Telehealth became permanent for mental health after the pandemic — therapy is the one specialty where video visits stuck. But "permanent" doesn't mean "uniform": every payer applies its own rules, and telehealth denials concentrate in a few details that are easy to get wrong.
The modifiers: 95, 93, and FQ
- Modifier 95 — synchronous video (real-time audio and video). The default for video sessions with most commercial payers and Medicare.
- Modifier 93 — synchronous audio-only (telephone). Some payers cover audio-only sessions; many pay less or not at all.
- Modifier FQ — audio-only, appended alongside 93. Medicare requires both 93 and FQ on audio-only visits.
Place-of-service: 02 vs 10
POS 02 tells the payer the patient is somewhere other than home; POS 10 says the patient is at home. Medicare created POS 10 in 2022 and pays home-based telehealth differently from other locations. Commercial payers vary — some follow Medicare, some want POS 02 everywhere, some accept the practice's normal office POS. Using the wrong POS is one of the top reasons telehealth mental health claims deny.
The rules that change payer by payer
- Whether the patient needs an established relationship before a telehealth session
- Whether audio-only sessions are covered at all, and at what rate
- Which provider types can bill telehealth — counselors, social workers, psychologists, prescribers
- State licensure requirements when the patient is in a different state than the clinician
- Frequency limits or pre-authorization requirements on certain codes
How to keep telehealth claims clean
- Capture the session type and the patient's physical location at check-in, not at billing
- Apply the payer's own telehealth matrix — and keep it updated, because the rules shift several times a year
- Document time accurately; telehealth psychotherapy is still time-based coding
- Review telehealth denials weekly during the first month with any new payer
Telehealth rules are the part of mental health billing that changes most often — which makes it the area where a dedicated billing team pays for itself fastest.