Telehealth billing for rural clinics in 2026: what actually gets paid
The post-PHE rules are still in flux and small practices are leaving money on the table. A practical walk-through of which codes work, which patients qualify, and what documentation holds up to audit.
Frequently asked questions
Is audio-only telehealth still covered by Medicare in 2026?
Yes. Audio-only telehealth is covered by Medicare through December 31, 2026 when the patient cannot use or declines video. Mental-health and substance-use telehealth (including audio-only, with home as the originating site) is permanently covered under the 2023 CAA carve-out. Claims must include modifier 93 and, for most E/M services, POS 10 when the patient is at home.
What is the difference between POS 02 and POS 10 for telehealth?
POS 02 means the patient was NOT in their home during the encounter (for example, at a clinic or facility). POS 10, introduced in 2022, means the patient WAS in their home. POS 10 pays at the higher non-facility (office) rate, while POS 02 pays at the lower facility rate. Many EHRs still default to POS 02 from pre-2022 setup, so rural clinics routinely lose the office-rate uplift on home-based telehealth visits.
Which modifier do I use on a telehealth claim — 95 or 93?
Use modifier 95 for synchronous audio-video telehealth. Use modifier 93 for audio-only telehealth (including behavioral-health audio-only encounters). Missing modifier 93 on an audio-only claim is one of the most common denial reasons — payers interpret no modifier as a billing error and either deny the claim outright (CO-16) or reprocess at a reduced rate.
Can a Rural Health Clinic (RHC) or FQHC bill telehealth under the all-inclusive rate?
Yes. When an RHC or FQHC provider renders a telehealth service, the clinic bills HCPCS G2025 at the all-inclusive rate (AIR). RHCs and FQHCs can also bill G0071 (virtual communication services), G2010 (remote evaluation of patient-submitted images/video), and G2012 (5-10 minute virtual check-in) separately from the AIR. Most RHCs bill zero G2012 even though clinical staff routinely perform the work — the code is simply not enabled in the billing system.
What are the top denial reasons for rural-clinic telehealth claims?
The top three reason codes, per AMA 2024 benchmarks, are CO-16 (missing information — usually missing modifier 95/93 or missing POS 10), CO-170 (performed service not consistent with provider type — a credentialing gap for that payer), and CO-45 (charge exceeds fee schedule — usually a POS code mismatch). Small-practice telehealth denial rates run 12–18%, roughly double the in-person E/M denial rate. These denials are largely appealable with a payer-specific letter keyed to the reason code and CPT.
Is behavioral-health telehealth permanently covered for Medicare?
Yes. Behavioral-health telehealth (mental-health and substance-use encounters) is permanently covered by Medicare with the patient's home as an originating site, and audio-only is included. This was carved out by the Consolidated Appropriations Act of 2023 and has held through every subsequent legislative cycle. Psychotherapy codes (90832, 90834, 90837) and Collaborative Care Model codes (99492, 99493, 99494, G0323) are all billable via telehealth.
Does my state Medicaid program cover telehealth the same way Medicare does?
No — state Medicaid telehealth policy is a patchwork. Most states now pay parity (same rate as in-person) for telehealth E/M through 2026–2027, but audio-only coverage varies widely and many states require a state-specific modifier beyond Medicare's 95/93 (Virginia uses GT for some MCOs; Pennsylvania has a state-specific consent form). Managed Care Organizations (MCOs) often have tighter rules than fee-for-service Medicaid in the same state. Always check your state Medicaid manual and each MCO's provider guide before assuming.
What documentation does Medicare require for a telehealth encounter?
CMS requires: (1) that the encounter was telehealth with modality specified (audio-video vs audio-only); (2) the originating site (patient location) and distant site (provider location); (3) for audio-only, a reason why video was not used (patient preference, lack of access, technical failure); (4) clinical documentation equivalent to what an in-person visit at the same code would require (HPI, ROS where relevant, MDM elements, plan); and (5) informed consent for telehealth, documented once per patient per calendar year.
How much unbilled telehealth revenue is a typical 3-provider RHC leaving on the table?
For a 3-provider RHC running disciplined telehealth billing, typical previously-unbilled or under-billed revenue is $4,000–$8,000 per month. The biggest contributors are: unbilled G2012 virtual check-ins ($10K–$15K annually), mis-coded POS 02 on home-based telehealth (losing the office-rate uplift on every claim), and untapped Collaborative Care Model billing when the practice has any behavioral-health integration.