What is the difference between POS 02 and POS 10 for telehealth billing?
The main difference between Place of Service (POS) 02 and POS 10 is the physical location of the patient during the telehealth encounter, which directly impacts your reimbursement rate.
💻 📊 POS Code Comparison
| Feature | 🏠 POS 10: Telehealth in Home | 🏥 POS 02: Telehealth Outside Home |
|---|---|---|
| Patient Location | Patient's private residence or home | Anywhere other than home (clinic, office, SNF, hospital) |
| Reimbursement Rate | Non-facility rate (higher, matches in-office rate) | Facility rate (lower, reflects facility overhead) |
| Common Use Case | Routine virtual visit from a patient's couch | Virtual consultation while patient is at a clinic |
📌 Key Details to Know
- Based on the patient, not the provider: Both codes reflect where the patient is sitting, not where the practitioner is located.
- Financial Impact: Billing POS 02 instead of POS 10 for an at-home patient can accidentally lower your claim payout by 10% to 25% because of the facility versus non-facility fee schedule difference.
- Not for facilities: If a patient is in a nursing home, assisted living, or hospital, use POS 02, not POS 10.
What is the correct POS for telehealth?
The correct place of service (POS) code for telehealth is either POS 10 (when the patient is in their home) or POS 02 (when the patient is located anywhere other than their home).
- POS 10 (Telehealth Provided in Patient's Home): Use this when the patient is in their personal residence. It typically reimburses at the higher non-facility rate.
- POS 02 (Telehealth Provided Other than in Patient's Home): Use this when the patient is at a clinic, nursing facility, or another location outside their home. It typically reimburses at the lower facility rate.
Key Billing Details
- Patient Location: The correct code depends entirely on where the patient is physically sitting during the virtual encounter, not where the provider is located.
- Modifiers: Medicare and many other payers may require specific modifiers like 95 (synchronous audio-video) or 93 (audio-only) depending on the service track and payer rules. You can review detailed criteria on the Telehealth HHS Billing Guide.
What are the CMS guidelines for telehealth billing in 2026?
CMS telehealth billing guidelines for 2026 extend key pandemic-era flexibilities through December 31, 2027, under the Consolidated Appropriations Act, 2026.
Place of Service (POS) and Coding
- POS 10: Use for telehealth services provided while the patient is in their home; Medicare reimburses these at the higher non-facility rate.
- POS 02: Use for telehealth services provided when the patient is not in the home (such as an office or clinic); reimbursed at the facility rate.
- Medicare Code Divergence: Medicare denies the AMA’s dedicated telehealth E/M codes 98000–98015, except for brief virtual check-in code 98016. For standard Medicare telehealth visits, report regular in-person office codes (99202–99215) paired with the correct POS code.
Key Flexibilities and Rules
- Geographic and Location Limits: Beneficiaries can receive telehealth from any location nationwide, including their homes, without rural/urban restrictions through 2027.
- Audio-Only Care: Permitted for behavioral health and select services when video is unavailable or unconsented.
- Supervision: Virtual direct supervision via real-time audio-video is permanently allowed for most services (excluding 010 and 090 global surgery periods).
- Platform Compliance: Full enforcement requires HIPAA-compliant platforms; non-compliant consumer tools are no longer permitted under enforcement discretion.
- Originating Site Fee: Facility-hosted originating sites may bill HCPCS code Q3014, set at a maximum standard of $31.85 for 2026.
Are telehealth visits billed differently?
Yes, telehealth visits use the same core procedure codes as in-person visits, but they are billed differently using specific place-of-service codes and modifiers.
Key Differences in Telehealth Billing
- Procedure Codes (CPT): Providers generally use the same standard CPT codes (such as 99213 or 99214 for office visits, or specific therapy codes) for both virtual and face-to-face appointments.
- Place of Service (POS) Codes: Claims must show where the patient and doctor were during the call.
- POS 10: Used when the patient is located in their home.
- POS 02: Used when the patient is at a location other than their home (like an office or secondary site).
- Modifiers: Insurers often require specific add-on codes to indicate how the service was delivered.
- Modifier 95: Used for live, real-time audio-video interactions.
- Modifier 93: Used for interactive audio-only (phone call) visits.
- Reimbursement Rates: Many states have "pay parity" laws requiring insurance companies to pay the same rate for telehealth as in-person visits, though rules vary widely by private commercial payer and specific state guidelines. You can review ongoing policy updates via the Centers for Medicare & Medicaid Services Telehealth FAQ.
Does POS 10 need a modifier?
Yes, Place of Service (POS) code 10 typically requires a telehealth modifier like 95 for real-time audio-video or 93 for audio-only services.
Modifier Requirements for POS 10
- Audio-Video Visits: Attach Modifier 95 to your CPT/HCPCS code to show the encounter happened via live, two-way interactive video and audio.
- Audio-Only Visits: Attach Modifier 93 if the patient only used a phone and video was not available or not consented to.
- Payer Discrepancies: Always check commercial, Medicaid, or Medicare Advantage rules, as some individual payers consider certain modifiers redundant or require specific legacy codes (like GT) depending on your provider type.
Telehealth Place of Service (POS) 02 and 10 for 2024
9 related questions found
What is the difference between telehealth POS 10 and 2?
Place of service (POS) code 02 means the patient is not at home during the telehealth visit, while code 10 means the patient is at home.
Key Differences
- POS 02 (Telehealth Other Than Home): Used when the patient is in a facility, clinic, office, or outside location. This triggers a facility payment rate, which is generally lower because it assumes institutional overhead.
