Key Takeaways
- When voice and video telehealth happen at the same time, the CPT modifier is 95. It works for codes on the AMA CPT Appendix P or the payer’s own list of allowed codes.
- Type 95 goes with POS 02 or POS 10 on Medicare professional claims. People in POS 10 (at home) pay the non-facility rate, while people in POS 02 (somewhere else) pay the facility rate.
- The modifier GT is no longer valid for professional telehealth claims made by Medicare. For Critical Access Hospital Method II institutional claims, you must do it again.
- CMS does not pay for CPT codes 98000-98015, which are the new telemedicine E/M series. In 2025 and 2026, CMS refused to add them to the Medicare Telehealth Services List because the Physician Fee Schedule does not cover them separately when provided in person. The short virtual check-in code, CPT 98016, is now used instead of G2012.
- The Consolidated Appropriations Act, 2026, signed on February 3, 2026, added more Medicare telehealth options until December 31, 2027. These options include the patient’s home as the starting point for the call and coverage for audio-only calls.
- Modifier 93 handles synchronous services that only send audio. You can’t use it instead of marker 95.
On a claim, modifier 95 indicates a synchronous audio-video telehealth service. It works with POS 02 or POS 10 to tell Medicare the visit was video. According to the Medicare Claims Processing Manual, POS alone certifies that the service meets the telehealth requirements on a professional claim. However, most practices still add modifier 95. Modifier GT used to do the same thing, but in 2018 Medicare removed it from professional claims and now uses it only on Critical Access Hospital Method II institutional claims. Many Medicaid programs and commercial payers still need marker 95 for standard E/M codes that are paid through the audio-video.
What Is Modifier 95?
It is a CPT modifier that means “Synchronous Telemedicine Service Rendered via a Real-Time Interactive Audio and Video Telecommunications System.” The AMA created it to show that telehealth visits are different from phone-only or store-and-forward services because they use live, two-way audio and video.
There is no change in payment for the adjustment itself. It says what kind of delivery is being used. Payment is based on the claim’s place-of-service code, not on whether marker 95 is present or not.
Modifier 95 only works with CPT codes that are in the AMA CPT Appendix P. This list includes codes that can be used for synchronous telemedicine. Payers may keep their own list of eligible codes, and some are stricter than Appendix P. Before adding modifier 95 to a code, make sure that the specific CPT code is on the list of eligible codes for that payer, not just Appendix P.
For Medicare, the Medicare Telehealth Services List is the same thing. The CMS updates it every year as part of the process of making rules for the Physician Fee Schedule. The final rule for the CY 2026 physician fee schedule added four services to that list: group psychotherapy for multiple families, group behavioral counseling for obesity, an add-on code for infectious diseases, and services for hearing devices implanted in the bone.
Modifier 95 vs GT: What Is the Difference?
The HCPCS Level II modifier GT is used. Its description says, “Via Interactive Audio and Video Telecommunication Systems.” In simple terms, GT and 95 refer to the same technology, which is why Medicare switched between them.
Because modifier 95 is a CPT modifier, it is in the AMA code set. Editor GT is an HCPCS editor that is run by CMS. As of January 1, 2018, CMS changed the rules for billing telehealth services for professional claims. GT was taken out of professional Medicare claims and replaced with a mix of telehealth POS codes (originally POS 02, later adding POS 10) and marker 95. CMS made the removal official for professional claims on October 1, 2018, through Transmittal R4026CP. This told contractors to turn down any service line with modifier GT, except for CAH Method II institutional claims with revenue codes 96X, 97X, or 98X.
GT can’t go away completely because institutional claims, as the UB-04 form hospitals use, don’t have a place-of-service line. The POS method can’t be used to mark a service as telehealth on an institutional claim without a POS field. This is why Critical Access Hospital Method II institutional claims were given to GT.
