Modifier 93 vs. 95 for Telehealth: The Billing Detail That’s Costing Behavioral Health Practices Real Money

Across the roughly 50 behavioral health practices we work with at Revenant Care Group, one of the most consistent sources of avoidable claim denials in 2025 and into 2026 is the misapplication of telehealth modifiers 93 and 95. These two modifiers look interchangeable on the surface. They are not, and payers are increasingly programmed to reject or downcode claims where the modifier does not align with the service delivery method, the place of service code, and the payer’s specific telehealth policy. Getting this wrong is not a one-claim problem. On a panel of 300 weekly telehealth visits, a systematic misapplication of these modifiers can generate $8,000 to $15,000 in monthly denied or downcoded revenue before you even start counting secondary payer impact.

This post is a working reference for behavioral health CFOs and RCM directors who want to stop the bleed. We are going to walk through what each modifier actually means, how payers are adjudicating them in 2026, which CPT codes are most affected, and what our billing team watches for when we audit a new client’s telehealth claims.

What Modifier 95 Actually Means and When to Use It

Modifier 95 indicates that a service was delivered via synchronous telemedicine, meaning real-time audio and video communication. CMS established this modifier specifically for Medicare and it has been adopted broadly by Medicaid managed care plans and commercial payers. The operative word is synchronous, and the operative technology requirement is two-way audio-visual. When you append modifier 95 to a claim, you are telling the payer that the clinician and the patient were face-to-face via live video at the time of service.

For Medicare, modifier 95 is paired with Place of Service 02 (POS 02) when the patient is located at a healthcare facility, or POS 10 when the patient is located at their home. The POS 10 designation became permanent for Medicare telehealth following the Consolidated Appropriations Act of 2023, and most commercial payers have followed suit for 2026 plan years. The most frequently billed behavioral health CPT codes under modifier 95 include:

• 90837 (psychotherapy, 60 minutes)
• 90834 (psychotherapy, 45 minutes)
• 90832 (psychotherapy, 30 minutes)
• 90847 (family psychotherapy with patient present)
• 99213, 99214 (E/M office visits when delivered via telehealth by a psychiatrist)
• H0004 (behavioral health counseling, SUD-focused)

What Modifier 93 Actually Means and When to Use It

Modifier 93 is newer and narrower in scope. CMS introduced it effective January 1, 2023, to designate synchronous telehealth services delivered using audio-only technology. This is the modifier you append when a patient does not have access to video, refuses video, or when the technology on either end does not support two-way video. The clinical service itself must still be synchronous, meaning real-time communication, but the modality is telephone only.

The coverage landscape for modifier 93 is more complicated than for modifier 95. Medicare covers audio-only telehealth for certain behavioral health services through the end of 2024 flexibilities extended by the American Relief Act of 2025, with Congressional extensions carrying some audio-only coverage into 2026, but the covered service list is narrower than video telehealth. Behavioral health services where audio-only coverage has remained relatively stable include psychotherapy codes 90832, 90834, and 90837, as well as psychiatric evaluation codes 90791 and 90792, when billed by qualified mental health professionals. However, coverage is payer-specific and plan-specific. We routinely see Medicaid fee-for-service cover modifier 93 claims that a managed care organization for the same state will deny outright.

The single most common modifier 93 billing error we correct in new client audits is the use of POS 02 instead of POS 10 on an audio-only claim for a patient receiving services at home. That pairing triggers an automatic system denial at most payers because POS 02 implies an originating site that is a healthcare facility, and audio-only telephone services to a patient’s home should carry POS 10.

Where the Confusion Creates Denials: The Four Most Common Errors

The pattern we see at practices that are managing telehealth billing without specialized behavioral health RCM support breaks down into four specific error types:

• Modifier 95 on audio-only claims. A clinician documents a phone call. The biller defaults to modifier 95 because it is in the system template. The payer’s system flags the mismatch between the documented service type and the modifier, and the claim denies. Recovery rate on these corrected and resubmitted claims is approximately 78 to 85 percent when corrected within the payer’s timely filing window.
• Modifier 93 on video visits. Less common but it happens, particularly when billing staff rotate. This results in downcoding rather than denial at some payers, particularly those that reimburse audio-only at a reduced rate compared to video. The revenue loss per claim is typically 15 to 22 percent of allowed amount.
• Wrong POS paired with either modifier. POS 02 with modifier 93 on a home-based audio-only visit, as described above, is the most frequent. POS 11 (office) used on telehealth claims at payers that require POS 02 or POS 10 is another consistent error we find in initial audits.
• Modifier stacking errors on add-on codes. When billing 90837 with add-on code 90785 (interactive complexity) via telehealth, both codes need the modifier appended in the right sequence. Practices frequently omit the modifier from the add-on code, which creates a line-item mismatch that some payers use to deny the entire claim rather than just the add-on.

Payer-Specific Rules That Override the Standard Logic

Federal guidelines set the floor, but commercial payers and Medicaid managed care organizations build their own telehealth policies on top of them, and behavioral health is where those policies diverge most aggressively. We have seen BCBS plans in the same state operate with completely different audio-only coverage rules depending on whether the patient has an HMO or PPO product. Aetna and Cigna have issued 2026 telehealth policy updates that tighten video verification requirements for certain behavioral health CPT codes, meaning a claim with modifier 95 may now require documentation that the video platform used is HIPAA-compliant and that video was active for the entire session duration.

This payer-specific complexity is exactly the environment where MHPAEA parity protections become operationally important. If a payer is covering the same CPT code at a higher reimbursement rate for video versus audio-only in a way that creates a meaningful disparity with how analogous medical services are covered, that may represent a parity violation worth appealing. Our team has written about this in detail: how behavioral health practices are leaving money on the table through unaddressed MHPAEA parity violations.

What a Corrected Telehealth Modifier Audit Actually Returns

When we onboard a behavioral health practice that has been managing telehealth billing internally or with a generalist billing company, the first 90-day audit of telehealth modifier errors typically identifies recoverable revenue in the range of $12,000 to $45,000 depending on practice size and telehealth volume. For a mid-size outpatient behavioral health group seeing 400 to 600 telehealth visits per month, systematic modifier misapplication across a 12-month lookback period has produced recoverable amounts exceeding $80,000 in several client engagements. These are not theoretical numbers. They represent actual corrected claims, resubmissions, and appeals that converted to paid status.

For SUD practices specifically, the telehealth modifier problem compounds with other coding issues. Practices that are also under-coding drug screens alongside telehealth modifier errors are often leaving revenue on multiple fronts simultaneously. If your practice bills G0480 through G0483, we have covered the drug screen coding gap separately: why most SUD practices are under-coding and leaving 4.5x revenue per test.

What Your Billing Team Should Audit This Week

If you want a starting point before engaging outside support, pull the last 90 days of telehealth claims and filter by modifier. Look at every claim carrying modifier 95 and confirm the documentation specifies two-way video. Look at every claim carrying modifier 93 and confirm POS 10 is on the claim if the patient was at home. Pull your denial reason codes 4 and CO-4, CO-5, and CO-97, which commonly appear on telehealth modifier mismatches, and quantify the total denied amount by modifier type. That 30-minute exercise will tell you whether this is a $3,000 problem or a $30,000 problem.

If you want a team that has already built that audit into a structured process, we offer a free 30-day denial audit for behavioral health and SUD practices. No obligation, and the findings are yours to keep. Book a time on our calendar here and we will walk you through what we find in your claims data within the first week.