Telehealth for Therapists: What It Is and What Payers Expect
Telehealth for therapists means delivering psychotherapy or psychiatric care to a client through live video or audio instead of in your office. For your practice, it also adds a second set of rules: what each payer covers, which place-of-service code goes on the claim, and how you protect client information on the platform. This guide is for psychotherapists and psychiatrists. It is operational billing guidance, not legal advice.
What is telehealth for therapists?
Telehealth is the use of phones, computers or other technology to give care from a distance. The U.S. Department of Health and Human Services (HHS) says telehealth, also called telemedicine, lets a person see a provider remotely instead of going to the office, through phone or video conversations and secure messaging. In a therapy practice that usually means live video sessions, and sometimes audio-only sessions when video is not an option. See the glossary entries for Telehealth and Telehealth Flexibilities.
Is telehealth the same as telemedicine? HHS uses the two terms together. Payers do not always do the same, so use each payer’s own wording in your policies and claims.
Medicare rules for telehealth for therapists
This section covers Original Medicare only. Private insurers and Medicaid set their own rules, covered in the next section. These points come from the CMS Medicare Telehealth FAQ (updated October 2026).
- Location: geographic and place-of-service limits on behavioral health telehealth were permanently removed, so a client can be at home.
- Audio-only: two-way audio-only is allowed for behavioral health telehealth. From January 1, 2028, audio-only in the home applies when you can use video but the client cannot or does not consent to it.
- In-person visit: Medicare requires an in-person visit within 6 months before the first mental health telehealth service, effective after December 31, 2027. Clients who began mental health telehealth at home on or before that date count as established, with an in-person visit at least every 12 months afterward.
- Payment: since January 1, 2024, Medicare pays telehealth to clients in their homes at the non-facility rate.
Congress has moved these dates before, so recheck the CMS FAQ each quarter. For background, read our guide to telehealth originating site rules and the glossary entry for Originating Site.
Private payers, Medicaid and state law
Private payers, Medicaid programs and state laws each set their own telehealth rules, and they often differ from Medicare. Do not assume one payer’s rule applies to another. Ask every payer these questions before you bill:
- Does the plan cover telehealth for psychotherapy and psychiatric visits, and for which CPT codes?
- Which place-of-service code does it want, and does it also want a telehealth modifier such as Modifier 95?
- Is audio-only covered, and does the plan have its own documentation rules?
- Does the plan require prior authorization for telehealth visits?
Our guide to telehealth billing rules by payer goes deeper. Medicaid also varies by state: the Illinois Medicaid telehealth billing guide shows how one state handles it.
Place of service codes: POS 02 and POS 10
The place-of-service (POS) code tells the payer where the client was during the visit. The CMS place of service code set (modified February 2026) defines the two telehealth codes below.
| Code | What CMS says it is |
|---|---|
| POS 02 | Telehealth provided other than in the client’s home |
| POS 10 | Telehealth provided in the client’s home |
Medicare uses these codes, and private payers may ask for something different, so confirm with each plan. Our guide to in-home telehealth POS codes explains the home-visit rules.
HIPAA and your telehealth platform
HIPAA applies to telehealth. HHS Office for Civil Rights guidance on audio-only telehealth (last reviewed June 23, 2026) says providers using remote communication technology must follow the HIPAA Privacy, Security and Breach Notification Rules. It also says a vendor that stores, creates or maintains protected health information, such as an app that records or transcribes sessions, needs a business associate agreement (BAA). Use a private space for sessions and confirm who is on the call.
Telehealth checklist for therapists: 6 easy steps
- Ask your state licensing board where a client must be located during a session.
- Check each client’s telehealth benefits as part of insurance verification for therapists.
- Choose a platform whose vendor will sign a BAA.
- Document each session the way the payer requires, including the client’s location and the platform used.
- Choose the POS code and modifier the payer asks for.
- Recheck Medicare dates each quarter against the CMS FAQ.
How does MCM South help with telehealth billing?
MCM South is a medical billing service that works only in mental and behavioral health. We serve psychotherapists and psychiatrists in solo and medium-size practices, and our billing work covers telehealth claims alongside in-office claims. See Who We Serve for the practices we support, or ask for a free quote and we will tell you how we handle the payers you bill.
Telehealth for therapists: the short version
Telehealth for therapists is live video or audio care with its own billing rules. For Medicare, behavioral telehealth can happen at home, and the in-person visit requirement begins after December 31, 2027. For everyone else, ask each payer about coverage, POS code, modifier and documentation. Use a HIPAA-ready platform with a BAA. Browse more guides in the Resources hub and the CPT and E/M code guide.
Keep going
Related reading
Telehealth for therapists FAQ
What is telehealth for therapists?
Telehealth for therapists is delivering psychotherapy or psychiatric care by live video or audio instead of in the office. HHS describes telehealth, also called telemedicine, as a way to see a provider remotely.
Does Medicare cover telehealth for mental health?
Yes. For behavioral health, CMS says geographic and place-of-service limits were permanently removed, so the client can be at home, and two-way audio-only is allowed. The in-person visit requirement takes effect after December 31, 2027. Source: CMS Medicare Telehealth FAQ, updated October 2026.
Which place-of-service code do I use for telehealth from home?
CMS defines POS 10 as telehealth provided in the client’s home and POS 02 as telehealth provided somewhere other than the home. Private payers may have their own rules, so confirm with each plan.
Is telehealth HIPAA compliant?
HIPAA applies to telehealth, so you must follow the Privacy, Security and Breach Notification Rules. A vendor that stores, creates or maintains protected health information, such as a session recording or transcription app, needs a business associate agreement. Source: HHS Office for Civil Rights.
Do all payers pay for telehealth the same way?
No. Each private payer, Medicaid program and state sets its own coverage, codes, modifiers and documentation rules. Ask each payer before you bill and record the answer.
Where MCM South works
MCM South works only in mental and behavioral health. We serve psychotherapists and psychiatrists in solo and medium-size practices across ten currently served states: Georgia, Massachusetts, Connecticut, Texas, Florida, New York, Colorado, Tennessee, North Carolina and Illinois. Need a payer contact? Use our insurance companies contact directory.
