The Medicaid Telehealth Coding Cheat Sheet
Why Medicaid Telehealth Billing Confuses Even Experienced Providers
Medicaid telehealth billing is one of the most complex areas in medical revenue cycle management — and one of the most costly to get wrong.
Here's a quick answer to what you need to know:
Key Element What to Know Modalities covered Audio-visual, audio-only, remote patient monitoring, store-and-forward Common modifiers GT, 95, 93, GQ, FQ (vary by state and payer) Place of service codes POS 02 (not at home), POS 10 (patient at home) Originating site fee Bill HCPCS Q3014 when applicable Payment parity 35+ states require same rate as in-person visits Biggest denial risk Missing or incorrect modifier (e.g., Illinois denies with code EX1i)
Rules change by state, by modality, and by whether a patient is enrolled in fee-for-service or a managed care plan. A modifier that works in New York may trigger a denial in Illinois. A billing code valid in Colorado may not apply in Florida.
Virtual care went from 0.4% of network visits in 2019 to nearly 13% in 2020 — and it never fully went back down. As of June 2026, telehealth is a permanent part of how Medicaid delivers care. But the billing rules haven't gotten simpler.
I'm Olivia Harper, Founder and Denial Management & Reimbursement Specialist at National Billing Institute, and over my 30+ years in revenue cycle management I've helped hundreds of practices stop losing money to Medicaid telehealth billing errors. This guide gives you the coding cheat sheet your team needs to get claims right the first time.
Understanding Medicaid Telehealth Modalities and Covered Services
Before we look at modifiers and place of service (POS) codes, we must understand how Medicaid categorizes telehealth. Medicaid does not view telehealth as a separate benefit type. Instead, federal guidelines treat it as an alternative delivery method for services that would otherwise be provided face-to-face.
Because of this, states have broad flexibility under federal rules to decide which services are covered, where they can be delivered, and which modalities are permitted.
To build a compliant billing workflow, we must first break down the four primary modalities recognized under USA Telemedicine Billing and federal Reimbursement for Telehealth and Provider and Facility Guidelines frameworks.
Audio-Visual and Audio-Only Medicaid Telehealth Billing
Synchronous Audio-Visual (Real-Time): This is the most widely covered modality. It requires real-time, two-way interactive video and audio communication that functionally replicates an in-person face-to-face visit. Both the patient and the provider must be present simultaneously.
Audio-Only Telehealth (Telephone): Audio-only services became vital during the public health emergency to bridge the digital divide for patients lacking high-speed internet or compatible devices. However, as of June 2026, many states have narrowed their audio-only coverage.
Many Medicaid programs now require a documented "established relationship" before an audio-only visit can be billed. For example, some states require the patient to have had at least one in-person or synchronous audio-visual encounter with the provider (or another provider within the same group practice) within the past three years. To explore how different payers handle these requirements, see the national updates on Audio-Only Telehealth Post-PHE -- Medicare, Medicaid, and Private ....
Remote Patient Monitoring and Store-and-Forward Rules
Asynchronous Store-and-Forward: This modality involves transmitting recorded clinical data (such as X-rays, photos, pre-recorded videos, or digital dental impressions) through a secure electronic communications system to a practitioner at a distant site. The distant site practitioner reviews the case and provides an assessment or consultation without the patient being present in real-time.
It is important to note that store-and-forward explicitly excludes basic emails, faxes, or voice mail messages. To bill store-and-forward successfully, the distant site practitioner must generate a formal written consultation report for the patient's medical record.
Remote Patient Monitoring (RPM): RPM involves the collection of physiologic data (such as blood pressure, heart rate, or blood glucose levels) from a patient at home, which is then securely transmitted to a supervising healthcare professional. Under modern Medicaid guidelines, RPM is increasingly covered for patients managing chronic conditions like hypertension, diabetes, or congestive heart failure.
Step-by-Step Guide to Medicaid Telehealth Billing and Coding
Billing for virtual visits requires the same clinical rigor as billing for in-person care. We cannot simply copy-paste clinical templates or assume that any virtual encounter is billable.
To ensure compliant reimbursement, your team must follow a structured step-by-step process for every claim.
1. Verify Provider and Patient Eligibility
Not every healthcare professional can bill Medicaid for telehealth. Eligible practitioners typically include licensed physicians, nurse practitioners (NPs), physician assistants (PAs), clinical psychologists, licensed clinical social workers (LCSWs), and physical/occupational/speech therapists.
Additionally, we must verify the patient's active Medicaid eligibility and specific plan enrollment (Fee-For-Service vs. Managed Care) prior to the visit. For a complete look at general billing workflows, read our guide on How to Bill for Telemedicine Visits.
2. Select the Correct CPT or HCPCS Code
You should select the procedure code that accurately reflects the service delivered, such as Evaluation and Management (E/M) codes (e.g., 99202–99215) or behavioral health codes (e.g., 90832–90837). The service delivered via telehealth must meet all clinical and time-based elements of the chosen code. For a comprehensive list of active codes, refer to the CMS Telehealth Billing Codes registry.
