Telehealth is now a core component of psychiatric and neurological care delivery—and the coding landscape continues to evolve. New CPT code families, updated Medicare policy, and a congressional extension are shaping the 2026 billing picture.
Starting in 2025, the American Medical Association (AMA) introduced a dedicated family of telehealth CPT codes, the Centers for Medicare & Medicaid Services (CMS) updated its reimbursement policy under the CY 2026 Medicare Physician Fee Schedule (MPFS), and a congressional extension locked key Medicare telehealth flexibilities in place through December 31, 2027.
For billing teams and practice leaders, staying current on telehealth CPT codes for 2026 matters for every visit delivered remotely—including appointments where remotely completed cognitive assessment data is part of the clinical conversation. This article is a practical reference for the codes, modifiers, place of service designations, and payer considerations that apply.
What Changed for Telehealth CPT Codes in 2026
The 2026 telehealth billing picture is shaped by key developments: a new AMA code family for telehealth E/M services, a CMS decision not to reimburse most of those new codes under Medicare, and a congressional extension that resolved months of regulatory uncertainty around telehealth flexibilities.
In late 2025, CMS finalized payment policies under the Physician Fee Schedule, effective January 1, 2026. Shortly after, on February 3, 2026, the Consolidated Appropriations Act, 2026 (H.R. 7148) was signed into law, extending most Medicare telehealth flexibilities through December 31, 2027.
The net effect is a more settled environment than providers faced in 2024 and 2025, but one that still requires billing teams to navigate a dual-track coding system: one set of rules for Medicare, another for commercial payers.
New Telemedicine CPT Codes (98000–98016): What They Cover
Starting in 2025, the AMA introduced a dedicated family of CPT codes for telehealth evaluation and management services. These codes remain in effect for 2026, replace the now-deleted telephone visit codes (99441–99443), and are structured to mirror the logic of standard office visit coding—selected based on either medical decision-making (MDM) or total time spent on the date of the encounter.
Audio-Video CPT Codes (98000–98007)
CPT codes 98000–98007 cover synchronous audio-video evaluation and management (E/M) services for new and established patients. They parallel the 99202–99215 office visit series but specify real-time audio and video technology as the service modality. Code selection follows the same MDM or time-based criteria used for office visits: straightforward, low, moderate, or high complexity for both new and established patients.
Because the telehealth modality is built into the code descriptor, modifier 95 is not required when billing these codes to payers that accept them.
Audio-Only Telehealth Services (98008–98015)
CPT codes 98008–98015 follow the same structure but apply to synchronous audio-only encounters. These replaced the deleted 99441–99443 telephone codes and represent a significant shift: audio-only visits are now treated as full E/M services rather than limited telephone interactions, with the same MDM and time-based coding tiers.
Brief Communication — Virtual Check-Ins (98016)
CPT 98016 describes a brief, patient-initiated communication technology-based service for established patients, involving 5–10 minutes of medical discussion. It replaced HCPCS code G2012. The service must be patient-initiated and cannot relate to an E/M visit within the prior seven days or lead to one within 24 hours (or the soonest available appointment). It is not selected based on medical decision-making (MDM) or total time in the same manner as E/M services and can be delivered via either audio-only or audio-video communication.
Why Medicare Still Doesn't Reimburse 98000–98015
CMS has determined that codes 98000–98015 are duplicative of existing E/M codes with modifiers and does not reimburse them under Medicare.
The sole exception is CPT 98016, which Medicare reimburses as the direct replacement for G2012.
For Medicare fee-for-service claims, practices should continue billing standard office E/M codes (99202–99215) with the appropriate place of service code and modifier (see below). CMS has assigned the 98000–98015 codes a status indicator of "I" (not valid for Medicare purposes), meaning they will trigger denials if submitted to Medicare.
Many commercial payers and some state Medicaid programs do accept the 98000–98015 series, creating a dual-track billing system. Billing teams should verify coverage with each contracted payer before submitting claims using these codes. The reimbursement rates assigned by CMS to these codes are notably lower than those for their in-person office visit counterparts, so even where they are accepted, rate comparison is warranted.
CY 2026 Medicare Telehealth Policy Updates
Beyond the new code families, several policy changes under the CY 2026 MPFS and the Consolidated Appropriations Act, 2026, directly affect how practices bill and deliver telehealth services.
