Most behavioral health providers had to learn telehealth billing overnight. While the technology became second nature quickly, the rules for getting paid stayed messy.
We see claims denied due to a minor modifier error or rejected because the place-of-service code did not match the payer’s expectations. It is frustrating because these errors have nothing to do with the quality of care you provide. They are simply translation errors between your clinic and the insurance company.
If you offer teletherapy or remote psychiatry, you need to know the specific rules that lead to a check in the mail rather than a denial letter.
The Real Hurdle for Mental Health Providers
Before we look at specific codes, we have to address the biggest challenge. Telehealth billing for mental health involves using a system designed for office visits.
The CPT codes for a 45-minute therapy session are the same whether you are sitting across from the patient or looking at them through a screen. The difference lies in the “tags” you add to that code. These tags (modifiers and place-of-service codes) indicate that the session occurred virtually.
We have found that three things make this complicated:
- Payer Variety: Medicare, Medicaid, and private insurance companies each have their own playbooks.
- Changing Rules: Policies enacted during the health emergency are still evolving. For example, HHS notes that telehealth rules continue to evolve as temporary flexibilities are reviewed for permanent status.
- Hidden Interpretations: Two different insurance companies might see the same code but pay them at different rates.
This is not a problem you can solve once and be done with it. It requires a team that stays on top of these shifts every single month.
Teletherapy Billing Codes You Need to Use
For the most part, we use the same CPT codes for virtual care as we do for in-person visits. The key is how we report them.
Evaluation and Management (E/M)
For prescribers doing remote check-ins, the standard codes apply:
- 99213–99215 (Existing patients)
- 99202–99205 (New patients)
Standard Therapy Codes
Most of our clients rely on these core codes:
- 90791: Initial evaluation
- 90832: 16–37 minutes of therapy
- 90834: 38–52 minutes of therapy
- 90837: 53 or more minutes of therapy
If you want to see how these codes interact, we have a detailed guide on CPT codes 90791 and 90834.
The code itself does not change for telehealth. However, if the claim does not clearly state that the session was remote, the payer might apply the wrong rate or deny it for missing information.
Telehealth Modifiers: Where the Errors Happen
If the CPT code is the foundation, modifiers are the frame of the house. A modifier is a two-letter code that gives the payer more context.
For telehealth, these are the most important:
Modifier 95
We often use this for “synchronous” telehealth. This means a real-time video and audio session. While many commercial payers and Medicare recognize this, it is no longer a “one-size-fits-all” requirement. Some payers have transitioned to using Place of Service codes alone to identify telehealth.
Modifier GT
This was the old standard for video sessions. While Medicare does not use it much anymore, we still see some private payers require it. If your claim is denied for a “missing modifier,” we often find this is the reason.
Modifiers for Audio-Only (93 and FQ)
This is a high-scrutiny area. Modifier 93 is used for synchronous mental health services provided via audio-only technology. For providers in specific settings like Federally Qualified Health Centers (FQHCs) or Rural Health Clinics (RHCs), Modifier FQ is often required to indicate the same.
We only use these when video is not an option, and we verify that the payer allows audio-only for that specific service.
According to CMS telehealth guidance, Medicare has expanded audio-only coverage for mental health, but only under specific circumstances.
Place of Service (POS) Codes
These codes indicate where the patient was during the session. This is a common spot for quiet errors that lead to underpayment.
- POS 10: Telehealth provided in the patient’s home.
- POS 02: Telehealth provided in a location other than the patient’s home.
We pay close attention to these because they affect your bottom line. If we use POS 02 when the patient is actually at home (POS 10), the payer might pay a lower “facility rate.”
This is not a denial; it is a loss of revenue that adds up quickly across hundreds of claims.
The Documentation Rules We Follow
A correct code is useless if your notes do not support it. We recommend that every telehealth note include:
- A statement that the session was held via secure video or audio.
- Where the patient was located at the time.
- A note that the patient gave consent for a virtual session.
- The exact start and stop times.
We see payers recoup money during audits simply because the notes did not prove the session was virtual. We view documentation as the best way to protect the money you have already earned.
Solving Telehealth Billing Puzzles
1. Do we need new codes for virtual sessions?
No, we use the same therapy and evaluation codes. You add a modifier, like 95 (when required), and a place-of-service code, such as 10 or 02, to tell the payer it was remote.
2. Can we bill for a session if the video cuts out?
If the video fails but you finish via phone, you may be able to use an audio-only modifier like 93. However, we always check if the specific payer allows audio-only first. If they don’t, that time may not be billable.
3. Why was our claim paid at a lower rate than usual?
This often happens because of the Place of Service code. If the payer thinks the session happened in a facility, they pay less for overhead. We check to make sure POS 10 is used for home-based sessions to capture the full non-facility rate when allowed.
4. Is Modifier 95 always required?
No. Some payers have moved away from Modifier 95 in favor of Place of Service codes 10 and 02. We maintain a database for each payer to avoid using unnecessary modifiers that could trigger a rejection.
A Smarter Way to Handle Virtual Care
Telehealth billing for mental health does not have to be a source of stress. It is a matter of building a system that accounts for the differences between payers and catches errors before they leave your office.
At Aspen Ridge Billing, we work with behavioral health facilities to ensure their virtual care revenue is steady. We don’t just fix errors; we help you create a workflow that prevents them. If you are seeing too many telehealth denials, we can help you find exactly where the chain is breaking.
The most helpful thing you can do right now is review your last 10 telehealth denials. If you see the same reasons popping up, you have a system problem, not a clinical one.
We are ready to help you clear those hurdles.
Reach out to our team to get your billing back on track.
Disclaimer: The content provided by Aspen Ridge Billing is intended for informational purposes only and does not constitute legal, financial, or medical advice. While we strive to ensure the accuracy and reliability of the information, Aspen Ridge Billing does not guarantee its completeness, timeliness, or applicability. Users should seek direct consultation with qualified professionals for specific concerns.