3. Document the Visit Thoroughly
Your clinical documentation must justify the medical necessity of the telehealth encounter and explicitly state the modality used. The federal government provides detailed resources on maintaining these standards through the official portal for Billing for telehealth. At a minimum, every telehealth medical record must include:
An explicit statement that the service was delivered via telehealth.
The specific modality used (e.g., synchronous audio-visual, audio-only).
The physical location of the patient during the visit (the originating site).
The physical location of the provider (the distant site).
Documented verbal or written patient consent obtained before or during the first virtual encounter.
Start and stop times of the visit (crucial for time-based codes).
Place of Service Codes and Modifiers for Medicaid Telehealth Billing
The fastest way to trigger a Medicaid claim denial is to use the wrong combination of Place of Service (POS) codes and billing modifiers.
For professional claims (CMS-1500), we must use specific POS codes to indicate where the patient was located when they received the virtual service:
POS 02 (Telehealth Provided Other than in Patient’s Home): Use this code when the patient is located at an eligible facility (such as a clinic, hospital, or nursing home) during the telehealth encounter.
POS 10 (Telehealth Provided in Patient’s Home): Use this code when the patient is located in their private residence or temporary lodging (such as a shelter) during the encounter. For an in-depth breakdown of when and how to apply this code, see our detailed guide on POS 10.
To clarify how these POS codes interact with billing modifiers, we must also append the correct modifier to the CPT/HCPCS codes. Let's look at the primary modifiers used in 2026:
Modifier 95: Indicates synchronous audio-visual telemedicine. This is widely used by commercial payers, Medicare Advantage, and several state Medicaid programs.
Modifier GT: Used by many state Medicaid programs to represent interactive audio and video telecommunications.
Modifier 93: Appended to claims for synchronous audio-only services to indicate that the service was delivered via telephone.
Modifier GQ: Used for asynchronous store-and-forward transmissions.
Modifier FQ: Used by Medicare and certain state Medicaid programs for audio-only mental and behavioral health services.
To stay compliant with the latest changes, we recommend keeping our guide on Telehealth Modifiers 2026 handy.
Modality Default POS Required Modifiers Key Billing Tip Synchronous Audio-Visual POS 10 (Home) or POS 02 (Facility) Modifier 95 or GT Verify whether your state Medicaid program prefers GT over 95. Synchronous Audio-Only POS 10 (Home) or POS 02 (Facility) Modifier 93 or FQ Ensure the patient has a documented "established relationship" if required by your state. Asynchronous Store-and-Forward POS 02 or POS 10 Modifier GQ Keep a copy of the written consultation report in the patient's file. Remote Patient Monitoring POS 10 No telehealth modifiers (RPM codes are asynchronous) Do not append telehealth modifiers to RPM codes (99453–99458).
Originating vs. Distant Site Billing and Facility Fees
Telehealth billing involves two distinct physical locations, and Medicaid allows for separate billing at both ends of the transmission:
The Distant Site: This is where the practitioner rendering the service is physically located. The distant site provider bills their professional services using the appropriate CPT/HCPCS code, the correct POS code (02 or 10), and the required state-specific modifier.
The Originating Site: This is where the patient is physically located during the encounter. If the patient is at home (POS 10), no originating site fee can be billed. However, if the patient is located at an eligible healthcare facility (such as a rural health clinic, hospital, or physician's office) that provides the space and telecommunications equipment for the visit, that facility can bill an originating site facility fee.
To bill the originating site facility fee, the facility submits a claim using HCPCS code Q3014. Only specific provider types are eligible to bill this code, and the clinical record must document that the patient was physically present at the facility during the virtual visit.
Furthermore, many states enforce payment parity laws. Payment parity requires Medicaid programs to reimburse telehealth services at the same rate as comparable in-person visits, ensuring that providers do not face a financial penalty for offering virtual care options.
Specialized Benefits: Behavioral Health, EPSDT, and Managed Care
Telehealth rules intersect uniquely with specialized Medicaid benefits:
Behavioral and Mental Health: Mental health services are highly compatible with telehealth. Under current 2026 rules, geographic restrictions are permanently waived for mental health telehealth, allowing patients to receive therapy and psychiatric care from their homes. However, providers must remain vigilant about state-specific rules regarding group therapy, substance use disorder (SUD) programs, and Applied Behavior Analysis (ABA) services.
EPSDT Benefits: The Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit covers comprehensive healthcare services for Medicaid-eligible children under age 21. EPSDT mandates that states cover any medically necessary service to correct or ameliorate a physical or mental condition, even if that service is not normally covered under the state's standard Medicaid plan. This mandate extends to telehealth, meaning pediatric patients often have broader virtual care coverage than adults.
Managed Care Organizations (MCOs) vs. FFS: While fee-for-service (FFS) Medicaid guidelines are set directly by the state, the majority of Medicaid beneficiaries are enrolled in managed care plans (such as Sunshine Health in Florida). MCOs must cover at least the same services as FFS Medicaid, but they may have different prior authorization requirements, credentialing processes, and preferred billing pathways.