The hospital then bills the practitioner using the telehealth HCPCS code with GT on the institutional claim, and the A/B MAC handles it. Keep in mind that starting January 1, 2026, CAH Method II claims will be rejected if the attending and rendering sources have not been transferred to the CAH’s 855A billing PTAN.
| Feature | Modifier 95 | Modifier GT |
| Code set | CPT (AMA) | HCPCS Level II (CMS) |
| Technology | Synchronous audio-video | Interactive audio-video |
| Medicare professional claims | Valid (with POS 02 or 10) | Rejected since October 2018 |
| Medicare CAH Method II institutional claims | Not used | Required |
| Commercial payers | Widely required | Some plans still require it |
| Medicaid | Varies by state | Some state programs still require it |
The correct modifier to use is 95 when you bill a professional claim (CMS-1500) for a Medicare patient seen via audio-video telehealth. Medicare will reject that professional claim at the line level if you add GT to it by accident. The right modifier for that channel is still GT if the CAH your doctor has given billing to is sending an institutional claim under Method II.
It’s more complicated for business providers and many state Medicaid programs. Some large commercial plans and state Medicaid programs still haven’t fully switched to the POS-plus-95 model. These programs still expect GT on audio-video claims.
When Medicare Requires Modifier 95 in 2026
Medicare’s telehealth billing structure for 2026 uses place-of-service codes to identify telehealth claims. Modifier 95 is added to these codes to confirm that audio and video are delivered at the same time. On a CMS-1500, the order is: POS 02 or POS 10 on the claim, plus modifier 95 on the service line.
There are subtleties here that are worth figuring out. Part 12 of the Medicare Claims Processing Manual says the POS code shows the service meets the standards for telehealth on a professional claim. In this case, POS 10 or POS 02 by themselves, without modifier 95, technically meet Medicare’s billing needs for video telehealth. In real life, most billers and businesses still add modifier 95 to POS 02 and POS 10, and most MACs handle both properly.
When modifier 95 is needed along with POS on a professional claim, these situations apply:
In acute hospital care at home programs, services are provided to patients who are receiving inpatient care at home. When the telemedicine part of the care is paid on a professional claim, marker 95 must be used to identify it.
Therapists who work in hospitals and file institutional claim types (which don’t have a POS field) need to add modifier 95 to the service line to indicate that the delivery was audiovisual telehealth.
All OTP claims for services delivered via synchronous audio-video use POS 58, and modifier 95 marks those lines as having an audio-video telehealth component.
When billing telehealth critical care consultations with G0508 or G0509, add modifier 95 with POS 02 or POS 10. The CY 2026 Physician Fee Schedule removed the frequent caps for these codes for good.
Until December 31, 2027, Medicare telehealth flexibilities will remain in effect. These include coverage for patients at home, eliminating the requirement for a rural geographic originating site, and audio-only coverage for certain service types. Section 6209 of the Consolidated Appropriations Act, 2026, which was signed on February 3, 2026, made this continuation law.
POS 02 vs POS 10 and Payment
The second point (POS 02) covers telehealth services when the patient is not at home, such as at a clinic, school, workplace, or community site. POS 10 talks about remote services where the patient stays at home during the visit. As of January 1, 2024, POS 10 replaced POS 11 with modifier 95 as the standard home telehealth code. This change came about because of COVID.
This difference matters for financial reasons because POS, not the modification, determines how much Medicare pays for claims.
There is a higher non-facility rate that POS 10 pays because it believes that the provider’s office or the patient’s home, which is the same thing, pays the costs. The facility rate is lower for POS 02 because it is thought that a facility will cover its own overhead costs. This structure was kept in the CY 2026 Physician Fee Schedule, with POS 10 being reimbursed at the non-facility PFS rate.
For example, a 99214 (old patient, moderate complexity) billed with POS 10 for a patient videoconferencing from home is paid at the non-facility rate. People who join from a treatment site pay the lower facility rate for the same 99214 billed with POS02. The non-facility rate for 99214 in 2026 is about $148.63, while the facility rate is about $110.56. This is a difference of about $38 per claim. That difference grows over a year for a full group of telehealth patients.
