Telehealth CPT Codes for 2026: A Plain-English Billing Guide for Small Practices

If you've tried to bill a telehealth visit in 2026, you've probably already hit the confusion. Your biller submits a claim with the new 98000 series, and Medicare rejects it. Or you use a traditional E/M code with a telehealth modifier, and a commercial payer kicks it back saying the new codes are required. Welcome to the 2026 telehealth billing landscape, where the rules depend entirely on who you're billing.

This post is a practical, plain-English guide to telehealth CPT codes in 2026. Not a textbook. Not a regulatory summary copy-pasted from CMS.gov. A working reference you can use to actually get paid.

The Fundamental Split: Medicare vs Commercial

Here's the thing that almost every billing guide buries in paragraph seven: Medicare and commercial payers now use different code systems for telehealth. This is the single most important fact to understand.

• Medicare: Continues to use traditional Evaluation and Management (E/M) codes (99202-99215) with modifiers 95 or 93 to indicate telehealth delivery. Place of service codes 02 or 10 are also required
• Commercial payers: Have largely adopted the new 98000-98016 CPT code series, which are telehealth-specific codes that replace E/M codes for virtual encounters

The New 98000 Series Explained

The 98000 series was introduced to standardize telehealth billing for commercial payers. It separates visits by modality (audio-video vs audio-only) and by patient status (new vs established).

Audio-Video Visits (New Patient)

• 98000: Straightforward, low-complexity (~15 min)
• 98001: Low complexity (~30 min)
• 98002: Moderate complexity (~45 min)
• 98003: High complexity (~60 min)
• 98004: Very high complexity (~75+ min)

Audio-Video Visits (Established Patient)

• 98005: Straightforward (~10 min)
• 98006: Low complexity (~20 min)
• 98007: Moderate complexity (~30 min)
• 98008: High complexity (~40 min)
• 98009: Very high complexity (~55+ min)

Audio-Only Visits

• 98010-98012: New patient audio-only visits by complexity
• 98013-98015: Established patient audio-only visits by complexity
• 98016: Brief virtual check-in (5-10 min)

Medicare Telehealth Billing in 2026

Medicare preserved the E/M code structure but layered on multiple required elements. Missing any one of them will get your claim denied or downcoded.

1. The E/M code itself: 99202-99205 for new patients, 99211-99215 for established patients, chosen by complexity or time
2. Telehealth modifier: 95 for audio-video visits, 93 for audio-only (when allowed by Medicare)
3. Place of service code: 02 if the patient was located in a healthcare facility, 10 if they were at home
4. Documentation: Must indicate the visit was conducted via telehealth, patient location, and whether synchronous audio-video or audio-only was used

Audio-Only Coverage Is Limited

Medicare covers audio-only telehealth for specific services, primarily behavioral health and select E/M services when the patient can't use video. Modifier 93 indicates audio-only delivery. Check your specific service type; audio-only coverage is not universal.

State Medicaid: The Third System

Medicaid is effectively a third billing system. Each state sets its own telehealth rules, coverage, and code requirements. Some states follow Medicare's E/M approach. Others have adopted the 98000 series. Many have their own state-specific modifiers or place-of-service requirements.

If you bill Medicaid in multiple states, you need state-specific configurations for every state you serve. A national Medicaid billing approach does not work.

The Decision Framework

When you're about to submit a telehealth claim, ask these questions in order:

1. Who is the payer? Medicare → use E/M codes + modifiers. Commercial → use 98000 series. Medicaid → check state rules
2. Was it audio-video or audio-only? This determines modifier (93 vs 95) for Medicare, and which 98000 subcode for commercial
3. Is this a new or established patient? Determines the specific code within the series
4. What was the complexity or time? Drives the specific code (98001 vs 98002 vs 98003)
5. Where was the patient located? Drives place of service code (02 vs 10) for Medicare

Common Billing Mistakes That Cost You Money

• Using 98000 codes for Medicare: Medicare will reject the claim. You must use E/M + modifier
• Using E/M codes for commercial payers that require 98000: The commercial payer will either reject or downcode, reducing your reimbursement
• Forgetting the place-of-service code: Medicare claims without POS 02 or POS 10 on telehealth services get rejected
• Using modifier 95 for audio-only: Audio-only requires modifier 93 (when covered). Using 95 is incorrect documentation
• Insufficient documentation of the modality: 'Virtual visit' is not sufficient. Documentation should specify audio-video or audio-only and patient location
• Not verifying payer-specific rules: Assuming all commercial payers follow the same rules. Some still accept E/M codes. Always verify payer-specific policies

What Changed From 2025

If you were billing telehealth in 2025, the main things to know:

• The 98000-98016 series became the commercial payer standard in 2025 and is now fully adopted in 2026
• Medicare extended the expanded telehealth flexibilities (geographic restrictions waived for behavioral health permanently, extended through 2027 for most other services)
• Audio-only coverage expanded for behavioral health under Medicare, but remains limited for other specialties
• More state Medicaid programs added parity requirements for telehealth reimbursement

How to Reduce Claim Denials at Scale

For small practices processing 50-500 telehealth visits per month, manually managing payer-specific coding is feasible but error-prone. For anything beyond that volume, you need infrastructure that automates payer routing.

The right billing infrastructure should: detect the payer type on patient intake, route to the correct code system automatically, validate documentation completeness before submission, and flag visits that may need manual review (audio-only, complex cases, unusual payers).

This is exactly the kind of problem that Thimble Hub's checkout and data routing infrastructure was built to solve. Correct codes routed to the correct payer, automatically, from the moment a patient books.