Medicare Telehealth Extended Through 2027: Behavioral Health Billing Updates

Legislative Background: How We Got Here

Before the COVID-19 public health emergency (PHE), Medicare telehealth was restricted to patients located in rural Health Professional Shortage Areas (HPSAs), required the patient to be at a designated originating site (a healthcare facility, not their home), and covered a limited list of eligible services. The pandemic triggered emergency waivers that eliminated these restrictions, and behavioral health telehealth utilization increased by over 3,000% between 2019 and 2021 according to CMS data.

As the PHE waivers expired, Congress acted repeatedly to preserve telehealth access:

• Consolidated Appropriations Act, 2023: Extended most telehealth flexibilities through December 31, 2024.
• Consolidated Appropriations Act, 2024: Extended again through March 31, 2025.
• Consolidated Appropriations Act, 2025: Extended most flexibilities through March 31, 2027, and made audio-only behavioral health telehealth permanent.

The pattern of serial extensions reflects strong bipartisan Congressional support for telehealth but ongoing debate about whether to make all flexibilities permanent or to maintain some restrictions. For behavioral health specifically, the permanent authorization of audio-only coverage represents a significant legislative commitment that signals long-term policy support for telehealth-delivered behavioral health services.

What the Extension Covers for Behavioral Health: A Detailed Breakdown

Geographic Restriction Removal (Behavioral Health)

The pre-pandemic Medicare requirement that telehealth patients be located in a rural HPSA has been permanently eliminated for behavioral health services. This means:

• Patients in urban, suburban, and rural areas can all receive behavioral health telehealth services under Medicare
• Providers do not need to verify the patient's geographic location for behavioral health visits (they do still need to verify the state, for licensure purposes)
• This permanent change is not subject to the March 2027 extension deadline

Originating Site Flexibility (Behavioral Health)

The pre-pandemic requirement that Medicare telehealth patients be at a designated originating site (a hospital, physician office, rural health clinic, or other approved facility) has been eliminated for behavioral health. Patients can receive behavioral health telehealth from their home or any location. This is foundational to the viability of telehealth as a sustained delivery model because requiring patients to travel to a healthcare facility to receive a telehealth visit negated most of the access benefits.

Audio-Only Coverage (Permanent for Behavioral Health)

This is the single most important element for practices serving populations with limited technology access. Audio-only (telephone) behavioral health visits are now a permanent Medicare benefit. This is not subject to the March 2027 expiration. Key parameters:

• Modifier 93 must be appended to the CPT code to indicate audio-only delivery
• Eligible audio-only behavioral health CPT codes include 90834 (individual therapy, 45 min), 90837 (individual therapy, 60 min), 90847 (family therapy with patient), 99213 (E/M established patient, low complexity), and 99214 (E/M established patient, moderate complexity)
• Audio-only visits are reimbursed at the same rate as in-person visits for these codes
• The provider must have the capability to furnish the service via video and must have offered the patient the option of a video visit. If the patient chooses audio-only or cannot access video, audio-only is permitted
• The patient must consent to the audio-only modality, and this consent must be documented in the medical record

In-Person Visit Requirement Waiver (Through March 2027)

CMS established a requirement that patients receiving behavioral health telehealth services must have an in-person visit with the rendering provider within the 6 months preceding the telehealth visit. This requirement was intended to ensure an established patient-provider relationship. The Consolidated Appropriations Act waives this in-person requirement through March 31, 2027. After that date, if the waiver is not extended, providers will need to see behavioral health telehealth patients in person at least once every 6 months, which would affect scheduling, capacity planning, and the viability of purely telehealth-based behavioral health service models.

Billing Codes, Modifiers, and Place-of-Service Rules

Correct billing for Medicare telehealth requires the right combination of CPT code, place-of-service code, and modifier. Errors in any of these three elements result in claim denials, incorrect reimbursement, or compliance risk. The following table summarizes the key billing parameters for behavioral health telehealth:

Element	Video Telehealth	Audio-Only Telehealth
Place of Service (patient at home)	POS 10 (Telehealth Provided in Patient's Home)	POS 11 (Office) — use the POS where the service would have been furnished in person
Place of Service (patient at originating site)	POS 02 (Telehealth Provided Other than in Patient's Home)	POS of the originating site (e.g., POS 11 for office, POS 22 for hospital outpatient)
Primary modifier	Modifier 95 (synchronous telehealth)	Modifier 93 (audio-only)
Reimbursement rate	Same as in-person (no reduction)	Same as in-person (no reduction)
Key BH-eligible CPT codes	90834, 90837, 90847, 90832, 90846, 99213, 99214, 99215, 90791, 90792	90834, 90837, 90847, 99213, 99214