State-Specific Medicaid Telehealth Rules and Variations
Because Medicaid is administered at the state level, there is no single "national" standard for medicaid telehealth billing. States have the authority to establish their own policies, leading to a patchwork of rules across the country.
To illustrate this, we will examine the unique guidelines of several key states. For a deeper look at state-specific policies, you can consult the official Medicaid Telehealth Manual.
New York and Florida Medicaid Telehealth Policies
New York State Medicaid
New York covers four distinct telehealth modalities: synchronous audio-visual, audio-only, remote patient monitoring, and store-and-forward.
Under New York State law, payment parity is protected until April 1, 2026, requiring telehealth services to be reimbursed at the same rate as in-person visits (with some exceptions for specific facility types).
New York requires professional claims to use modifiers 95 or GT for synchronous audio-visual services, and modifiers 93 or FQ for audio-only services. To learn more about how these modifiers function, check our guide on the Telehealth Modifier.
Florida Medicaid (Sunshine Health)
Florida Medicaid covers telehealth services at the same rate as in-person visits for eligible providers, including physicians, NPs, PAs, therapists, and behavioral health specialists.
Florida requires interactive audio and video equipment permitting two-way, real-time communication. Simple telephone calls, emails, and faxes are excluded from standard telehealth billing, though specific "virtual check-ins" and "e-visits" have their own coding structures.
Notably, post-public health emergency rules in Florida ended telehealth reimbursement for ABA caregiver training, while lead analysts remain eligible for remote billing.
Colorado, Washington, Wisconsin, and Illinois Billing Requirements
Colorado (Health First Colorado)
Colorado Medicaid treats telehealth as a delivery method rather than a distinct benefit. Effective July 1, 2025, Health First Colorado expanded its coverage to include Remote Patient Monitoring (RPM) for eligible chronic conditions.
Colorado providers must use POS 02 or POS 10 and apply modifier GT for FQHC and RHC telemedicine claims. Colorado also introduced a specialized "eHealth" entity provider type for groups that deliver services exclusively via telemedicine. For a retroactive look at how these rules evolved, see How to Bill Telemedicine Visits 2025.
Washington State (Apple Health)
Washington allows audio-only telemedicine, but only for established patients who have a documented clinical relationship with the provider (or their group practice) within the past three years.
Washington's store-and-forward guidelines explicitly exclude telephone, fax, or email, requiring dedicated asynchronous communication platforms instead.
Wisconsin (ForwardHealth)
Wisconsin Medicaid distinguishes between temporarily covered and permanently covered telehealth services.
For permanently covered services, distant site providers must use POS 02 and modifier GT. For temporarily covered or audio-only emergency services, modifier 95 is used to ensure clarity during state audits.
Wisconsin also dictates that group services for psychosocial rehabilitation or substance abuse must be billed with face-to-face POS codes, even when delivered virtually using modifier 95.
Illinois Medicaid
Illinois has strict billing compliance rules. To avoid automatic denials, providers must append modifiers GT or 93 to their claims alongside POS 02 or POS 10.
Claims submitted without these required modifiers will be denied immediately under code EX1i (CARC 16/RARC N823).
Frequently Asked Questions about Medicaid Telehealth Billing
What is the difference between POS 02 and POS 10 for Medicaid?
The difference is based entirely on the physical location of the patient during the encounter. Use POS 10 if the patient is at home or in a private residence. Use POS 02 if the patient is located at a healthcare facility, clinic, or other non-residential site.
Using the incorrect POS code can result in claim denials or audit penalties, as explained in our overview of Telehealth Billing Modifiers.
Can out-of-state providers bill Medicaid for telehealth services?
Yes, but with strict conditions. The rendering provider must be fully licensed in the state where the patient is physically located at the time of the visit. Additionally, the provider must be enrolled as a participating provider in that state’s Medicaid program.
Many states participate in the Interstate Medical Licensure Compact (IMLC), which accelerates the licensing process, but it does not bypass individual state Medicaid enrollment requirements.
What happens if a Medicaid telehealth claim is missing a modifier?
The claim will likely be denied. For example, Illinois Medicaid will deny the claim with code EX1i, while other states will reject the claim as incomplete.
Your billing team must establish clean claim edits to ensure that every telehealth claim has the correct modifier (GT, 95, 93, or GQ) paired with the appropriate POS code before submission.
Conclusion
Navigating the complexities of medicaid telehealth billing requires constant vigilance, specialized coding knowledge, and state-specific expertise. A single missing modifier or incorrect place of service code can disrupt your cash flow and lead to administrative headaches.
At National Billing Institute, we specialize in simplifying medical billing for healthcare providers across the United States. Operating from our 100% USA-based headquarters in Boca Raton, Florida, our team brings over 30 years of industry experience to your revenue cycle.
By leveraging advanced, AI-automated claims processing and maintaining strict HIPAA compliance, we consistently deliver the lowest denial rates in the industry, helping practices achieve a 15% to 30% increase in revenue.
Let us handle the coding guidelines while you focus on delivering quality care to your patients. Partner with National Billing for expert medical billing services today and optimize your virtual care reimbursement.
