The Most Common Telehealth Billing Errors in 2026
Telehealth Billing Errors

The Most Common Telehealth Billing Errors in 2026

What Virtual Care Providers Must Know About POS Codes, Modifiers & Payer Updates

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The Most Common Telehealth Billing Errors in 2026

The 2026 Telehealth Billing Landscape

Telehealth is no longer an emergency workaround; it is a permanent pillar of modern healthcare delivery. By 2026, virtual care spans behavioral health, chronic disease management, cardiology follow-ups, dermatology consultations, and beyond. But as adoption grows, so does billing complexity.
The stakes are high. Some specialties are now facing telehealth claim denial rates as high as 25%, driven almost entirely by avoidable coding mistakes. The errors are rarely about clinical documentation; they stem from incorrect Place of Service (POS) codes, misapplied or missing modifiers, and failure to track rapidly evolving payer-specific rules.
On February 3, 2026, the Consolidated Appropriations Act (CAA 2026) was signed into law, extending most Medicare telehealth flexibilities through December 31, 2027. This includes geographic and originating-site waivers, audio-only coverage for behavioral health, and billing authority for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs).
At the same time, the AMA introduced a dedicated telehealth E/M code series (98000–98016) in 2025. CMS rejected most of these for Medicare reimbursement, creating two parallel billing tracks that practices must navigate simultaneously.

Key 2026 Regulation: The CAA 2026 extended Medicare telehealth flexibilities through December 31, 2027. CMS also requires new billing codes or modifiers by 2027 to identify services delivered via third-party virtual platforms.

The 2026 Telehealth Billing Landscape

Error #1 — Confusing POS 02 and POS 10

Place of Service codes tell the payer where the patient was located during the telehealth encounter. Getting this wrong does not just cause a denial — it changes the reimbursement rate entirely.
POS Code When to Use It Reimbursement Rate Common Mistake
POS 10
Patient connects from their home or temporary residence
Non-facility (higher) rate
Using POS 02 when the patient is actually at home
POS 02
Patient connects from a clinic, office, or skilled nursing facility
Facility (lower) rate
Using POS 10 when the patient is in a clinical setting
The financial impact is real: POS 10 reimbursement under Medicare is calculated at the non-facility rate, which is meaningfully higher than the facility rate applied under POS 02. Pediatric and family medicine practices are among the specialties most commonly cited for POS inconsistencies.

How to Avoid This Error:

  • Always confirm the patient’s physical location at the start of every telehealth encounter.
  • Document the patient’s location explicitly in the visit notes.
  • Build a location-verification step into your intake workflow.

Error #2 — Wrong or Missing Telehealth Modifiers

Telehealth modifiers tell payers how the service was delivered. Incorrect modifier application is one of the top causes of telehealth claim denials in 2026. There is no universal rule; requirements differ by payer, code, and modality.
Modifier Meaning Primary Use Notes
95
Synchronous audio-video service
Medicare & most commercial payers
Required on Medicare E/M codes 99202–99215
GT
Interactive audio-video telecommunication
Medicare Advantage & some commercial
Not used on standard Medicare Fee-for-Service
93
Audio-only telehealth
Medicare (limited services)
Must document why audio-video was not used
FQ
Audio-only behavioral health
Medicare behavioral health services
Used alongside 93 for specific BH services
A critical rule: never assume modifiers apply universally. Commercial payers like Blue Cross Blue Shield and UnitedHealthcare do not always follow the CMS structure. Some require Modifier 95; others prefer GT; some waive modifiers altogether but require specific POS codes. Medicaid rules depend on state guidelines and can vary widely.

Pro Tip: Maintain a payer modifier policy tracker, a simple spreadsheet updated quarterly, listing which modifier each payer requires per service type. This single tool can dramatically reduce your denial rate.

Error #3 — Using Outdated CPT Codes

Several legacy telehealth CPT codes were retired effective January 1, 2026. Practices still billing with these codes are receiving automatic rejections.
Old Code Status in 2026 Replacement Code Applicable Payers
99441–99443
Deleted – invalid
98000–98016 series
Commercial & some Medicaid
G2012
Retired
98016 (brief virtual check-in)
Medicare
98000–98015
NEW, E/M via video
Use for commercial payers
Commercial & some state Medicaid
99202–99215
Active for Medicare
Pair with POS + modifier
Medicare Fee-for-Service
The most dangerous scenario: practices billing Medicare with the new 98000-series codes. CMS declined to reimburse most of these under Medicare, viewing them as duplicative of existing E/M codes with modifiers. For Medicare claims, continue using 99202–99215 with the correct POS and modifier combination.

Error #4 — Ignoring the Medicare vs. Commercial Payer Split

The most significant billing complexity of 2026 is the divergence between what Medicare accepts and what commercial payers require. This two-track system trips up even experienced billing teams.

Payer Type Accepted Code Set Modifier Required POS Code
Medicare Fee-for-Service
99202–99215 (E/M)
95 or 93
POS 02 or POS 10
Medicare Advantage
Varies by plan
Often GT
Per plan policy
Commercial (most)
98000–98016 or 99202–99215
95 or GT (payer-specific)
POS 02 or POS 10
Medicaid
Varies by state
Varies widely
Per state policy
FQHCs / RHCs
G2025 (Medicare)
Per CMS guidance
Distant site

Billing the wrong code set to the wrong payer is one of the fastest ways to trigger a denial. Never assume that what works for Medicare applies to a commercial plan, or vice versa.

Error #5 — Billing Audio-Only Services Incorrectly

Audio-only telehealth is allowed under specific circumstances, but the rules are narrow and frequently misunderstood. Billing audio-only services without meeting documentation requirements is a leading cause of rejections.