- POS 10 (Telehealth in Home): Used when the patient is in a private residence or temporary lodging like a hotel. This triggers a higher non-facility payment rate (comparable to in-office rates).
Compliance and Billing Tips
- Location Focus: The code is based on where the patient sits, not where the provider is located.
- Reimbursement Impact: Mixing up codes alters your payout and can trigger payer audits or claim denials.
- Official Guidance: You can review further instructions via the CMS Telehealth POS Guidance.
What are the billing codes for telehealth services?
Telehealth services are billed using standard Evaluation and Management (E/M) or specialty CPT codes combined with specific Place of Service (POS) codes and modifiers to denote remote delivery.
Standard Outpatient E/M Codes
For most real-time (synchronous) audio-video visits, providers bill standard office visit codes used for in-person care:
- New Patients: CPT 99202 through 99205
- Established Patients: CPT 99211 through 99215
Place of Service (POS) Codes
You must designate where the patient was located during the remote visit:
- POS 10: Patient's home (non-facility rate)
- POS 02: Telehealth provided other than in the patient's home (facility rate)
Telehealth Modifiers
Modifiers indicate the technology modality used during the session:
- Modifier 95: Synchronous telemedicine service rendered via real-time audio-video
- Modifier 93: Synchronous telemedicine service rendered via audio-only technology
Payer-Specific Rules (Medicare vs. Commercial)
- Medicare Fee-for-Service: Does not use dedicated telehealth CPT codes (98000–98015), requiring standard office codes (99202–99215) alongside POS 02 or 10 and the appropriate modifier. Medicare does reimburse CPT 98016 (brief virtual check-in, 5–10 minutes). More details can be found on the Telehealth.HHS.gov Billing Guide.
- Commercial Payers: Policies vary widely; some accept the dedicated AMA CPT 98000 series (audio-video and audio-only E/M codes), while others follow Medicare's modifier approach. You can review structural breakdowns through the Telehealth CPT Coding Overview.
What is the current CMS ruling on telehealth visits?
The Centers for Medicare & Medicaid Services (CMS) has extended major Medicare telehealth flexibilities through December 31, 2027, allowing beneficiaries to continue receiving services without strict geographic or location limits.
Key Current Flexibilities (Active through December 31, 2027)
- Location Freedom: Patients can receive non-behavioral and behavioral telehealth services directly from their home with no geographic restrictions on the originating site.
- Eligible Providers: All eligible Medicare providers may continue furnishing and billing for distant-site telehealth services.
- Audio-Only Access: Non-behavioral and behavioral services can be delivered using audio-only platforms when video technology is unavailable or not consented to by the patient.
- Facility Extensions: Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can continue serving as distant-site providers.
- In-Person Visit Rules: Waived requirements for an in-person visit within six months of starting mental health telehealth services.
Permanent Policy Highlights
- Behavioral Health: Home-based mental health telehealth, zero geographic restrictions, and audio-only delivery for behavioral care are permanently authorized.
- Provider Locations: Practitioners furnishing telehealth from home do not have to report their residential home address on Medicare enrollment applications if they maintain a separate physical practice location.
What is the modifier for a telehealth visit in 2026?
For 2026, the primary active telehealth modifiers are Modifier 95 for synchronous audio-video services and Modifier 93 for synchronous audio-only services.
You can review official regulatory guidance and updates via the Centers for Medicare & Medicaid Services (CMS) Telehealth FAQ.
Key Telehealth Modifiers in 2026
- Modifier 95: Indicates synchronous telemedicine services rendered via a real-time interactive audio and video telecommunications system. Used predominantly for commercial payers and Medicare Advantage alongside standard E/M codes (99202–99215).
- Modifier 93: Indicates synchronous telehealth services rendered via real-time audio-only communication technology (telephone). Required by Medicare and many other payers for audio-only E/M claims.
- Modifier GT: Considered a legacy/limited modifier. It is generally retired for standard professional claims but remains active for specific institutional claims like Critical Access Hospital Method II.
- Modifier FQ / GQ: Used in specific settings; FQ is used by RHCs/FQHCs or specific payers for audio-only behavioral health, and GQ denotes asynchronous (store-and-forward) telehealth where accepted.
Place of Service (POS) vs. Modifiers
- POS 10: Patient's home (generally yields the higher non-facility rate).
- POS 02: Location other than the patient's home (facility rate).
- Note: For original Medicare fee-for-service, the POS code itself designates the telehealth context, while commercial payers more heavily rely on Modifier 95 or 93.
What are the five basic requirements for telemedicine?
The five basic requirements for legally compliant telemedicine are consent, online prescribing rules, cross-state licensing, licensure compacts, and professional board standards.
Legal and Regulatory Requirements
- Consent: Document that the patient understands and agrees to the risks and benefits of virtual care.
- Online Prescribing: Follow rules for remote prescriptions, which often vary by state or require prior evaluations.
- Cross-State Licensing: Hold a valid medical license in the state where the patient is located.
- Licensure Compacts: Use multi-state agreements to make practicing across state lines easier.
- Professional Board Standards: Meet the rules and ethical codes set by medical boards.
Technical and Setup Essentials
If you also need the basic technical tools to run a visit, you will need:
- A stable high-speed internet connection
- Secure, HIPAA-compliant software or video tools
- Working hardware like a computer, tablet, or smartphone with a camera and microphone
- A private, quiet workspace for the provider
- Proper technical support or system maintenance