Industry TrendsUpdated 3 min read
Medicare telehealth billing rules for 2026 and 2027
Medicare telehealth rules are extended, not permanent, for most services. Learn what CMS says, how place of service works, and what to record for each commercial payer.
Written by the billing team at Medical Billing Services for Small Practices
Telehealth billing depends on who pays. This guide summarizes Medicare, using CMS's Telehealth FAQ updated February 26, 2026, which was still the newest FAQ on CMS's telehealth page when we checked on September 25, 2026.[1] Commercial payers write their own rules, so the last section covers how to track them.
Medicare flexibilities run through 2027
CMS says beneficiaries can receive Medicare telehealth services anywhere in the United States and territories through December 31, 2027. Starting January 1, 2028, except for behavioral health services, beneficiaries will generally need to be in a medical facility in a rural area.[1] APA Services reported in February 2026 that the extended coverage policies, including the delay of the in-person visit requirement, are set to expire after December 31, 2027.[3]
| Period | Most Medicare telehealth services | Behavioral health |
|---|---|---|
| Through December 31, 2027 | Can be received anywhere in the US and territories[1] | No geographic or place-of-service restriction, permanent since the Consolidated Appropriations Act, 2021. Audio-only is permitted.[1] |
| From January 1, 2028 | Generally in a medical facility in a rural area[1] | Home still allowed. For mental health services, the in-person visit requirement applies after December 31, 2027, and audio-only use is limited to patients who cannot or will not use video.[1] |
CMS's calendar year 2027 Physician Fee Schedule proposed rule (CMS-1848-P, published July 16, 2026) comes with a file titled "CY 2027 PFS Proposed Rule List of Telehealth Services." Its comment period closed on September 14, 2026.[4] This article covers the rules in CMS's February 2026 FAQ, so the final rule is the next thing to check.
Place of service codes
CMS tells practitioners to use POS 02 for telehealth provided other than in the patient's home and POS 10 for telehealth provided in the patient's home. Since January 1, 2024, Medicare pays telehealth services delivered to patients at home at the non-facility rate.[1]
Modifiers depend on the payer
CMS's December 2025 telehealth booklet describes professional billing through POS 02 and POS 10. It ties modifier GT to critical access hospital Method II institutional claims and modifier 95 to outpatient therapy furnished by hospital-employed therapists.[2] It does not say whether professional claims need 95 or GT, so confirm each payer's rule instead of assuming either way.
Commercial payers: keep a rule sheet
Commercial plans write their own telehealth policies, so do not assume Medicare's rules carry over. For each payer, record:
- Which telehealth codes are covered
- The place of service and modifier requirements
- Whether audio-only visits are covered
- How telehealth is paid compared with an in-person visit
- Prior authorization rules
- The policy's effective date and where you found it
Update the sheet whenever a payer publishes a change. Our medical billing and coding services include keeping that kind of payer detail current.
A quarterly checklist
- Confirm the place of service on every Medicare telehealth claim: POS 02 or POS 10.
- Refresh your payer rule sheet from each payer's latest published policy.
- Check CMS's telehealth page for a newer FAQ than the one dated February 26, 2026.
- Put December 31, 2027 on your calendar, and plan for the January 1, 2028 changes, including the in-person visit requirement for mental health.
Related guides
For code-level detail on psychotherapy visits, read our guide to psychotherapy billing time rules, and see our mental health billing page.
Sources
- Telehealth FAQ, updated February 26, 2026, Centers for Medicare & Medicaid Services
- Telehealth & Remote Monitoring (MLN901705), CMS Medicare Learning Network, December 2025
- APA Services facilitates continued coverage of behavioral health services furnished via telehealth for Medicare beneficiaries, APA Services, February 9, 2026
- CY 2027 Payment Policies under the Medicare Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies (CMS-1848-P), Centers for Medicare & Medicaid Services, proposed rule published July 16, 2026
This article is general information for practice staff, not legal, coding or compliance advice. Payer rules and Medicare policy change, so confirm current requirements with each payer before you bill.