Telehealth Flexibilities Extended Through December 31, 2027
The Consolidated Appropriations Act, 2026 (Section 6209) extended most Medicare telehealth flexibilities through December 31, 2027. These provisions had briefly lapsed when the previous authorization expired on January 30, 2026, during a short government shutdown, before being retroactively reinstated. The extended flexibilities include:
- The patient's home remains an eligible originating site—patients do not need to travel to a healthcare facility to receive Medicare telehealth services
- Geographic restrictions remain suspended, allowing beneficiaries in both urban and rural areas to access telehealth
- The expanded list of distant-site practitioners (including PTs, OTs, SLPs, and audiologists) remains eligible to deliver telehealth services
- Federally qualified health centers (FQHCs) and rural health clinics (RHCs) can continue serving as distant-site providers
- Audio-only communication technology remains covered for non-behavioral/mental health telehealth services when clinically appropriate
- The in-person visit requirement for behavioral health services is waived through January 1, 2028—meaning Medicare patients can continue receiving mental health telehealth services without first having a face-to-face encounter
A key takeaway for practice leaders: the nearly two-year extension provides more regulatory certainty than the cycle of short-term extensions providers navigated in 2024 and 2025. Practices can maintain current telehealth workflows and make operational investments without the near-term risk of flexibilities sunsetting.
Permanent Virtual Direct Supervision
The CY 2026 MPFS final rule permanently changed the definition of "direct supervision" under §410.26. Starting January 1, 2026, supervising physicians can meet the "immediate availability" requirement for most incident-to services through real-time audio-video communication rather than being physically present in the office suite.
This applies to incident-to services (§410.26), diagnostic tests (§410.32), and cardiac and pulmonary rehabilitation services (§410.47, §410.49). The exception: services with a global surgery indicator of 010 or 090 (10-day and 90-day global period procedures) still require in-person physical presence for supervision.
For psychiatric practice leaders who supervise nurse practitioners, physician assistants, or other providers, this is a meaningful operational change. It allows supervisors to oversee auxiliary staff delivering services at satellite locations or through telehealth without being in the same physical office, and it is now a permanent policy rather than a temporary flexibility.
Additions to the Medicare Telehealth Services List
CMS added several services to the Medicare Telehealth Services List for CY 2026, including:
- CPT 90849 — Multiple-family group psychotherapy (relevant to behavioral health practices)
- HCPCS G0473 — Group behavioral counseling for obesity
- HCPCS G0545 — Infectious disease add-on code
- CPT 92622 and 92623 — Auditory osseointegrated sound processor services
CMS also streamlined its review process for adding services to the Telehealth Services List.
Originating Site Facility Fee (Q3014)
For CY 2026, the payment amount for HCPCS code Q3014 (telehealth originating site facility fee) is $31.85, up from $31.01 in CY 2025. This reflects the 2.7% increase in the Medicare Economic Index (MEI). Medicare pays 80% of the lesser of the actual charge or $31.85, with the beneficiary responsible for any unmet deductible and coinsurance.
Commercial Payer Variations and Avoiding Claim Denials
Medicare's decision not to reimburse 98000–98015 creates a split that billing teams need to manage carefully. While Medicare uses the established E/M codes with modifiers and place of service codes, many commercial payers and state Medicaid programs have adopted some or all of the new 98000–98016 telehealth codes—sometimes at different reimbursement rates.
Where Commercial Payers Diverge from Medicare
Commercial payer policies on telehealth coding vary significantly. Some have adopted the 98000–98015 series for telehealth E/M services. Others continue requiring standard 99202–99215 codes with telehealth modifiers, mirroring Medicare's approach. Documentation requirements, modifier conventions, and coverage scope for audio-only visits also differ across payers.
Practices that serve both Medicare patients and commercially insured patients need to configure dual coding pathways in their billing software: one for Medicare (99202–99215 with POS and modifier), one for commercial payers that accept the new codes. Submitting claims using the wrong code set for a given payer is one of the fastest ways to trigger a denial or payment delay.
Patient Consent, Place of Service, and Modifier Quick Reference
For Medicare telehealth claims billed using 99202–99215, two modifiers indicate modality:
- Modifier 95 indicates the service was delivered via real-time audio and video communication. Used primarily with Medicare and commercial payers when billing traditional E/M codes.
