Telehealth made it possible for behavioral health practices to survive 2020. It also created a new category of billing error that did not exist before, and payers are getting better at catching it.
These are not obscure technicalities. They are the same five mistakes that show up in denial reports across Medicare, Medicaid, and commercial payers every quarter. If your practice bills telehealth sessions, read this before your next claim goes out.
Mistake 1: Using the Wrong Place of Service Code
This is the most common telehealth billing error, and it is entirely preventable. Most electronic health record systems default to Place of Service 11 (Office). If your front desk or biller does not manually update that field for every telehealth session, you are submitting claims with the wrong POS code, and many payers will deny or reduce reimbursement as a result.
The rule is simple: POS 02 if the patient is somewhere other than home. POS 10 if the patient is at home. POS 11 is for in-person only. Never use POS 11 on a telehealth claim.
Why does this matter? Payers use the POS code to determine the correct fee schedule. Medicare, for example, pays at a different rate depending on whether the patient is at home (POS 10) versus at a non-home originating site (POS 02). A POS mismatch does not just risk a denial; it can result in underpayment that you never catch because the claim technically processed.
Fix it: Audit your EHR’s default POS setting for telehealth appointments. Build a checklist item into your front desk workflow, confirm patient location before every telehealth session and document it in the chart.
Mistake 2: Appending the Wrong Modifier or None at All
Telehealth modifier rules have changed more times in the past four years than in the previous two decades combined. As of 2026, the standard modifiers are: Modifier 95 for real-time audio and video, Modifier GT for legacy audio-video (still accepted by some commercial payers but being phased out), Modifier FQ for audio-only sessions where video is not used, and Modifier FR for supervision scenarios where the supervising provider is connected via telehealth.
The error practices make most often: submitting telehealth claims with no modifier at all, or defaulting to GT when their payer has switched to requiring 95. Both scenarios result in avoidable denials.
Fix it: Check your top three payers’ current telehealth billing guides, not the version from 2022, the current one. Modifier requirements were updated significantly in 2023 and again in 2024. If you bill audio-only sessions, make sure FQ is in your EHR’s workflow. Members can find the full modifier reference table in the Telehealth Cheat Sheet inside the portal.
Mistake 3: Billing Audio-Only Sessions Without Documentation
Audio-only telehealth (telephone-only, no video) is covered by Medicare and many commercial payers, but coverage comes with a condition. The payer expects to see a clinical reason why video was not used.
Documentation does not need to be lengthy. One sentence in the clinical note is sufficient: “Session conducted by telephone due to patient’s inability to access video technology.” What it cannot be is absent.
Post-payment audits for audio-only claims have increased across all major payers since 2023. If your chart does not document why the session was audio-only, you risk recoupment — even on claims that were originally paid.
Fix it: Add a required field or prompt to your telehealth note template. Train every clinician to complete it before saving the note.
Mistake 4: Not Checking Telehealth Eligibility Before Billing
Not every CPT code is telehealth-eligible with every payer. Individual therapy codes like 90834 and 90837 are broadly covered via telehealth. Psychological testing codes — 96130, 96131, 96136, 96137- are generally not, with very limited exceptions.
Commercial payers maintain their own telehealth-eligible code lists, and those lists are not identical to Medicare’s. Aetna, UHC, and BCBS have each adjusted their lists in the past 18 months. What was billable via telehealth in 2023 may not be in 2025.
Fix it: Download the current telehealth policy from your top three payers’ provider portals and cross-reference against every CPT code your practice bills. Members have access to the full CPT Telehealth Eligibility Matrix in the portal, covering all 14 codes across all six major payers.
Mistake 5: Assuming the Rules Are the Same as Last Year
Telehealth billing rules are the least stable area in behavioral health reimbursement. The pandemic-era flexibilities that allowed audio-only billing, home-based originating sites, and expanded code lists were extended repeatedly, and each extension came with modifications to the original rules.
Practices that set up their telehealth billing workflow in 2021 and have not revisited it since are almost certainly operating on outdated assumptions. The modifiers have changed. The eligible code lists have changed. Some states have locked in permanent telehealth parity; others have not.
The cost of staying current is low. The cost of a post-payment audit on 18 months of incorrect telehealth claims is not.
Fix it: Schedule a quarterly billing review specifically for telehealth. Pull denial reports filtered by telehealth-related denial codes. If you see a pattern, investigate the payer’s current policy before assuming it is a coding error on your end.
The Bottom Line
None of these mistakes require a billing specialist to fix. They require current information and a workflow that applies it consistently. The practices that get telehealth billing right are not doing anything complicated — they are checking the rules regularly and building them into their process.
The ones that don’t are funding their payer’s audit team.
Candor Health Intel monitors telehealth policy changes across Medicare, Medicaid, UHC, Aetna, BCBS, and Cigna every week and translates them into plain English, delivered every Tuesday morning. See a free sample issue at candorhealthintel.com.