Modifier Details

• Modifier 95 (Synchronous Telehealth Service): Used for real-time interactive audio-video telecommunications. This is the standard Medicare telehealth modifier and replaces the older modifier GT that some payers still use. When billing Medicare, always use modifier 95 for video visits.
• Modifier 93 (Audio-Only Telehealth): Used exclusively for audio-only (telephone) visits. This modifier signals to the payer that the service was delivered via telephone without video capability. Do not use modifier 95 and modifier 93 on the same claim line. Audio-only and video are mutually exclusive modalities.
• Modifier placement: When the CPT code requires additional modifiers (such as therapy modifiers or multiple-procedure modifiers), place the telehealth modifier (95 or 93) in the first modifier position on the claim line.

Place-of-Service Code Guidance

POS code errors are the most common Medicare telehealth billing mistake. The rules are straightforward but must be applied consistently:

• POS 10 (Telehealth Provided in Patient's Home): Use when the patient is at their home and the visit is conducted via real-time video. This is the most common POS for behavioral health telehealth because the elimination of originating site requirements means most behavioral health patients receive telehealth from home.
• POS 02 (Telehealth Provided Other than in Patient's Home): Use when the patient is at a healthcare facility or other non-home location and the visit is via video. This applies when a patient is physically present at a satellite clinic, hospital outpatient department, or community mental health center while the provider delivers care remotely.
• POS 11 (Office) for audio-only: For audio-only visits, CMS instructs providers to use the POS code for the setting where the service would have been furnished in person. For most office-based behavioral health providers, this is POS 11.

Documentation Requirements for Medicare Behavioral Health Telehealth

Medicare telehealth visits require the same clinical documentation as in-person visits, plus additional telehealth-specific documentation elements. Audits of telehealth claims have increased significantly since 2023, and documentation deficiencies are the primary audit finding:

• Modality statement: Every telehealth note must document whether the visit was conducted via real-time video or audio-only. A simple statement such as "This visit was conducted via synchronous audio-video telehealth" or "This visit was conducted via audio-only telephone" satisfies this requirement.
• Patient location: Document the state where the patient is physically located at the time of the visit. This is required for licensure verification and POS code accuracy. Example: "Patient located in their home in Phoenix, Arizona."
• Consent for telehealth: Document that the patient consented to receive services via telehealth. For audio-only visits, document that video was offered but the patient chose or could only access audio. Consent can be verbal and documented in the record; a separate written consent form is not required by Medicare (though some state laws may require it).
• Technology and connectivity: Note the technology platform used. If there were connectivity issues that affected the session (dropped video, degraded audio quality), document them and note how the session was adapted (e.g., switched from video to audio-only).
• Clinical content: The clinical documentation standards are identical to in-person visits. For time-based codes like 90834 and 90837, document the total session time and that it meets the minimum time threshold for the billed code. For E/M codes billed based on medical decision-making, document the complexity elements. There is no reduced documentation standard for telehealth.

What Your Billing Team Needs to Do

The following action items ensure correct Medicare telehealth billing and position your practice to maximize the revenue opportunity during the extension period:

1. Verify modifier usage across all telehealth claims. Pull a sample of telehealth claims from the last 90 days and verify that video visits use modifier 95 (not GT or other legacy modifiers) and audio-only visits use modifier 93. If your billing system is appending incorrect modifiers, update the configuration immediately. Incorrect modifiers are the fastest path to preventable telehealth denials.
2. Audit POS codes for accuracy. Verify that your practice management system assigns POS 10 when the patient is at home and POS 02 when the patient is at a facility. For audio-only visits, confirm POS 11 (or the appropriate non-facility POS) is being used. Many practice management systems default to a single POS for all telehealth, which creates billing errors when the patient location varies. If your EHR has configurable visit-type templates, set up distinct templates for video-at-home, video-at-facility, and audio-only that automatically apply the correct POS and modifier.
3. Train clinicians on audio-only documentation requirements. Audio-only visits require documenting that video was offered and the patient chose or could only access audio. Many clinicians omit this element. Create a documentation template or note macro that includes the required telehealth attestation fields. Behavioral health EHR platforms like AZZLY Rize and Ease that support configurable note templates can embed these fields directly into the telehealth visit workflow, ensuring clinicians capture the required elements without additional effort.
4. Model telehealth capacity expansion. With payment parity and no geographic restrictions, telehealth represents an opportunity to expand capacity without proportional facility costs. Calculate your current telehealth utilization rate (telehealth visits as a percentage of total visits), model the revenue impact of increasing that rate by 10 to 20 percentage points, and identify the operational changes needed (scheduling template adjustments, provider licensing in additional states, technology upgrades) to achieve the target.
5. Build a telehealth compliance calendar. Track the key expiration and review dates: the March 31, 2027 extension deadline, any state-specific telehealth rule changes (state rules may be more or less restrictive than Medicare), and your practice's internal telehealth policy review dates. Set alerts 6 months before the March 2027 deadline to reassess your telehealth model based on Congressional action or inaction.
6. Review state telehealth rules for non-Medicare patients. Medicare telehealth rules apply only to Medicare beneficiaries. Medicaid, commercial payers, and self-pay patients are governed by state telehealth laws that vary significantly. Cross-reference your state's current telehealth billing rules against Medicare parameters. Our state-by-state behavioral health guides cover state-specific telehealth billing requirements in detail.
7. Prepare for the in-person visit requirement. If the in-person visit requirement waiver is not extended past March 2027, you will need to see every behavioral health telehealth patient in person at least once every 6 months. Assess how many of your current telehealth patients have not been seen in person recently and develop a plan to bring them in before the waiver expiration.

Revenue and Financial Impact

The financial impact of the Medicare telehealth extension for behavioral health practices operates through capacity expansion, cost structure optimization, and patient access improvements:

Capacity Expansion Without Proportional Facility Costs

A provider conducting 25 in-person visits per week requires a dedicated office, waiting room space, and associated facility overhead. The same provider can conduct 25 telehealth visits from any location with no incremental facility cost. For a behavioral health practice with 5 providers, shifting 30% of visits to telehealth (from an average of 125 weekly visits to a 87 in-person / 38 telehealth split) reduces the physical office footprint requirement by approximately one treatment room, yielding $18,000 to $36,000 in annual facility cost savings depending on market. If that freed-up room is used to add a sixth provider for in-person visits, the practice gains both the cost savings and the additional provider's revenue, which at 20 visits per week and an average reimbursement of $120 per visit represents $124,800 in incremental annual revenue.

Reduced No-Show Rates

Behavioral health practices consistently report lower no-show rates for telehealth visits compared to in-person visits. Industry data shows an average behavioral health no-show rate of 18% to 25% for in-person visits versus 8% to 14% for telehealth. For a practice with 500 scheduled visits per month and an average per-visit reimbursement of $130, reducing the effective no-show rate by 8 percentage points through telehealth adoption yields approximately $62,400 in annual recovered revenue from visits that would otherwise have been lost to no-shows.

Geographic Market Expansion

The elimination of geographic restrictions for behavioral health telehealth allows practices to serve Medicare patients anywhere within the states where their providers are licensed, rather than being limited to the commuting radius around their physical office. For practices in competitive urban markets, this provides access to underserved suburban and rural populations. For practices in areas with declining Medicare populations, this provides geographic diversification of revenue. The incremental revenue from geographic expansion depends entirely on demand and provider licensing, but practices that have actively marketed telehealth availability to new geographies report 10% to 20% patient volume growth within the first year.

Audio-Only as an Access and Revenue Tool

The permanent authorization of audio-only behavioral health telehealth creates a durable revenue stream from patient populations that may not have reliable internet access, video-capable devices, or the technical literacy to participate in video visits. For practices serving older adults on Medicare, populations in digital-divide communities, or patients with disabilities that make video participation difficult, audio-only visits maintain treatment engagement and revenue continuity that would otherwise be lost. At payment parity with in-person and video visits, every audio-only visit represents revenue that was previously inaccessible for these patient populations.

