Telehealth Modifier Guide 2026: 95, 93, GT, FQ and Place of Service Codes
Telehealth modifiers tell payers how a visit was delivered — synchronous audio/video, audio-only, or via a specific telehealth program — and are required on every telehealth claim alongside the correct Place of Service (POS) code. In 2026, the four telehealth modifiers physicians encounter are modifier 95 (synchronous audio/video, current standard), modifier GT (legacy audio/video, CMS considers obsolete since 2024), modifier 93 (audio-only with documented clinical/technical reason), and modifier FQ (audio-only for FQHCs/RHCs and specific programs). Choosing the wrong modifier or Place of Service code is one of the most common sources of E/M coding denials in telehealth — and every denial is preventable with a clear decision framework.
This guide covers every telehealth modifier in use today, the two Place of Service codes that determine your reimbursement rate, payer-specific requirements for Medicare, commercial payers, and Medicaid, and a decision tree that answers “which modifier do I use?” in 30 seconds. The same MDM-based E/M coding rules apply to telehealth and in-person visits — modifiers and POS codes are the only billing differences.
Modifier 95: Synchronous Audio/Video Telehealth (Current Standard)
Modifier 95 means “Synchronous Telemedicine Service Rendered Via Real-Time Interactive Audio and Video Telecommunications System.” It is the current standard telehealth modifier accepted by Medicare and the majority of commercial payers. Append modifier 95 to the same E/M CPT code you would use for an in-person visit — for example, 99214-95 indicates a Moderate complexity established patient visit delivered via real-time audio and video.
| Attribute | Detail |
|---|---|
| Full Name | Synchronous Telemedicine Service Rendered Via Real-Time Interactive Audio and Video Telecommunications System |
| Technology Required | Two-way, real-time audio AND video (Zoom, Doxy.me, built-in EHR video, etc.) |
| Medicare Accepted | Yes — the preferred modifier since 2017 |
| Commercial Payers | Accepted by the vast majority; some legacy systems may still require GT |
| New Patients | Allowed for both new (99202–99205) and established (99212–99215) patients |
| Common POS | POS 10 (patient at home) or POS 02 (patient at facility) |
Documentation requirements for modifier 95: The medical record must indicate the visit was conducted via real-time interactive audio and video, name the technology platform, confirm both audio and video were functional throughout the encounter, and note the patient’s location (home, office, clinic, etc.). Annual patient consent for telehealth must be documented (for Medicare, consent is valid for the calendar year once obtained).
Modifier GT: Legacy Audio/Video Telehealth
Modifier GT means “Via Interactive Audio and Video Telecommunications Systems.” It was the original CMS telehealth modifier before modifier 95 was introduced.CMS considers modifier GT obsolete for Medicare claims as of 2024 and instructs providers to use modifier 95 instead. However, modifier GT has not been formally retired from the CPT modifier list, and some payers still require it.
When You May Still Need Modifier GT
- Some state Medicaid programs have not updated to modifier 95
- Legacy commercial payer systems that reject modifier 95
- Specific managed care contracts that explicitly require GT
Best practice: Default to modifier 95. If a claim is rejected with modifier 95, resubmit with modifier GT before pursuing a formal appeal.
The clinical and technology requirements for modifier GT are identical to modifier 95 — real-time, synchronous audio and video. The difference is purely administrative: which modifier code the payer’s claims system recognizes. Never use both modifier 95 and modifier GT on the same claim line — they are functionally equivalent and using both will trigger a duplicate modifier denial.