When Audio-Only Is Permitted:

  • Behavioral health services: Medicare has permanent coverage for audio-only behavioral health.
  • Situations where the patient lacks access to video technology.
  • Situations where the patient did not consent to video.

Required Documentation for Audio-Only Claims:

  • Clear statement that audio-video was not used.
  • Clinical or technological reason why the video was unavailable or not appropriate.
  • Patient consent documentation per applicable state law.
  • Modifier 93 on the claim, along with Modifier FQ for behavioral health services.

Common Mistake: Billing audio-only visits with Modifier 95 (which indicates audio-video) is a frequent error. Always use Modifier 93 for audio-only encounters and document why video was not used.

Error #6 — Weak or Missing Documentation

Even a perfectly coded claim can be recouped during an audit if the underlying documentation is insufficient. Modifiers and POS codes will not protect a claim if the record does not support the service.
For every telehealth claim in 2026, your documentation must confirm:
  • The date and start/end time of the encounter.
  • The patient’s physical location (home, clinic, nursing facility, etc.).
  • The provider’s location at the time of service.
  • The technology platform used (must be HIPAA-compliant).
  • Patient consent for telehealth as required by state law.
  • Medical necessity, why telehealth was clinically appropriate.
  • Whether the service was audio-video or audio-only, and why.
For services billed under the 98000-series codes with commercial payers, documentation must also clearly indicate the modality (video vs. audio-only), as claims may fail payer review if modality is not specified.

2026 Payer Update Cheat Sheet

Update Effective Date Impact on Billing
CAA 2026 extends Medicare telehealth through Dec 31, 2027
Feb 3, 2026
Geographic and originating-site waivers remain active
98016 replaces G2012 for brief virtual check-ins
Jan 1, 2026
Update code sets; G2012 claims will be denied
99441–99443 retired; replaced by 98000-series
Jan 1, 2026
Commercial payers, update to new codes immediately
New modifier/code required for 3rd-party virtual platforms
By 2027 (CMS mandate)
Begin tracking which visits use external telehealth vendors
Audio-only behavioral health, permanent Medicare coverage
Ongoing 2026
Bill with Modifier 93 + FQ; document patient access barriers

Quick-Reference: Telehealth Billing Checklist

Use this checklist before submitting every telehealth claim:
  • Confirmed patient’s physical location at time of service.
  • Applied correct POS code: POS 10 (home) or POS 02 (non-home facility).
  • Verified whether payer requires Modifier 95, GT, 93, or FQ.
  • Used correct CPT code set for this payer: 99202–99215 (Medicare) or 98000-series (commercial).
  • Documented medical necessity for a telehealth visit.
  • Documented technology platform used and its HIPAA compliance.
  • Documented patient consent per state law.
  • For audio-only: used Modifier 93, documented reason video was not used.
  • Checked payer’s current telehealth policy before submission (not just last quarter’s).
  • Ensured credentialing is active with this payer for telehealth services.
How MaxRemind Helps You Bill Telehealth Right

How MaxRemind Helps You Bill Telehealth Right

Keeping up with telehealth billing changes is a full-time job, and most virtual care practices are already stretched thin. That is where MaxRemind comes in.

MaxRemind‘s AI-powered Rule-Based System (RBS) automatically flags telehealth claims with POS mismatches, missing or incorrect modifiers, and outdated CPT codes before submission. Our billing specialists maintain live payer policy trackers across Medicare, Medicaid, and major commercial plans, so your claims always reflect current requirements.

What You Get With MaxRemind Telehealth Billing:

  • Real-time claim scrubbing with AI-powered error detection.
  • Dedicated telehealth billing specialists trained on 2026 CMS and payer updates.
  • Payer-specific modifier and code set verification before every submission.
  • Denial management and appeals support with a 99% first-pass resolution target.
  • Monthly policy update briefings so your team is never caught off guard.
Ready to Reduce Your Telehealth Denial Rate? MaxRemind offers a free demo and a 1-month free trial with no credit card required. Our team will identify billing gaps in your current telehealth workflow and show you exactly how much revenue you may be leaving on the table.

Reduce Telehealth Claim Denials Before They Happen

MaxRemind helps virtual care providers identify POS mismatches, missing modifiers, outdated CPT codes, and payer-specific billing errors before claims are submitted.
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FAQs
What is the difference between POS 02 and POS 10 for telehealth billing?

POS 10 is used when the patient receives telehealth services from their home or temporary residence and is generally reimbursed at the non-facility rate. POS 02 is used when the patient is located in a healthcare facility, clinic, or other non-home setting during the telehealth visit.

Which telehealth modifier should I use in 2026?

The correct modifier depends on the payer and the type of telehealth service provided. Modifier 95 is commonly used for audio-video telehealth visits, Modifier 93 is used for audio-only services, GT may be required by certain Medicare Advantage and commercial plans, and Modifier FQ applies to specific audio-only behavioral health services.

Are the new 98000–98016 telehealth CPT codes accepted by Medicare?

In most cases, Medicare Fee-for-Service does not reimburse the new 98000–98016 telehealth E/M code series. Medicare providers should generally continue using E/M codes 99202–99215 with the appropriate POS code and telehealth modifier. Commercial payer policies may differ.

Can audio-only telehealth visits still be billed in 2026?

Yes. Medicare continues to allow audio-only billing for certain services, particularly behavioral health. Providers must use the appropriate modifier, document why video was not used, and maintain all required consent and clinical documentation to support the claim.

How can healthcare practices reduce telehealth claim denials?

Practices can reduce denials by verifying patient location, selecting the correct POS code, applying payer-specific modifiers, using current CPT codes, maintaining complete telehealth documentation, and regularly reviewing payer policy updates. Automated claim-scrubbing solutions can also help identify billing errors before submission.

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