One error that still appears in audits: practices using POS 11 (office) with modifier 95, a work arrangement that was acceptable during the COVID public health emergency. With the end of the COVID flexibilities, POS 11 is no longer valid for Medicare telehealth claims. Based on where the patient is at the time of the visit, the right numbers are POS 02 or POS 10.
POS rules differ for commercial payers. The POS 02/10 framework from Medicare is used by some plans. Others use POS 02 or POS 11, or require a different POS for each service type.
Modifier 95 vs 93: Audio-Only Services and FQ
Modifier 93 marks synchronous audio-only telehealth services, which are phone visits that don’t include video. You can’t use it instead of modifier 95. Use 95 if the visit was both voice and video. Use 93 if the visit was just audio.
For Medicare in 2026, audio-only telehealth coverage rules are as follows:
Behavioral health visits, like therapy for mental illness or care for a drug use problem, are covered by audio-only if the patient can’t or doesn’t want to use audio-video technology. The patient’s inability or refusal must be documented in the chart.
Some non-behavioral health telehealth services can be provided over the phone with audio only when the patient is at home (POS 10), and there is proof that audio-video services were unavailable or declined.
For Medicare claims that only include audio, modifier 93 shows up on the service line next to POS 10 or POS 02, depending on where the patient is located. The level of proof needed is higher than for audio-video claims; the note has to explain exactly why audio-only was used.
The FQ modifier is used by Rural Health Clinics and Federally Qualified Health Centers instead of the 93 modifier on their own claim types to describe audio-only services. FQ and 93 refer to the same method of delivery, but they use different billing channels.
RHCs and FQHCs can use the CY 2026 Physician Fee Schedule to bill G2025 through December 31, 2026 for audio-only non-behavioral telehealth. For the non-behavioral population, the 2026 rule did not extend G2025 past that date.
Modifier FR shows services where a supervising practitioner was present through two-way audio-video technology. This can meet the needs for virtual direct supervision in some clinical settings. Modifier FR does not allow audio-only.
All Telehealth Modifiers at a Glance
| Modifier | Technology | Who Uses It | Medicare Status in 2026 |
| 95 | Synchronous audio-video | Professional claims, Medicare, and commercial | Valid with POS 02 or 10 on professional claims |
| 93 | Synchronous audio-only | Professional claims, Medicare and commercial | Required for audio-only encounters |
| FQ | Audio-only | RHCs and FQHCs | Used in place of 93 for RHC/FQHC claims |
| FR | Virtual supervision (two-way audio-video only) | Supervising practitioners | Required for virtual direct supervision; audio-only excluded |
| GT | Interactive audio-video | CAH Method II institutional claims only | Required on CAH Method II; rejected on professional claims |
| GQ | Asynchronous store-and-forward | Federal demonstrations (Alaska and Hawaii only) | Limited to specific federal programs |
| G0 | Acute stroke telehealth | Telestroke distant-site services | Active for acute stroke claims |
Commercial and Medicaid Payer Rules
This is where modifier 95 and GT rules get really tricky, since private payers and state Medicaid programs don’t all follow the same rules. Medicare and Aetna have different requirements. Also, Medicaid rules can differ from one state to another, even between nearby states.
Medicare pays only for CPT 98016 (short virtual check-in, which replaces G2012), part of the new CPT 98000-98016 telemedicine E/M code series. In both 2025 and 2026, CMS refused to add CPT 98000-98015 to the Medicare Telehealth Services List. They said these codes are not separately payable under the Physician Fee Schedule when provided in person, which is required to be eligible for the telehealth list. Because telehealth is built into the code descriptor itself, CPT 98016 doesn’t need modifier 95. For the same reason, payers that accept the broader 98000-98015 series don’t need an extra qualifier.
