Key takeaways
- Medicare wants POS 10 when the client is at home and POS 02 when they're somewhere else. Commercial and Medicaid plans vary: some want those codes, others want POS 11 with modifier 95.
- For mental health, Medicare permanently allows telehealth to the client's home anywhere in the U.S., and audio-only is allowed.
- Medicare's in-person visit rule for home mental health telehealth doesn't take effect until after December 31, 2027. New modifiers BB and BC are required from January 1, 2027.
Place of service: 02, 10, or 11
The place of service (POS) code tells the insurer where the client was during the session. For telehealth there are two:
| POS | Meaning | When to use it |
|---|---|---|
| 10 | Telehealth provided in the client's home | The client joined from a private residence. This is most therapy telehealth. |
| 02 | Telehealth provided other than in the client's home | The client joined from somewhere else, such as a school, workplace, or a clinic acting as the originating site. |
| 11 | Office | In-person sessions. Some commercial plans want POS 11 on telehealth claims too, with modifier 95 to mark the visit as virtual. |
Medicare uses POS 02 and POS 10, and since January 1, 2024 it pays telehealth to a patient's home (POS 10) at the higher non-facility rate, the same as an office visit. Commercial and Medicaid plans don't all follow Medicare. Some match it, some want the POS where the session would have happened in person (usually 11) plus a modifier, and a few still use older conventions. The plan's provider manual or telehealth policy is where to check, and it's worth re-checking each January.
Modifiers: 95, GT, 93, and the new BB and BC
- 95: synchronous telehealth by real-time audio and video. Many commercial and Medicaid plans require it on every telehealth line, especially when they want POS 11.
- GT: an older telehealth modifier. A few plans still ask for it; most have moved to 95.
- 93: the service was delivered audio-only (by phone). Medicare and many other plans use it to tell phone sessions apart from video.
- BB and BC: new Medicare modifiers, required starting January 1, 2027. BB marks a telehealth service delivered through a virtual platform owned by an entity the clinician contracts with or pays for its use. BC marks a telehealth service furnished “incident to” another practitioner's service. CMS says they don't change payment, but claims that need them should carry them from January 1.
Modifiers go on each service line, not on the claim as a whole. If a visit has two lines, such as a med check and a therapy add-on, both lines need the telehealth modifier when the plan requires one.
Medicare: home, location, and audio-only
Medicare's telehealth rules are different for mental health than for everything else. Since the Consolidated Appropriations Act, 2021, there are no geographic or place-of-service restrictions on behavioral health telehealth. A Medicare client in a city or a rural area can see you from home, and two-way audio-only is allowed.
The broader flexibilities that let any Medicare patient get telehealth anywhere, for any covered service, run through December 31, 2027. From January 1, 2028, most non-behavioral telehealth goes back to requiring a rural medical facility. Mental health telehealth keeps its exemption.
From January 1, 2028, audio-only mental health sessions to a client at home are allowed when you're able to use video and the client can't, or doesn't consent to, use video. Note the reason in the record.
Medicare's in-person visit requirement
Federal law requires an in-person, non-telehealth visit within six months before a client's first mental health telehealth session at home, followed by an in-person visit within 12 months of each telehealth session, with limited exceptions. Congress has delayed this repeatedly. Per CMS's FAQ, it applies after December 31, 2027.
CMS has also said that clients who began receiving mental health telehealth at home before January 1, 2028 are treated as established. They won't need the six-month visit, but will need at least one in-person visit every 12 months after December 31, 2027. The in-person visit can be done by another clinician of the same specialty in your group if you aren't available.
If you run a virtual-only practice with Medicare clients, plan for how you'll meet the annual visit before 2028: a local partner, occasional in-person days, or a colleague in your group.
Where you are matters too
Medicare lets clinicians provide telehealth from home. If you have a physical office, you can bill from that office's address without reporting your home address. If your home is your only practice location, it must be enrolled as a practice location; you can mark it “Home office for administrative/telehealth use only” to keep the street address off Medicare's public Care Compare site.
Licensure follows the client, not you: you generally need to be licensed in the state where the client is during the session. Commercial plans also apply state telehealth laws, which differ on whether telehealth must be paid at the same rate as in-person care.
A telehealth claim checklist
- The note says the session was telehealth, whether it was video or audio-only, where the client was, and that they consented.
- The POS matches where the client was (10 at home, 02 elsewhere), or the plan's own rule if it wants 11.
- Every line carries the modifier the plan requires: 95, 93 for audio-only, and from 2027, BB or BC when they apply on Medicare claims.
- You're licensed in the client's state, and credentialed with the plan for telehealth if it requires that separately.
Where Remitra fits
Remitra sets the place of service from where each session happened (your office, the client's home, or elsewhere) and lets you add modifiers line by line, so a two-line med visit gets the modifier on both lines. It doesn't guess each insurer's telehealth policy for you. You decide which modifier each plan wants, or our billing team does if you choose the Billing option. See how Remitra handles telehealth practices.
Sources
- CMS: Telehealth FAQ (updated October 8, 2026)
- CMS: Telehealth and remote patient monitoring
- CMS: Place of Service code set
- CMS MLN booklet: Medicare & Mental Health Coverage (MLN1986542, March 2026)
This article is general information, not legal, coding, or reimbursement advice. Payer rules change and vary by plan and state, so check each payer's current policy. CPT® is a registered trademark of the American Medical Association.