EHR and Technology Implications

Maximizing the telehealth revenue opportunity requires EHR and practice management capabilities that support telehealth-specific workflows end to end:

• Integrated video platform or seamless third-party integration: Your EHR should either include a built-in telehealth video platform or integrate seamlessly with platforms like Zoom for Healthcare, Doxy.me, or Microsoft Teams. The integration must allow session launch from within the patient record, automatic session logging, and documentation linkage. Behavioral health EHR platforms including AZZLY Rize and Ease offer integrated or tightly coupled telehealth capabilities that reduce the technology friction of conducting and documenting telehealth visits.
• Configurable visit-type templates with automatic POS and modifier assignment: Set up distinct visit types in your EHR for video telehealth, audio-only telehealth, and in-person visits. Each visit type should automatically populate the correct POS code and modifier on the claim, eliminating manual entry errors. This is the single most effective control for preventing telehealth billing errors.
• Telehealth consent and attestation tracking: Your EHR should capture and track telehealth consent at the patient level, including the initial consent for telehealth, the specific modality consent for audio-only, and the documentation that video was offered. This information must be accessible for audit response.
• State licensure tracking: If your practice serves patients across multiple states via telehealth, your EHR should track which providers are licensed in which states and flag scheduling conflicts where a patient's location state does not match the provider's licensure states.
• Telehealth utilization reporting: Build reports that track telehealth versus in-person visit mix, audio-only versus video split, no-show rates by modality, and revenue per visit by modality. These reports are essential for modeling telehealth capacity expansion and measuring the financial performance of your telehealth program.

Frequently Asked Questions

Is audio-only telehealth for behavioral health permanently covered by Medicare?

Yes. The Consolidated Appropriations Act made audio-only telehealth coverage for behavioral health services a permanent Medicare benefit. This is not subject to the March 2027 expiration that applies to most other telehealth flexibilities. Audio-only visits must be billed with modifier 93 appended to the CPT code. Eligible codes include 90834, 90837, 90847, 99213, and 99214. Reimbursement is at the same rate as in-person visits.

What is the correct place of service code for Medicare telehealth visits?

For video visits with the patient at home, use POS 10 (Telehealth Provided in Patient's Home). If the patient is at an originating site like a clinic, use POS 02. For audio-only visits, use the POS where the service would have been provided in person, typically POS 11 (Office). POS code errors are the most common Medicare telehealth billing mistake and frequently result in claim denials or incorrect reimbursement. Configure your EHR visit-type templates to assign POS codes automatically.

Are there geographic restrictions for Medicare behavioral health telehealth?

No. The pre-pandemic restriction limiting Medicare telehealth to patients in rural Health Professional Shortage Areas has been permanently eliminated for behavioral health services. Patients in any geographic area, urban or rural, can receive behavioral health telehealth under Medicare. This applies to both video and audio-only visits. The geographic waiver for non-behavioral-health telehealth is extended through March 2027.

Is Medicare telehealth reimbursed at the same rate as in-person visits for behavioral health?

Yes. Medicare reimburses behavioral health telehealth, including both video and audio-only modalities, at the same rate as equivalent in-person visits. There is no telehealth-specific payment reduction for behavioral health services. This payment parity applies to individual therapy (90834, 90837), family therapy (90847), and E/M visits (99213, 99214), among other eligible codes.

What happens to Medicare telehealth flexibilities after March 2027?

If Congress does not act before the March 31, 2027 expiration, several changes would occur for non-behavioral-health telehealth: geographic restrictions would return, originating site requirements would be reinstated, and certain provider types would lose telehealth eligibility. For behavioral health, the in-person visit requirement (currently waived) would take effect, requiring an in-person visit within the preceding 6 months. However, audio-only behavioral health coverage is permanent and would not be affected. Congressional action before the deadline is widely expected.

Do I need to use modifier 95 or modifier GT for Medicare telehealth claims?

For Medicare, use modifier 95 for synchronous video telehealth visits. Modifier GT was the older convention and has been superseded by modifier 95 for Medicare billing. For audio-only visits, use modifier 93 (not modifier 95). Some commercial payers may still require modifier GT, so check each payer's requirements. When multiple modifiers are needed on a claim line, place the telehealth modifier (95 or 93) in the first modifier position.

Editorial Standards

Last reviewed: February 26, 2026

Methodology

• Medicare telehealth billing codes, modifier requirements, and POS rules verified against CMS Medicare Learning Network publications and the CY 2026 Medicare Physician Fee Schedule final rule
• Legislative history and extension provisions validated against the full text of the Consolidated Appropriations Act and related Congressional committee reports
• Reimbursement parity and payment rate information confirmed through CMS Physician Fee Schedule Lookup Tool and Medicare Administrative Contractor guidance
• No-show rate and telehealth utilization statistics sourced from published behavioral health practice data and APA practice survey results

Primary Sources

• CMS Medicare Telehealth Services
• Medicare Learning Network: Telehealth Services
• CMS Telehealth Eligible Services List
• American Psychological Association: Telehealth Guidance
• Congress.gov: Consolidated Appropriations Act