Before billing any commercial or Medicaid plan for telehealth services, work through these five questions:
- For audio-video telehealth, does this payer need the modifier 95, GT, or none?
- Which POS code does this payer want: 02, 10, 11, or the in-person POS code for the service location?
- Does this payer have a list of CPT codes that can be used for telehealth?
- Does this payer cover audio-only? If so, do they need marker 93 or FQ? Does this payer need proof that video wasn’t available?
- Do I need to get permission ahead of time for this type of visit or for this patient’s plan?
Over the past few years, payer policies on telehealth have changed more often than almost any other type of billing rule. A rule that made sense in 2024 might not be what the plan calls for in 2026.
Claim Examples
Example 1: Medicare established patient, 99214, audio-video, patient at home
Box 24B: POS 10; Box 24D: 99214-95
Modifier 95 identifies the audio-video delivery. POS 10 sets the non-facility payment rate. This is the standard Medicare video visit at home in 2026.
Example 2: Medicare new patient, 99203, audio-video, patient connecting from work
Box 24B: POS 02; Box 24D: 99203-95
POS 02 applies because the patient is not at home. The facility rate applies. Modifier 95 identifies audio-video delivery.
Example 3: Commercial payer, 99213, audio-video
Box 24B: POS 10 (or the payer’s required POS); Box 24D: 99213-95
Verify the payer accepts modifier 95 and check whether the plan expects POS 10 or a different code.
Example 4: Medicare, 90837, audio-only behavioral health, patient at home
Box 24B: POS 10; Box 24D: 90837-93
The chart must document that the patient was unable to use or declined audio-video technology.
Example 5: Medicare, 99214 with a significant separately identifiable E/M service on the same day
Box 24D: 99214-25-95
Modifier 25 always precedes modifier 95 when both appear on the same line. Payment modifiers come before informational modifiers.
Example 6: Medicare brief virtual check-in
Box 24B: POS 10; Box 24D: 98016
No modifier 95 needed. The code descriptor identifies the service as a technology-based communication.
Documentation Requirements
For a claim with modifier 95, you need more than just the modifier in the right field. What the modifier says has to be backed up by the clinical note.
Document the technology used, such as that the visit used two-way audio and video at the same time. If you have generic paperwork that just says “telehealth visit” without saying what kind of visit it is, the claim could be questioned.
When modifier 93 is used to bill for an audio-only visit, the note must explain why it was used: either the patient refused to use audio-video technology or could not use it. Without this proof, the claim could be denied on the grounds that video was available but not used.
If state law or payer policy requires it, get the patient’s permission for telehealth and document it. Different states have different rules about what kind of permission is needed, and some big commercial plans need proof of consent before they will pay a telemedicine claim.
For time-based codes, keep records of how long the visit lasted. If you are billing for more than one service on the same date, you should write down each service separately to support the modifier 25 pairing on any line where it applies.
Common Telehealth Modifier Denials and How to Fix Them
Wrong POS code. Most Medicare telehealth claims get it wrong by using POS 11 instead of POS 02 or POS 10.
- Fix: Change the POS to either 02 or 10, depending on where the patient was, then resend it.
Modifier 95 on a non-eligible CPT code. When marker 95 is added to a code that isn’t in Appendix P or on the payer’s list of qualifying codes, the claim is denied.
- Fix: Make sure the code works before billing. If that payer doesn’t cover the code through telehealth, the visit may need to be moved to a face-to-face meeting.
GT on a Medicare professional claim. Medicare has banned GT on professional claims since October 1, 2018, so putting it on a CMS-1500 for a Medicare patient leads to a line-level rejection.
- Fix: Change GT to 95 and resend it.
Audio-only claim without documentation explaining why audio-only was used. Medicare needs proof that the movie wasn’t available or was denied. Claims with 93 modifiers are denied when this documentation is missing.
