Telehealth Modifiers for Behavioral Health Practices: A Plain-Language Guide

Feb 23

A telehealth claim you submitted without errors in 2022 might get denied today. Not because the service changed. Because the rules did.

Behavioral health practices now navigate multiple telehealth modifiers: 95, GT, FQ, 93. Each payer has its own preferences, and those preferences have shifted considerably since telehealth expanded during the pandemic. If you're seeing denials you can't quite explain, the modifier is often where the problem starts.

This guide breaks down which telehealth modifier to use and when, covers the Place of Service code piece that trips up even experienced billers, and explains what actually changed for behavioral health in 2026.

What Is a Telehealth Modifier and Why Does Getting It Wrong Cost You?

A telehealth modifier is a two-character code added to a CPT code that tells the payer how the service was delivered: real-time video, audio-only phone, or another modality. Without the right one, the claim comes back denied.

Two denial codes show up most often in these situations:

CO 4: "Procedure code inconsistent with modifier or provider type." The modifier is present but wrong.
CO 197: "Payment denied due to absence of modifier indicating telehealth." No modifier was included at all.

Both require manual follow-up and rework. That's a time cost that multiplies fast across a busy practice. A group practice in Minneapolis where the EHR doesn't default a telehealth modifier on video session claims can end up with CO 197 denials across 40 or 50 sessions before anyone spots the pattern.[1]

Behavioral health practices are especially exposed because telehealth makes up a significant share of many caseloads. A systemic modifier error doesn't affect one claim. It affects every claim with that configuration until someone flags it and corrects it.

Consistent denial tracking catches these patterns before the dollar amount becomes a serious problem.

Modifier 95 vs. GT: Does Your Payer Even Require One?

This used to be the first question practices asked, and for a while, it was the right one. That's shifted.

Before the pandemic, most payers required a telehealth modifier on every claim. Over the last few years, that's changed significantly. Today, the majority of payers don't require GT or 95 at all. What matters more now is Place of Service.

CMS split the old POS 02 into two distinct codes: POS 02 for telehealth services delivered outside the patient's home, and POS 10 for telehealth provided in the patient's home. Most payers followed suit, and correct POS has become the primary driver of clean telehealth claims.

Some payers still require a modifier, so you can't ignore GT and 95 entirely. You just can't assume they're universally required either. The only safe approach is verifying each payer's current telehealth policy directly.

That's exactly why BreezyBilling maintains a payer-specific telehealth requirements list, and why BreezyNotes automatically appends the correct POS and modifier combination based on the payer's requirements and the client's location. The guesswork gets removed before the claim ever goes out.

Audio-Only Telehealth Has Its Own Modifiers: Modifier 93 and FQ Explained

Not every telehealth session is a video call. Phone-only sessions require different modifiers entirely, and applying modifier 95 to an audio-only session is a coding error that payers can deny or downcode.

Modifier 93 is the CPT modifier for audio-only telehealth. Use it on non-Medicare claims when the entire session occurs by telephone with no video component.

Modifier FQ is Medicare's modifier specifically for audio-only behavioral health telehealth. CMS requires it on phone-only sessions for Medicare patients.

The permanent good news: Medicare now covers audio-only behavioral health telehealth on a permanent basis as of 2026. Phone sessions with Medicare patients are a sustainable billing option, not a temporary accommodation that might expire.

One documentation requirement for FQ claims: note in the session record that the patient was offered video and either declined it or lacked the technology to participate. That documentation protects the claim.

A solo LCSW in rural Minnesota sees several elderly clients by phone who don't have reliable internet access. She had been applying modifier 95 to all of them. After switching to modifier FQ for her Medicare patients and modifier 93 for her Illinois commercial patients, she cleared a backlog of pending claims that had been sitting unresolved for weeks.

Eligibility verification upfront confirms whether a payer covers audio-only telehealth and what modifier they require. That prevents the backlog from forming.

POS 02 vs. POS 10: Why the Place of Service Code Matters for Telehealth Claims

Telehealth modifiers don't work in isolation. They pair with Place of Service (POS) codes, and getting the POS wrong creates its own denial even when the modifier is correct.

POS 02 applies when the patient receives telehealth services from somewhere other than their home: a hospital, clinic, or other care setting.

POS 10 applies when the patient is in their home during the session. This is the correct code for the vast majority of behavioral health video sessions, where clients connect from their living room or bedroom.

The key rule: POS reflects the patient's location, not the provider's. A therapist billing from their office for a client who is at home should use POS 10, not POS 02.

Optum Behavioral Health made POS codes mandatory on all behavioral health telehealth claims starting in late 2023, across commercial, Medicare Advantage, and Medicaid lines of business.[3] Other payers have followed with similar requirements.

A St. Paul therapy practice was using POS 02 on every telehealth claim because the provider was always in the office. Most of their clients connected from home. UnitedHealthcare flagged the POS inconsistency and denied the claims for a reason that looked completely separate from the modifier issue the practice had already corrected.

Two different denial types from the same underlying setup problem. That's how telehealth billing gets away from a practice quietly, one session at a time.

The 2026 Telehealth Update: What's Now Permanent for Behavioral Health

Behavioral health practices came out ahead in the 2026 telehealth policy changes compared to most other specialties. A few things are worth knowing because they affect how you build and maintain your billing setup going forward.

Under Medicare, these are now permanent for behavioral health:[4]

No geographic restrictions on where the patient is located
Patients can receive behavioral health telehealth services in their home
Audio-only sessions are covered when the patient can't or won't use video

Extended through December 31, 2026 with potential for renewal: broader behavioral health telehealth access that expanded during the pandemic. Congress has renewed these provisions multiple times, and behavioral health services have consistently received more favorable treatment than other specialties.

What this means practically: the PHE-era coding workarounds are behind you. You can build a stable, repeatable telehealth billing workflow rather than adjusting it every few months as extension deadlines approached.

One caveat worth repeating. Medicare rules don't automatically apply to state Medicaid programs or commercial payers. Each sets its own telehealth policies. Confirm requirements per plan, especially for Medicaid in Minnesota and Illinois.

A Twin Cities group practice that had been re-verifying telehealth eligibility before every billing cycle, bracing for another policy change, finally has a stable Medicare behavioral health workflow to build on. Their account coordinator flagged the permanent change in early 2026. They found out from a conversation, not a denial.

Final Thoughts

Telehealth billing isn't complicated because any single rule is hard. It's complicated because every payer has its own version of the rules, and those rules have been shifting for years.

Keeping all of that current across every payer a practice works with is exactly the kind of ongoing work that pulls a practice owner away from clinical care. It's also the kind of work a dedicated billing team handles as a matter of course.

If your practice is seeing telehealth denials you can't fully explain, there's usually a telehealth modifier or POS code at the root of it. BreezyBilling is here to help.

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