Bill a video session with the same CPT code you would use in the office, such as 90837. What changes is the place of service code and the modifier, and each payer sets its own. Medicare wants place of service 10 when the client is at home and 02 when they are somewhere else. Texas Medicaid wants modifier 95 for video and FQ for a session by phone. A fully insured Texas plan has to cover a video session from an in-network clinician on the same basis as an office visit. It does not have to cover a session by phone, and it sets its own codes.
A wrong code on a video session costs you twice. A claim whose codes the payer doesn't accept is denied or paid at the wrong rate, often weeks later. And a session the payer would not have covered at all, such as a Medicaid phone session with a client the practice hasn't seen in the office or by video in six months, is one the payer can take back in a later audit. Most of these rules turn on two facts the note has to record: where the client was, and whether the session was by video or by phone.
This post reads the Medicare telehealth booklet, the Texas Medicaid behavioral health handbook and the Texas Insurance Code as they stood on the day it was published.
What does each payer want on the claim?
The rest of this post is where each line comes from.
Medicare
Medicare names the place of service codes for professional claims. POS 02 is "Telehealth Provided Other than in Patient's Home", for a client who is somewhere else. POS 10 is "Telehealth Provided in Patient's Home" (CMS, Telehealth and Remote Patient Monitoring, MLN901705, December 2025). The booklet says "We pay for telehealth services you provide to patients in their homes at the non-facility PFS rate", which is the same rate as an office visit. A client's home counts as an allowed site for the diagnosis and treatment of mental health disorders.
A phone session can count too. The booklet says "For behavioral or mental telehealth, you may use 2-way, interactive, audio-only technology, and the patient must be in their home." The regulation narrows it. A phone session counts only when the clinician could use video "but the patient is not capable of, or does not consent to, the use of video technology", and the claim must carry CPT modifier "93" (42 CFR 410.78(a)(3)). So the note records why the session was not by video.
Does a Medicare client ever have to come in? The booklet says so. "You must conduct an in-person visit within 6 months of the initial telehealth visit and annually thereafter." The booklet points to an exception in the regulation. The clinician and client may skip the yearly visit for a 12-month period if they agree that its risks and burdens outweigh its benefits, and the clinician writes the reason in the record. Another clinician of the same specialty in the same group may hold the visit if the treating clinician is not available (42 CFR 410.78(b)(3)(xiv)). The regulation's text on how often the visit is due differs from the booklet's, so follow the booklet. Congress has pushed back the date this rule starts more than once, including in a November 2025 stopgap law that moved it to January 31, 2026 (Pennsylvania Office of Rural Health, November 15, 2025). A trade report says the Consolidated Appropriations Act, 2026, signed February 3, 2026, delays it for most mental health telehealth services until January 1, 2028 (Medical Economics, February 10, 2026). Confirm the date on the CMS telehealth page before you plan a Medicare client's care around it.
Texas Medicaid
The handbook asks for a modifier, not only a place of service. "Outpatient mental health services provided by synchronous audiovisual technology must be billed using modifier 95." The list includes the diagnostic evaluation and individual, family and group psychotherapy (90791, 90832 through 90838, 90846, 90847 and 90853). A phone session "must be billed using modifier FQ" (TMHP, Behavioral Health and Case Management Services Handbook, October 2026, §4.2.1).
A phone session also has conditions a video session doesn't:
- The client has an existing clinical relationship with the practice. That means at least one office or video session from the same billing provider in the six months before the first phone session. The handbook says this requirement "may not be waived."
- The clinician writes in the record why the session was by phone.
- The practice holds at least one office or video session in every rolling 12 months after the first phone session. The client and the practice can agree to skip it when it is clinically contraindicated or its risks or burdens outweigh its benefits. The reason goes in the record, and the agreement covers only that 12-month period.
The handbook says "same billing provider" means providers within the same organization, as identified by its NPI number or numbers, and that the earlier office or video session may be held by another professional of the same billing provider. So a client who saw one of your clinicians by video can, by that reading, have a phone session with another. Because Texas Medicaid pays only the clinician who performs a session, confirm with TMHP or the plan in writing how it reads this for a group before you rely on it. Every session by video or phone also has to be clinically appropriate and safe and agreed to by the client, and the handbook asks you to put the client's choice of how to meet ahead of the practice's convenience.
A Texas Medicaid managed care plan can add billing rules of its own, so ask each plan you contract with which place of service code it wants beside the modifier.
Commercial plans
Texas law sets the floor for fully insured plans, and each plan sets its own codes. A plan "must provide coverage for a covered health care service or procedure" delivered by telehealth "on the same basis and to the same extent" as in person, when an in-network clinician delivers it. It may not exclude a covered service "solely because" it was not delivered in person (Texas Insurance Code §1455.004). The client's deductible, copay or coinsurance for the video session may not be more than for the same session in the office. But the same section says a plan "is not required to provide coverage" for telehealth by audio alone, including "an audio-only telephone consultation".
That section is about coverage and what the client pays. It doesn't set what the plan pays you, which comes from your contract. It also doesn't reach a self-funded employer plan, which the post on checking a client's insurance shows how to spot.
The codes differ by plan. Aetna's Texas page, for example, says "Providers must bill with Place of Service 02 (Telehealth services) and/or modifier GT" or modifier 95 (Aetna, Texas telemedicine), and it doesn't mention POS 10. The page defines GT as asynchronous and 95 as live audio and video, so a live video session is POS 02 with modifier 95. The page also says Aetna is not required to cover an audio-only telephone consultation. Read each plan's telehealth policy, keep a copy of the version you followed, and ask the plan in writing where the policy is silent.
What should the note record?
Four things, for every session not held in the office:
- Whether it was by video or by phone.
- Where the client was: at home or somewhere else, and the state they were in.
- That the client agreed to meet this way.
- For a phone session, why it was by phone rather than by video.
The first two decide the codes. The last two are what a Medicaid audit reads first. Ask your licensing board before you see a client who is outside Texas for the session, because a client's location is a licensing question as well as a billing one.
What to do this week
- Pull five recent video claims for each payer and check the place of service and modifier against the table above.
- Check that your note template records how the session was held, where the client was and that they agreed.
- List your Texas Medicaid clients who have had a phone session, and check each one had an office or video session in the six months before the first.
- Find each commercial plan's telehealth policy, save the current version, and write down the codes it asks for.
- For each Medicare client seen only by video, write down when they were last seen in person.
Sources
- Telehealth and Remote Patient Monitoring, MLN901705, Centers for Medicare and Medicaid Services, December 2025.
- 42 CFR 410.78, telehealth services.
- Behavioral Health and Case Management Services Handbook, Texas Medicaid Provider Procedures Manual, TMHP, October 2026, §4.2.1.
- Texas Insurance Code §1455.004, coverage for telemedicine, teledentistry and telehealth services.
- Texas telemedicine, Aetna.
- Congress extends timeline for in-person visit requirements for Medicare BH telehealth, Pennsylvania Office of Rural Health, November 15, 2025.
- What changed in Medicare telehealth under the 2026 spending bill, Medical Economics, February 10, 2026.
Pass it on