Modifier 93: Audio-Only Telehealth
Modifier 93 means “Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System.” It is used when a visit is conducted by phone (audio only) without video. Medicare permits audio-only E/M services but imposes stricter requirements than audio/video visits.
| Requirement | Detail |
|---|---|
| Patient Eligibility | Established patients only (Medicare). Exception: behavioral health new patients with documented clinical reason. |
| Documented Reason Required | The medical record must state WHY video was not used. Valid reasons: patient lacks video technology, disability prevents video use, insufficient broadband, clinical reason (e.g., severe anxiety triggered by video). |
| E/M Codes Allowed | 99212–99215 with modifier 93, or telephone E/M codes 99441–99443 |
| MDM Rules | Same MDM framework as in-person and audio/video telehealth |
| Common POS | POS 10 (patient at home) in most cases |
Critical documentation requirement: Every audio-only encounter must include a statement explaining why the visit was not conducted via audio/video. Acceptable documentation examples: “Patient does not have a smartphone or video-capable device; visit conducted via landline telephone” or “Patient reports no internet access at current location; audio-only visit medically appropriate for medication management follow-up.” Without this documented reason, the claim is vulnerable to denial on audit.
Modifier FQ: Audio-Only for FQHCs, RHCs, and Specific Programs
Modifier FQ means “Telehealth Service Furnished Using Audio-Only Communication Technology.” It was created by CMS specifically for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) that bill under the all-inclusive rate methodology and need to differentiate audio-only telehealth from audio/video telehealth for payment calculation purposes.
For standard physician practices billing fee-for-service Medicare, modifier 93 is the correct choice for audio-only visits, not modifier FQ. However, some Medicare Advantage plans and state Medicaid programs have adopted modifier FQ more broadly. If you are unsure whether to use modifier 93 or FQ, check with the specific payer — and default to modifier 93 for standard Medicare Part B claims.
Place of Service Codes: POS 10 vs. POS 02
The Place of Service (POS) code determines the reimbursement rate for the telehealth encounter. This is where significant revenue is at stake — the wrong POS code can reduce payment by $15 to $50+ per visit.
| POS Code | Name | Patient Location | Payment Rate | 99214 Example* |
|---|---|---|---|---|
| POS 10 | Telehealth Provided in Patient’s Home | Personal residence | Non-facility (office) rate | ~$167 |
| POS 02 | Telehealth Provided Other than in Patient’s Home | Healthcare facility, clinic, hospital, nursing home | Facility rate | ~$120 |
*Approximate 2024 National Medicare Physician Fee Schedule rates for established patient office visit 99214.
The reimbursement difference exists because the non-facility (office) rate includes built-in compensation for practice overhead (staff, equipment, supplies, rent) that the physician’s practice bears. When the patient is at a healthcare facility (POS 02), CMS assumes the facility absorbs those costs, so the physician’s payment is reduced.For the vast majority of telehealth visits in 2026, the patient is at home, and POS 10 is correct.
Revenue Impact: POS 10 vs. POS 02
Using POS 02 instead of POS 10 when the patient is at home costs approximately $30–$50 per visit in lost reimbursement depending on the E/M code level. For a practice conducting 15 telehealth visits per day, the wrong POS code costs $450–$750 per day or $117,000–$195,000 per year. Always verify and document the patient’s location at the start of every telehealth encounter.
Common POS Mistakes
- Using POS 11 (Office) for telehealth: POS 11 indicates an in-person office visit. Using it with a telehealth modifier creates a POS/modifier mismatch that can trigger denials.
- Defaulting to POS 02 for all telehealth: Many EHR systems default to POS 02 for telehealth encounters. If the patient is at home, manually change to POS 10 before submitting the claim.
- Not documenting patient location: Without explicit documentation of the patient’s location, auditors may question the POS code. One sentence is sufficient: “Patient joining from home residence.”
Decision Tree: Which Telehealth Modifier Do I Use?
