Telehealth Billing Policy Updates

I would like to thank Dr. Jim Broyles and the Ohio Psychological Association for their leadership and ongoing work in helping provide guidance on this important issue. Their efforts to clarify evolving telehealth policies have been a valuable resource for behavioral health providers navigating these changes.

Telehealth coverage for behavioral health services continues across major payers serving Ohio. I received a lot of communication in 2025 from professional counselors in the field having difficulties with denials around which place of service (POS) they should use when billing telehealth. Below is a summary of publicly available telehealth policy language from several insurers. Because billing requirements vary by contract and plan type, counselors are strongly encouraged to verify telehealth reporting expectations within their specific payer agreements.

Place of Service (POS) Designation

For telehealth services, two Place of Service (POS) codes developed by the Centers for Medicare & Medicaid Servicesare are commonly referenced:

• POS 02: Indicates the client is located somewhere other than their home.

• POS 10: Indicates the client is in their home at the time of service.

These codes reflect the client’s physical location and must align with documentation of service modality. Because modifier requirements and overall billing expectations vary by insurer and by individual contract, counselors should review their specific payer agreements to confirm telehealth reporting requirements. Below is publicly available information related to private, state, and federal insurers that have offered guidance on place of service designation:

Private Insurance Plans

Aetna

Telehealth coverage for behavioral health services continues when delivered via audio and visual connection. Current policy materials do not specifically address Place of Service (POS) code selection. Public guidance references the use of modifier 95 for telehealth services. Medicare Advantage products align with current Medicare telehealth guidelines.

Anthem Blue Cross Blue Shield

Telehealth coverage continues. Policy references indicate use of Telehealth POS codes 02 (client located other than home) or 10 (client located in home). Both audio-video and audio-only connections may be recognized under plan guidelines, with modifiers referenced in policy materials.

Cigna

Telehealth psychotherapy services remain covered. However, psychological testing codes are not included among covered telehealth services, making verification important for assessment-focused practices. Policy references indicate POS 02 or 10 for telehealth, with both audio-video and audio-only modalities addressed in plan guidance.

Medical Mutual of Ohio

Written policy states:

“The Company considers services that are defined by the Centers for Medicare & Medicaid Services (CMS) as telehealth services to be eligible for reimbursement when reported using the

Place of Service (POS) code 02 (telehealth provided other than in patient’s home) or the POS code 10 (telehealth provided in patient’s home).” The policy further notes that modifier GT is recognized, though not required, for reporting telemedicine services.

Optum

Telehealth coverage continues for behavioral health services. Public guidance references POS 02 or 10 and addresses both audio-video and audio-only service delivery. Medicare Advantage products follow similar telehealth parameters. The prior requirement to attest to telehealth training has been discontinued.

Federal & State Programs

Medicare

Under guidance from the Centers for Medicare & Medicaid Services, telehealth services continue to utilize POS 02 or 10 based on client location. Modality-specific reporting and coverage parameters may vary by contractor.

Ohio Medicaid

The Ohio Department of Medicaid continues to recognize telehealth services within the licensed professional counselor scope of practice. Counselors should review the most current Ohio Medicaid telehealth billing guidance for updated requirements.

Recent State and Federal Developments

Recent updates at both the state and federal levels reinforce the importance of ongoing review. Ohio enacted Senate Bill 95 (effective April 9th, 2025), directing the Ohio Department of Medicaid to establish telehealth payment standards and explicitly recognizing licensed professional counselors among eligible practitioners for Medicaid reimbursement. Updated Ohio Medicaid telehealth billing guidelines effective 2026 also clarify reporting expectations, while allowing managed care organizations to maintain plan-specific requirements. At the federal level, the Centers for Medicare & Medicaid Services continues to adjust Medicare telehealth policy, with behavioral health services retaining broader flexibility than some other medical services, though contractor-specific guidance may vary. These developments underscore the importance of reviewing both statutory updates and individual payer contracts when confirming telehealth reporting requirements.

Ongoing Monitoring

The Insurance Advocacy Committee will provide updates as additional information becomes available. If you encounter telehealth-related denials or inconsistencies, please notify the Committee so we can identify trends and advocate for clarity and parity on behalf of Ohio counselors.

References

Ohio Psychological Association. (2023, September 20). Telehealth coverage update. https://ohpsych.org/blogpost/1567785/493773/Telehealth-Coverage-Update

Ohio Psychological Association. (2022, February 25). POS code developed by the Center for Medicare and Medicaid Services. https://ohpsych.org/blogpost/1567785/451129/POS-code-developed-by-the-Center-for-Medicare-and-Medicaid-Services

Ohio Department of Medicaid. (2025). Telehealth billing guidelines updates for 2025. https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Providers/Billing/BillingInstructions/Telehealth_Billing_Guidelines_updates_for_2025.pdf