Telehealth billing
Telehealth superbills: POS 02 vs 10 vs 11, and when modifier 95 applies
Three fields decide whether a telehealth superbill is payable: the place of service, the modifier, and whether the visit was video or audio-only. They are also the three fields most often filled in by habit instead of by rule.
Last reviewed October 2026. General information for out-of-network therapists, not legal or billing advice. Payer rules change — confirm with the payer before you bill.
Try the free check first. It runs entirely in your browser, takes about three minutes, and never uploads client data.
Check a telehealth sessionPOS describes where the client is, not where you are
The most common misconception is that place of service describes the clinician’s location. It does not. POS describes the location of the patient at the time of the service, which is why a therapist working from a home office can still bill POS 10.
| POS | Meaning | Typical telehealth use |
|---|---|---|
| 02 | Telehealth provided other than in the patient’s home | Client is at work, a school, or another clinic |
| 10 | Telehealth provided in the patient’s home | Client is at home — the usual case for therapy |
| 11 | Office | In-person visit; not an acceptable telehealth POS for some payers |
Why POS 11 on a telehealth line is a red flag
During the public health emergency, telehealth was billed with the in-person POS plus a modifier. That flexibility ended. One large behavioral health payer (Optum, UnitedHealthcare’s behavioral arm) has required POS 02 or 10 on all behavioral telehealth claims since November 1, 2023, and states explicitly that POS 11 is not an acceptable telehealth place of service.
The same guidance says a claim that carries only a telehealth modifier (93, 95, FQ, GQ, GT) with no POS 02 or 10 is not payable. In other words the modifier is not a substitute for the POS — you need both, and they have to agree.
Modifier 95 means synchronous audio and video
Modifier 95 is for real-time, interactive audio-video visits. If the session was a phone call, 95 is the wrong modifier: audio-only visits use 93 or FQ depending on the payer, and using both 95 and 93 on one line is a contradiction that invites a CO-4.
GT is legacy. It is still required by some state Medicaid programs and a handful of commercial plans, but it is no longer the default for telehealth. If you are billing a plan that wants GT, use GT — confirm with the payer rather than guessing.
The exception that keeps coming back: POS 11 + 95
Medicare and some commercial payers have, in certain periods, wanted telehealth psychotherapy billed as POS 11 with modifier 95 so the claim prices at the non-facility rate. That is why a rigid "POS 02/10 or nothing" rule would be wrong: it can be correct to bill POS 11 + 95 for a specific plan.
The practical answer is to treat POS 02/10 + 95 as the default, keep POS 11 available as an override, and confirm with the payer for any plan whose policy you have not read. A tool should warn here, not block.
Video and audio-only are different services on paper
A video session with modifier 95 and POS 10 is the mainstream telehealth line. An audio-only session needs its own modifier and, for some payers, its own documentation of why video was not possible. Mixing the two on one line — 95 plus 93 — tells the payer two contradictory things about the same visit.
If your telehealth platform reports the modality automatically, check what it writes into the superbill before the client submits it. The modality field is exactly where a copy-pasted template goes wrong.
Medicare keeps extending behavioral telehealth
Since 2025, Medicare has permanently covered a set of behavioral health services delivered by telehealth, including psychiatric evaluation, psychotherapy, crisis intervention and substance use treatment, with POS 02/10 continuing to be used. The in-person visit requirements attached to those services have been waived through the end of 2027.
Commercial plans set their own policies, and they change. Nothing on this page overrides a payer’s provider manual: confirm with the payer for the specific plan, and keep the confirmation with your records.
A two-minute self-check before you export
Ask four questions about every telehealth line: is the POS 02 or 10 (or a deliberate, documented POS 11 override)? Does the modifier match video versus audio-only? Is exactly one modality modifier on the line? And is the session length inside the CPT time band?
The free pre-check in this tool asks all four and shows the answer per line, in the browser, without uploading the client’s data.
The app only sends your license key and a device id to our license check (which asks Creem) — no patient or practice data ever leaves your browser.
Blocking items disable the PDF. A line that carries 95 together with an audio-only modifier (93 or FQ) comes back as a yellow warning, and payer-specific disagreements are warnings or tips: they stay on the list, nothing is silently dismissed, and it is your call whether the payer actually agrees.
What the free check catches
- CPT vs. session length (90832 = 16–37 min, 90834 = 38–52, 90837 = 53+, nothing under 16)
- Telehealth POS 02 / 10 vs. POS 11, and modifier 95 pairing
- Diagnosis pointers A–D that don’t resolve to a code on the client
- NPI format and check digit, TIN, member ID, units, signatures
- DOS age against the 60 / 90 day timely-filing warnings