- Modifier 93 indicates an audio-only encounter. Used by Medicare to indicate audio-only telehealth services when billing eligible services. Documentation should support why audio-video was not used when clinically appropriate—typically because the patient lacked access or did not consent to video technology.
Place of service codes tell the payer where the patient was located during the telehealth encounter:
- POS 10 (Telehealth Provided in Patient's Home) applies when the patient connects from their residence. Reimburses at the higher nonfacility rate.
- POS 02 (Telehealth Provided Other Than in Patient's Home) applies when the patient connects from a healthcare facility, clinic, or other non-home location. Pays the facility rate.
Patient consent for telehealth should be documented in the medical record per applicable state law. At a minimum, records should confirm: the telehealth platform used, the communication modality (audio-video or audio-only), and the patient's location at the time of the encounter.
Common Denial Patterns and How to Avoid Them
Several coding errors account for a disproportionate share of telehealth claim denials:
- Billing 98000–98015 to Medicare. These codes will be denied. For Medicare, always use 99202–99215 with the appropriate POS and modifier.
- Incorrect place of service code. POS 10 vs. POS 02 affects the reimbursement rate. Using the wrong one can result in underpayment or outright denial.
- Missing or incorrect modifier. Omitting modifier 93 on an audio-only Medicare claim, or applying modifier 95 where the payer doesn't require it, can delay processing or cause a rejection.
- Insufficient documentation of medical necessity. Clinical decision-making, the modality used, and the rationale for telehealth delivery should be clear in the encounter note.
- Same-day service conflicts. Billing a virtual check-in (98016) when it relates to an E/M visit within seven days or leads to one within 24 hours will be denied.
Conducting quarterly audits of telehealth claims to identify modifier and POS error patterns is a practical step for practices that deliver a high volume of remote care.
How Remote Cognitive Assessments Fit Into the Telehealth Workflow
The expanded telehealth framework also supports hybrid workflows where portions of the clinical evaluation occur asynchronously. Remotely administered cognitive assessments, for example, allow patients to complete validated screening measures on their own time, with results available to the clinician before or during a telehealth encounter. This approach can reduce the staff time associated with in-clinic test administration and give providers objective data to inform the clinical conversation—whether the focus is ADHD evaluation, cognitive decline monitoring, or treatment response tracking.
For practices that deliver a significant share of care via telehealth, the ability to pair remote assessment data with a virtual visit creates an efficient workflow: the patient completes the cognitive assessment remotely, the provider reviews results during or before the appointment, and the visit time can focus on clinical discussion and treatment planning rather than test administration.
Providers should note that remotely administered cognitive assessments may be billed separately from the telehealth E/M visit itself. Coverage and reimbursement for cognitive testing vary by payer, and practices should confirm their payer's policies on remote testing services before incorporating them into a telehealth workflow.
What to Watch in 2027
The current Medicare telehealth flexibilities expire on December 31, 2027. Unless Congress acts again, geographic and originating-site restrictions will return for non-behavioral health services, and audio-only coverage for those services will end. Behavioral health telehealth services follow a slightly different timeline: the waiver of in-person visit requirements expires January 1, 2028, at which point Medicare will require an in-person visit within six months of the initial behavioral health telehealth service and annually thereafter.
Commercial payer policies continue to evolve independently of Medicare timelines and may tighten coverage, documentation standards, or reimbursement rates on their own schedules. Practices that deliver care across state lines should also monitor state-level telehealth parity laws, which remain inconsistent.
CMS is also required under the CAA 2026 to establish new billing codes or modifiers by 2027 to identify telehealth services delivered through third-party virtual platforms—a transparency measure that may affect practices using external telehealth technology vendors.
Practices that proactively monitor these changes will be better positioned to maintain compliance, protect reimbursement, and sustain efficient telehealth operations as the regulatory landscape continues to evolve.
Written by Emily Montemayor, Medical Coding Support Manager
Emily Montemayor, a CCS, COC, CPC, CPMA, CMBCS, QMRAC, CPC-I, CPA-EDU Approved Instructor, is a recognized expert in coding compliance, revenue integrity, and provider education. As Medical Coding Support Manager at Creyos and Director of Education for OAHIMA, she has led international training and initiatives that optimize reimbursement, enhance documentation, and advance coding practices—driven by her passion for empowering healthcare teams and improving patient care through education and compliance excellence.