- Fix: Add to the chart note and resubmit with references to, or attachments of, the supporting documents.
Commercial payer mismatch. If the plan still needs GT to get a claim with 95, it will refuse it, and the same goes the other way around.
- Fix: Check the payer’s current policy on telehealth and send it again with the correct tag.
Modifier order error. The 25 goes first when the 95 shows up on the same service line. Some payers make processing errors because the modifiers are in the wrong order.
- Fix: Incorrect modifier order causes processing errors with some payers.
Using 98000-98015 with Medicare. CMS does not pay for these codes, and Medicare does not list them as a service. Claims will be turned down.
- Fix: For Medicare patients, bill the visit with the right standard E/M code (99202–99215), POS 02 or 10, and modifier 95.
Frequently Asked Questions
What is modifier 95?
For synchronous telehealth using real-time audio and video, use CPT modifier 95. It tells the payer that the visit was done through live two-way audio-video technology instead of in person and is valid for CPT codes in AMA Appendix P.
Is modifier 95 required for telehealth services in 2026?
Medicare says that the POS code (02 or 10) meets the telehealth requirement on a professional claim without modifier 95, but most practices still add it, and MACs process both correctly. Most commercial payers still require modifier 95 for standard E/M codes paid through audio-video.
What is the difference between modifier 95 and GT?
Part 95 of the CPT code is used on professional claims for Medicare and most private payers. The HCPCS modifier GT can only be used for Critical Access Hospital Method II institutional telehealth claims right now. A line-level denial happens when GT is used on a Medicare professional claim.
Can you bill 99214 with modifier 95?
Yes. Add 95 to the code for a 99214 delivered via audio-video if Medicare or a commercial payer asks for it. For Medicare, you should pair it with either POS 02 or POS 10, depending on where the patient is.
What does modifier 95 mean for CPT code 99213?
Modifier 95 on 99213 tells the payer that the office visit for an established patient was done through synchronous audio-video telehealth instead of in person. That 95th number doesn’t change the payment rate; the POS code does.
Which modifier comes first, 95 or 25?
Modifier 25 is the first one. Payment modifiers, which change how much you get reimbursed, come before data modifiers. It should be 99214-25-95, not 99214-95-25.
When should I use modifier 93 instead of 95?
Use Modifier 93 when the visit was audio-only and not video-based. Medicare doesn’t accept claims for 95 when the only service provided is audio-only telehealth.
Does modifier 95 change the payment rate?
Not at all. Modifier 95 provides information. Your place-of-service code tells us what rate to pay you. For example, POS 10 pays the non-facility rate, while POS 02 pays the lower facility rate.
Do commercial payers still accept the GT modifier?
Some people do. Some state Medicaid programs and some private plans still need GT for audio-video telehealth. As late as 2026, Ohio Medicaid’s behavioral health billing manual still has GT on it. Before you file, check to see what each payer’s current telehealth policy is.
Are Medicare telehealth flexibility still in effect?
Yes. The Consolidated Appropriations Act, 2026, signed on February 3, 2026, gave Medicare more flexibility for telehealth through December 31, 2027. This includes the patient’s home as an initial site, eliminating the need to be in a rural area for most services, and audio-only coverage for certain service types, such as permanent audio-only coverage for mental health services.
Conclusion
Telehealth modifier rules change along with new laws and payment policies. This means that a process that worked fine last year might not work this year, even if you didn’t change anything. If your practice bills for telehealth to more than one payer or is adding new telehealth service lines, the modifier-payer combination should be checked again against current policy before it turns into a pattern of denials.
Credex Healthcare medical billing services handle telehealth claim coding, modifier compliance, and payer-specific policy tracking for practices across specialties. If you are adding telehealth capacity, telehealth credentialing requirements need to be in place before the first claim goes out, and telemedicine licensing for each state where patients are located must be current. For behavioral telehealth specifically, behavioral telehealth licensing rules govern what you can bill and to whom.