Follow this decision framework to select the correct modifier for any telehealth encounter:
| Step | Question | Action |
|---|---|---|
| 1 | Was the visit conducted with real-time audio AND video? | Yes → Go to Step 2. No → Go to Step 4. |
| 2 | Is the payer Medicare or a commercial plan that accepts modifier 95? | Yes → Use modifier 95. No → Go to Step 3. |
| 3 | Does the payer (typically state Medicaid or legacy commercial) require modifier GT? | Use modifier GT. If unsure, try 95 first; resubmit with GT if rejected. |
| 4 | Was the visit audio-only (no video)? | Yes → Go to Step 5. No → Not a telehealth visit; do not append a telehealth modifier. |
| 5 | Is the patient established (or a behavioral health new patient)? | Yes → Go to Step 6. No → Audio-only not permitted for this patient under Medicare. Must use audio/video or in-person. |
| 6 | Is there a documented clinical or technical reason that video was not feasible? | Yes → Go to Step 7. No → Document the reason before billing. Audio-only claims without a stated reason are denied on audit. |
| 7 | Is your practice an FQHC or RHC billing under all-inclusive rate? | Yes → Use modifier FQ. No → Use modifier 93. |
After selecting the modifier, determine the POS code: if the patient is at home, use POS 10. If the patient is at a healthcare facility, use POS 02. Never use POS 11 (office) with a telehealth modifier.
Payer-Specific Requirements
Medicare (Parts A and B)
- Use modifier 95 for audio/video visits (modifier GT is obsolete for Medicare)
- Use modifier 93 for audio-only visits with documented reason
- Audio-only limited to established patients (behavioral health exception for new patients)
- Annual consent documentation required (valid for the calendar year)
- POS 10 for patient at home, POS 02 for patient at facility
- Originating site requirement eliminated for most services through 2026 legislative extensions
- Not all CPT codes are telehealth-eligible — check the CMS Telehealth List quarterly
Medicare Advantage
- Generally follows Medicare Part B rules but may have plan-specific variations
- Some MA plans accept modifier FQ instead of modifier 93 for audio-only
- Some MA plans have more generous audio-only policies (new patients, broader CPT list)
- Always verify with the specific MA plan — coverage varies significantly
Commercial Payers (Aetna, UHC, BCBS, Cigna, etc.)
- Most accept modifier 95 as of 2026
- Audio-only coverage varies — some commercial payers do not cover audio-only E/M at all
- Some payers require modifier GT instead of 95 (becoming rare but still exists)
- Consent requirements vary: some require written consent, some accept verbal
- POS code rules generally follow Medicare (POS 10 for home, POS 02 for facility)
- Reimbursement parity laws vary by state — some states require telehealth to pay the same as in-person
Medicaid (State-Specific)
- Rules vary dramatically by state — always check your state Medicaid manual
- Some states still require modifier GT and do not accept modifier 95
- Audio-only coverage expanded during the PHE; some states have made it permanent, others have rolled back
- Some state Medicaid programs use modifier FQ broadly (not just FQHCs/RHCs)
- POS code requirements may differ from Medicare
- Reimbursement rates and parity rules are state-specific
Audio-Only Eligibility Rules
Audio-only telehealth (modifier 93) has the strictest requirements of any telehealth modality. Failure to meet these requirements is a leading cause of telehealth audit findings and recoupment demands.
