Mental Health Telehealth Billing
Telehealth has become an important part of mental health care.
But billing telehealth correctly requires more than simply marking a visit as "virtual."
Depending on the payer, billing may involve:
- Place of service
- Modifiers
- Patient location
- Provider location
- Service type
- Technology used
- Payer-specific policies
- State requirements
POS 02 vs POS 10
For Medicare professional billing, CMS currently identifies:
POS 02
Telehealth Provided Other than in Patient's Home
The patient is receiving the telehealth service through telecommunications technology but is not located in their home.
POS 10
Telehealth Provided in Patient's Home
The patient is located in their home.
CMS confirms these definitions in its current telehealth guidance.
Don't Automatically Use POS 02 for Every Telehealth Visit
One of the most common mistakes is treating POS 02 as the universal telehealth code.
For Medicare professional claims, the patient's location determines whether POS 02 or POS 10 applies.
What About Modifier 95?
Modifier requirements vary by payer and service.
CMS's current telehealth materials contain modifier-specific instructions for certain services and settings. For example, CMS describes modifier 95 for certain institutional outpatient therapy telehealth services and uses different guidance for professional billing.
Therefore:
Do not automatically add modifier 95 to every mental-health telehealth claim.
Verify the payer's current instructions.
Audio-Only Telehealth
Audio-only services have separate rules and may be treated differently depending on payer, service and provider.
CMS currently identifies modifier 93 for synchronous telemedicine services rendered via telephone or other real-time interactive audio-only telecommunications technology in certain contexts.
Again, the exact rule depends on the service and payer.
Telehealth Billing Checklist
Before submitting a telehealth claim, verify:
- Patient location
- Provider location
- Payer
- Provider enrollment
- Correct CPT/HCPCS
- POS
- Modifier
- Authorization
- Telehealth coverage
- State requirements
- Documentation
Telehealth Is Not a Single Billing Rule
This is perhaps the most important message for providers.
Medicare rules are not automatically commercial-payer rules.
Aetna, Cigna, UnitedHealthcare, Blue Cross Blue Shield, Medicaid programs and other payers may have different policies.
The billing team should verify the applicable payer policy before submitting claims.
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