing that a real-time verbal interaction occurred.

Device-Based & Remote Monitoring Services

Telehealth is no longer limited to virtual visits. Device-based services—such as RPM (Remote Patient Monitoring) and RTM (Remote Therapeutic Monitoring)—are now separately billable with CPT codes.

Common CPT Codes for RPM & RTM:

What to Know:

• Not all commercial payers reimburse these yet.
• Documentation must include:
  • Time spent
  • Data reviewed
  • Patient interaction details
• Medicare does reimburse for both RPM and RTM—but with strict criteria:
  • Devices must meet FDA definitions
  • Must collect 16+ days of data per 30-day period

Behavioral Health: A Telehealth Standout

Behavioral and mental health services are leading the way in permanent telehealth policy expansion.

Key updates:

• Medicare now reimburses:
  • Audio-only psychotherapy
  • Virtual IOP (Intensive Outpatient Programs)
  • Tele-behavioral health with relaxed location restrictions
• Private payers are following suit, especially for:
  • Depression management
  • Substance use disorder counseling
  • Psychiatry follow-ups

Tip: Use CPT codes 90791–90834 for therapy sessions and ensure proper modifiers and POS codes are attached.

Reimbursement Variations: Medicare vs. Medicaid vs. Commercial Payers

Key Compliance Tips for Telehealth Reimbursement

• Stay updated on payer telehealth guidelines quarterly.
• Create a POS and modifier cheat sheet by payer.
• Use pre-bill scrubbing software to catch errors.
• Ensure provider documentation supports the modality and interaction type.
• Track denials by telehealth type to identify reimbursement trends.

Conclusion

Telehealth is evolving faster than static CPT codes can keep up. To maximize reimbursement and minimize denials, providers must go beyond the CPT manual and understand how each payer handles POS, modality, and telehealth services differently.

By aligning your billing with payer expectations—and being strategic with documentation, modifiers, and service setup—you’ll position your practice for success in the post-pandemic era of hybrid care.

Need Help Navigating Telehealth Billing?

Right Medical Billing specializes in telehealth reimbursement across specialties. From POS code configuration to modifier compliance and payer negotiation—we’ve got you covered.