| Requirement | Medicare Rule | Documentation |
|---|---|---|
| Established patient | Required (exception: BH new patients) | Prior encounter in medical record |
| Reason video not used | Required for every audio-only visit | “Patient reports no video-capable device” or similar statement |
| Consent | Annual consent for telehealth + acknowledgment of audio-only | “Patient consented to audio-only visit” |
| Visit type | Must be on CMS audio-only eligible list | E/M codes 99212–99215, 99441–99443, BH codes |
| In-person follow-up | Some payers require periodic in-person visits | Check payer policy; document when last in-person visit occurred |
Common Denial Reasons and How to Prevent Them
| Denial Reason | Root Cause | Prevention |
|---|---|---|
| Missing telehealth modifier | E/M code submitted without any modifier (95, 93, GT, or FQ) | Build telehealth modifier into EHR encounter template; auto-append based on visit type |
| Wrong modifier for payer | Using 95 when payer requires GT, or vice versa | Maintain payer-modifier crosswalk; default to 95, resubmit GT on rejection |
| POS/modifier mismatch | POS 11 (office) with telehealth modifier, or POS 02 when patient was at home | Link POS selection to visit-type workflow; always verify patient location |
| Audio-only without documented reason | Modifier 93 claim with no explanation of why video was not used | Add mandatory “reason for audio-only” field to telehealth encounter template |
| Audio-only for new patient | Modifier 93 on a new patient visit (Medicare restricts to established) | Check patient status before scheduling audio-only; offer video or in-person for new patients |
| Non-telehealth-eligible CPT code | Telehealth modifier on a code not on payer’s telehealth-eligible list | Reference CMS Telehealth List and payer-specific lists quarterly; train schedulers |
| Missing consent documentation | No telehealth consent documented in the medical record | Annual consent workflow at first telehealth visit of year; auto-reminder in scheduling |
Reimbursement Impact: Getting Modifiers and POS Right
The financial impact of correct telehealth modifier and POS code selection is significant. Here is the approximate reimbursement difference for established patient visits under 2024 National Medicare rates:
| E/M Code | MDM Level | POS 10 (Home) | POS 02 (Facility) | Difference |
|---|---|---|---|---|
| 99212-95 | Straightforward | $67 | $49 | $18 |
| 99213-95 | Low | $111 | $80 | $31 |
| 99214-95 | Moderate | $167 | $120 | $47 |
| 99215-95 | High | $224 | $163 | $61 |
The POS 10 vs. POS 02 difference alone ranges from $18 to $61 per visit. For a practice averaging 99214-level telehealth visits (the most common E/M code), using POS 02 when POS 10 applies costs $47 per visit — or $12,220 per year per provider at just one telehealth visit per day. With the typical telehealth-heavy practice conducting 8–12 telehealth visits daily, the annual revenue impact of incorrect POS coding is $97,000–$146,000 per provider.
Consent Documentation Requirements
Telehealth consent is not optional and is a frequent audit finding. Requirements differ by payer type:
Medicare Telehealth Consent
- Verbal or written consent is acceptable
- Must be obtained before the first telehealth service of the calendar year
- Valid for the remainder of the calendar year once obtained (annual renewal)
- Must be documented in the medical record
- Must include: patient agrees to telehealth, patient informed of right to in-person visit, date consent obtained
- For audio-only: additional acknowledgment that the visit will be audio-only and why
Commercial Payer Consent
- Requirements vary by payer — some require written (signed) consent
- Some require consent at every visit, not just annually
- State telehealth laws may impose additional consent requirements
- Best practice: have a standard telehealth consent form signed at intake and renewed annually
Telehealth E/M Coding: Same MDM, Different Modifier
The most important thing to remember about telehealth coding is that the E/M code level selection process is identical to in-person visits. You still apply the same Medical Decision Making framework: Number and Complexity of Problems (Element 1), Amount and Complexity of Data (Element 2), and Risk of Complications (Element 3). Two of three elements must meet the level for the encounter to qualify.
Time-based coding also applies to telehealth identically — total time on the date of the encounter includes pre-visit review, the synchronous encounter, and post-visit documentation and orders. The only differences are:
- Append the appropriate telehealth modifier (95, 93, GT, or FQ) to the E/M code
- Use POS 10 or POS 02 instead of POS 11
- Document the telehealth modality, technology platform, and patient location
- Maintain telehealth consent documentation
- For audio-only (modifier 93): document reason video was not used
Tools like CodeItRight.ai analyze telehealth notes using the same MDM engine as in-person visits and flag the correct modifier based on the documented modality. The AI detects whether the note describes an audio/video or audio-only encounter and recommends the appropriate modifier alongside the E/M code level.
Frequently Asked Questions
What is the difference between telehealth modifier 95 and modifier GT?
