Telehealth Billing in 2026: POS 02, POS 10, POS 11 and Modifier 95

The three POS codes and what they mean

POS 02 (telehealth other than patient's home): the patient is at an originating site that is NOT their home. Examples: rural health clinic, Federally Qualified Health Center, skilled nursing facility, hospital outpatient, school-based clinic.

POS 10 (telehealth from patient's home): the patient is at their primary residence. This is the dominant POS for modern outpatient telehealth post-pandemic. CMS made POS 10 permanent in 2022.

POS 11 (office): the provider is in their physical office. POS 11 with modifier 95 is the legacy commercial-payer billing pattern. Some commercial plans still prefer POS 11 over POS 02 or POS 10.

Medicare rules in 2026

Medicare's post-PHE telehealth rules now apply long-term to most services. For non-mental-health telehealth: use POS 10 if the patient is at home, POS 02 if elsewhere, with modifier 95 to indicate audio-video. Reimbursement matches in-person rates for most office E/Ms through 2026.

Mental health telehealth has its own rule: an in-person visit is required every 12 months for the same patient (with limited exceptions). This applies to Medicare; commercial varies.

Audio-only telehealth: Medicare allows audio-only for specific services (some behavioral health, some E/M when audio-video is not feasible) using modifier 93. Most non-mental-health E/M still requires audio-video and modifier 95.

Commercial payer rules

UnitedHealthcare, Aetna, Cigna, and most BCBS plans accept POS 10 with modifier 95 for home-based telehealth in 2026, mirroring Medicare. Some legacy contracts still use POS 11 with modifier 95; verify each payer's current preference.

Reimbursement parity (telehealth equals in-person) is now common but not universal. State law in some states (NY, CA, MA, others) mandates parity for commercial. Check your contracted fee schedule.

Audio-only telehealth on commercial: many plans accept modifier 93 with the appropriate POS, but with reduced reimbursement (often 50 to 70 percent of in-person).

Modifier 95 vs GT vs GQ vs 93

Four telehealth modifiers and their use:

• 95: synchronous audio-video telehealth. The dominant telehealth modifier. Use with POS 02 or POS 10 (Medicare 2022+) or POS 11 (some commercial).
• GT: synchronous audio-video, legacy code. Required by a small number of Medicaid programs and a few commercial plans; obsolete for Medicare. Check payer-specific guidance before billing.
• GQ: asynchronous (store-and-forward) telehealth. Only Medicare in Alaska and Hawaii. Almost never relevant in continental US practice.
• 93: audio-only telehealth. Use when video is not feasible or available, and the service is covered audio-only by the payer.

Common mistakes

Top errors in telehealth billing:

• POS 11 with modifier 95 on Medicare claims for home-based telehealth. Medicare prefers POS 10 in 2026. Submission with POS 11 may still process, but denials are increasing.
• Missing modifier 95 on a telehealth claim. The POS alone does not signal telehealth to all payers; modifier 95 is the explicit telehealth indicator.
• Billing audio-only as audio-video (modifier 95) when no video occurred. This is a billing-fraud risk and a common audit target.
• Forgetting the mental-health 12-month in-person rule for Medicare. After the visit window expires without an in-person visit, telehealth mental health claims can deny.
• Mismatching the originating-site facility fee. Q3014 (originating site facility fee) is billed by the originating-site facility, not the provider. Many primary care offices forget to bill Q3014 when their patient is in a nursing home or other facility for the telehealth visit.

Bottom line

POS 10 (home) plus modifier 95 is the default for 2026 outpatient telehealth on both Medicare and most commercial payers. Use POS 02 when the patient is at a non-home originating site. POS 11 with modifier 95 is legacy commercial. Audio-only uses modifier 93. Mental health has a 12-month in-person rule on Medicare. Verify each payer's specific preference before billing high volume.