Telehealth Billing Has Changed — Has Your Practice Kept Up?
Telehealth billing in 2026 is nothing like it was in 2020. What started as emergency pandemic flexibilities has evolved into a complex, payer-by-payer landscape with different rules for Medicare, Medicaid, and each commercial insurer. Practices that don’t keep up with these changes are filing claims with the wrong place-of-service codes, missing required modifiers, and getting denied at rates that now average 11.8% industrywide for telehealth claims.
This guide covers the current state of telehealth billing, the CPT codes that matter most, and how TBC Solutions helps practices navigate this constantly shifting landscape to protect their reimbursement.
Key 2026 Telehealth Billing Changes You Need to Know
Medicare Telehealth Permanency
The CMS CY 2026 Physician Fee Schedule made several telehealth provisions permanent, including the removal of frequency limits for subsequent inpatient and nursing facility visits. Medicare now reimburses these virtual visits without restrictions on visit count — a significant win for hospitalists and post-acute care providers.
Remote Patient Monitoring (RPM) Classification
CMS continues to classify RPM as “care management services” rather than traditional telehealth, which means RPM services are NOT subject to the same originating site or geographic restrictions that apply to other telehealth visits. This is critical for practices billing cardiac monitors, CGMs, and other remote monitoring devices — the coverage pathway is different from standard video visits.
Audio-Only Visits
Medicare allows audio-only visits for certain services when the patient doesn’t have access to video technology. However, commercial payers vary widely on this — many still require audio-video for full reimbursement. Billing audio-only with the wrong modifier or to a payer that doesn’t cover it results in systematic denials across your telehealth claims.
Essential Telehealth CPT Codes and Modifiers
Most telehealth visits use the same E&M codes as in-person visits. The difference lies in the place-of-service code and modifiers:
Place of Service (POS) Codes
- POS 02 — Telehealth provided other than patient’s home (provider’s office)
- POS 10 — Telehealth provided in patient’s home
- POS 11 — Still used for some Medicare services when the telehealth frequency exception applies
Telehealth Modifiers
- Modifier 95 — Synchronous telemedicine service rendered via real-time interactive audio and video (required by most commercial payers)
- Modifier GT — Via interactive audio and video telecommunications (used for Medicare fee-for-service)
- Modifier 93 — Audio-only synchronous telemedicine (where permitted)
Remote Patient Monitoring CPT Codes
- 99453 — Remote monitoring of physiologic parameter(s), initial; set-up and patient education
- 99454 — Device(s) supply with daily recording(s) or programmed alert(s) transmission, per 30 days
- 99457 — Remote physiologic monitoring treatment management, 20 minutes or more per month
- 99458 — Each additional 20 minutes (add-on to 99457)
- 99091 — Collection and interpretation of physiologic data; physician or qualified healthcare professional
Chronic Care Management (CCM)
- 99490 — CCM services, 20 minutes per month
- 99491 — CCM services, 30 minutes per month (physician/QHP)
- 99489 — Complex CCM, each additional 20 minutes (add-on)
The Most Common Telehealth Billing Mistakes
Wrong POS Code
Using POS 11 (office) instead of POS 02 or 10 for a telehealth visit results in a claim that misrepresents where the service was delivered. This is both a denial risk and a compliance risk. With Medicare paying differently for in-person vs. telehealth E&M visits, the financial stakes are real.
Missing Time Documentation for RPM
RPM codes like 99457 require a minimum of 20 minutes of interactive communication with the patient per month and must be documented with specific time logs. Submitting RPM claims without this documentation — or with vague notes — results in denial or, worse, recoupment if audited.
Billing RPM Without Patient Consent
RPM requires documented patient consent before monitoring begins. This consent must be on file and available for audit. Practices that skip the consent step face full recoupment of all RPM claims if payers conduct a post-payment audit.
Payer Mismatch on Telehealth Coverage
Each commercial payer has its own telehealth coverage policy. Some still limit telehealth to certain specialties. Others require the provider to have seen the patient in person at least once before billing telehealth follow-up visits. Billing without checking payer-specific policies results in systematic denials across your entire telehealth book.
How TBC Solutions Manages Telehealth Billing
Telehealth billing errors are almost always systematic — meaning a single policy misunderstanding affects every claim of that type. TBC Solutions prevents this by:
- Maintaining payer-specific telehealth policy matrices — We track each payer’s current rules so your claims always use the correct codes, modifiers, and POS codes
- RPM compliance audits — Before billing, we verify consent documentation, time logs, and device qualification for every RPM patient
- Real-time denial monitoring — Telehealth denials are flagged immediately and reviewed for policy root causes, not just resubmitted
- Monthly policy updates — As payers adjust their telehealth rules, we update our billing protocols automatically — your practice doesn’t need to track it
Is Your Practice Leaving Telehealth Revenue on the Table?
Most practices that bill telehealth in-house are either under-coding (missing RPM and CCM billing opportunities) or over-coding (billing incorrectly and facing denials). Either way, revenue is lost.
TBC Solutions provides a complimentary telehealth billing audit for new clients — we review your current claims to identify missed opportunities and compliance risks before they become problems.
Schedule your free consultation today. Learn more about how we handle Revenue Cycle Management and claims scrubbing to maximize your telehealth reimbursement.