Modifier 95 and modifier GT both indicate a service was delivered via synchronous audio/video telehealth, but they come from different eras. Modifier 95 (Synchronous Telemedicine Service Rendered Via Real-Time Interactive Audio and Video Telecommunications System) is the current standard adopted by CMS and most commercial payers since 2017. Modifier GT (Via Interactive Audio and Video Telecommunications Systems) is the legacy CMS modifier that was the standard before modifier 95 was introduced. As of 2024, CMS considers modifier GT obsolete for Medicare claims and instructs providers to use modifier 95 instead. However, some state Medicaid programs still require modifier GT, and a handful of commercial payers have not updated their systems. The safest approach is to use modifier 95 for Medicare and most commercial claims, and check your state Medicaid manual if billing Medicaid. If a claim with modifier 95 is rejected by a specific payer, try resubmitting with modifier GT before appealing.
When should I use modifier 93 for audio-only telehealth?
Modifier 93 (Synchronous Telemedicine Service Rendered Via Telephone or Other Real-Time Interactive Audio-Only Telecommunications System) is used when the telehealth visit is conducted via audio-only technology — meaning a phone call without video. Medicare allows audio-only E/M services (99441-99443 for telephone E/M, or standard office visit codes 99212-99215 with modifier 93) only when there is a documented clinical or technical reason that video was not feasible. Valid reasons include: the patient lacks video-capable technology, the patient has a disability that prevents video use, the patient is in a location without sufficient broadband, or there is a clinical reason video is not appropriate (e.g., behavioral health patient with severe anxiety triggered by video). The patient must generally be an established patient — Medicare does not allow audio-only E/M for new patients except in behavioral health. The clinical or technical reason must be documented in the medical record for every audio-only encounter.
What is modifier FQ and when is it required?
Modifier FQ (Telehealth Service Furnished Using Audio-Only Communication Technology) was introduced by CMS for specific program-level tracking of audio-only telehealth services. It is primarily used in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) that bill under the all-inclusive rate methodology and need to distinguish audio-only telehealth from audio/video telehealth for payment purposes. For most physician practices billing standard fee-for-service Medicare, modifier 93 is the correct modifier for audio-only services rather than modifier FQ. However, some Medicare Advantage plans and state Medicaid programs have adopted modifier FQ for broader use. Check your specific payer requirements — if you are an FQHC or RHC, modifier FQ is likely required for audio-only claims. If you are a standard physician practice, use modifier 93 unless the payer specifically requests FQ.
Should I use Place of Service 10 or Place of Service 02 for telehealth?
The choice between POS 10 and POS 02 depends on where the patient is located during the telehealth encounter, not where the provider is. POS 10 (Telehealth Provided in Patient's Home) is used when the patient is at their personal residence during the visit. POS 10 reimburses at the non-facility (office) rate, which is higher because it accounts for the practice's overhead costs. POS 02 (Telehealth Provided Other than in Patient's Home) is used when the patient is at a healthcare facility, clinic, hospital, or other non-home location during the telehealth visit. POS 02 reimburses at the facility rate, which is lower. For most telehealth encounters in 2026, POS 10 is correct because patients are typically connecting from home. The reimbursement difference between POS 10 and POS 02 ranges from $15 to $50+ per visit depending on the E/M code level — using POS 02 when POS 10 applies directly reduces your payment. Always verify the patient's location at the start of every telehealth visit and document it.
What are the most common telehealth modifier denial reasons?
The five most common telehealth modifier denials are: (1) Missing modifier — submitting a telehealth E/M code without any telehealth modifier, causing the claim to process as an in-person visit and potentially deny for missing documentation of the in-person encounter. (2) Wrong modifier for payer — using modifier 95 for a state Medicaid program that still requires modifier GT, or vice versa. (3) Audio-only without documented reason — using modifier 93 without documenting why video was not feasible, which Medicare requires for every audio-only visit. (4) Wrong Place of Service — using POS 11 (office) instead of POS 10 or POS 02, or using POS 02 when the patient was at home, triggering a mismatch between the telehealth modifier and the place of service code. (5) Non-covered telehealth service — appending a telehealth modifier to a CPT code that the payer does not recognize as telehealth-eligible, such as certain procedures that require physical examination. Prevention requires knowing each payer's specific modifier and POS requirements and verifying telehealth eligibility for the CPT code being billed.
Do I need patient consent documentation for telehealth visits?
Yes. Medicare requires documented patient consent for telehealth services, and most commercial payers follow suit. For Medicare: the provider must obtain verbal or written consent from the patient before the telehealth visit, document the consent in the medical record, and the consent is valid for the remainder of the calendar year once obtained (annual renewal). The documentation must include: the patient agreed to receive the service via telehealth, the patient was informed of their right to an in-person visit, and the date consent was obtained. For commercial payers, consent requirements vary — some require written consent (signed form), some accept verbal consent documented in the note, and some require consent at every visit rather than annually. For audio-only visits under modifier 93, additional consent documentation may be required explaining that the visit will be audio-only and why video is not being used. Best practice: obtain and document consent at the first telehealth visit of each calendar year, note it in the chart, and have a standard consent form in your patient intake process.
How do telehealth modifiers affect E/M code level selection?
Telehealth modifiers do not change how you select the E/M code level — the same Medical Decision Making (MDM) or time-based rules apply whether the visit is in-person or via telehealth. You still assess the Number and Complexity of Problems (Element 1), Amount and Complexity of Data (Element 2), and Risk of Complications (Element 3) using the same CMS MDM framework. The modifier (95, 93, GT, or FQ) is appended to the same E/M CPT code you would use for an in-person visit — for example, 99214-95 indicates a Moderate complexity established patient visit delivered via audio/video telehealth. What does change is the reimbursement rate based on Place of Service: POS 10 (home) pays the non-facility rate (same as office), while POS 02 (facility) pays the lower facility rate. Time-based coding works the same way for telehealth — total time includes all activities on the date of the encounter (pre-visit review, the synchronous encounter, and post-visit documentation and orders). The key documentation addition for telehealth is noting the modality (audio/video or audio-only), the technology platform used, and the patient's location.
Can I bill telehealth E/M codes for new patients?
Yes, you can bill telehealth E/M codes for new patients using audio/video technology (modifier 95). Medicare and most commercial payers allow new patient visits (99202-99205) via synchronous audio/video telehealth with no restrictions beyond the standard requirements of a telehealth modifier and appropriate Place of Service code. However, audio-only telehealth (modifier 93) is generally restricted to established patients under Medicare rules. Medicare does make an exception for behavioral health services — audio-only visits for new patients are permitted when the visit is for diagnosis or treatment of a mental health disorder and there is a documented clinical reason that audio-only is appropriate. Some commercial payers are more permissive and allow audio-only new patient visits broadly, while others follow Medicare's restriction. For Medicaid, rules vary significantly by state — some states allowed audio-only new patient visits during the PHE flexibilities and have since continued them, while others have reverted to established-patient-only for audio. Always verify the specific payer policy for new patient audio-only eligibility before billing.
Get Telehealth Modifiers Right Every Time
Telehealth modifier selection is straightforward once you know the decision tree: audio/video = modifier 95 (or GT for legacy payers), audio-only = modifier 93 (or FQ for FQHCs/RHCs), and always POS 10 when the patient is at home. The same MDM rules determine the code level whether the visit is in-person or telehealth — modifiers and POS codes are the only billing differences.
Continue building your telehealth coding knowledge: read our deep dive on telehealth E/M coding rules for 2026, explore the CodeItRight for telehealth providers page, or review the foundational guides on E/M coding and the 2026 E/M code levels chart. Or paste any telehealth note into CodeItRight.ai and get modifier recommendations, MDM leveling, and dual-code results in 30 seconds.