Behavioral Health and Telemedicine Billing Guide

As healthcare continues to adapt in the wake of recent changes, it’s essential to recognize the impact of regulatory shifts. In 2020, CMS introduced temporary waivers allowing behavioral health providers to conduct initial evaluations and therapy sessions via audio/visual (and even audio-only) communication. This adjustment made it easier for patients to receive care from home, regardless of location, and extended to medication management services (99202–99215).

Key Points of CMS Waivers for Behavioral Health Services During the COVID-19 Pandemic

CMS issued the waivers in 2020, bringing several significant changes to how behavioral health and medical services were provided remotely. These provisions included:

• Real-Time Communication for Behavioral Health: Allowed behavioral health services to be conducted via real-time audio/visual communication or phone only.
• Virtual Office Visits: Permitted office visits through real-time audio/visual communication.
• Documentation Flexibility: Allowed documentation to be treated as if the service was in person when provided through audio/visual or audio-only technology.
• Medication Management Coverage: Paid for telephone codes 99441, 99443 at the same rate as office visits 99212—99215 for medication management.
• Location Requirements: During service delivery, the patient and clinician must be located within the U.S.
• Modifier Reporting: Modifier FQ is required for audio-only behavioral health services.
• Reporting in RHC/FQHC: In Rural Health Clinics (RHCs) or Federally Qualified Health Centers (FQHCs), corresponding HCPCS codes were used for reporting services. Reporting on a UB claim form did not allow for modifiers (revenue code 780 indicates telehealth services can be input).

Overview of Behavioral Health Services and Telemedicine Post-PHE (2023-2025)

As of May 23, 2023, the end of the Public Health Emergency (PHE), CMS continues to allow behavioral health services for Medicare patients via real-time audio/visual technology or audio-only communication. The Consolidated Appropriations Act (CAA) of 2021, which permanently established telehealth for behavioral health services as a Medicare benefit, made this possible.

Key Provisions of the Consolidated Appropriations Act, 2021

• Telehealth for Behavioral Health: Behavioral health services can be provided to patients in their homes via real-time audio/visual communication or phone only, regardless of location.
• Location Requirement: When services are delivered, the patient and clinician must be located in the U.S. (including U.S. territories).
• Reporting in RHC/FQHC: Services are reported using corresponding HCPCS codes in rural health clinics (RHCs) and Federally Qualified Health Centers (FQHCs).
• Audio-Only Modifier: Modifier FQ is required for audio-only behavioral health telehealth services (consult with your MAC, as modifier 93 may also be used for audio-only services).

Medication Management Changes Starting in 2025

• Audio-Only Medication Management: CMS will allow medication management (office visits) for behavioral health services via audio-only if certain conditions are met:
  • Patient-driven choice
  • Based on the patient's technological limitations and preferences
  • Comfort with using video technology in their home
• Flexibility on "Home" Definition: CMS does not have a strict definition of "home" and recognizes that patients may not have access to a private living space or prefer to use alternative locations like a car for privacy.

Changes to CPT Codes

• Effective January 1, 2025, CPT codes 99441-99443 will be deleted. Instead, E/M codes (99202-99215) can be reported using the 93 or FQ modifier for audio-only services.

Additional Requirements for Behavioral Health Telemedicine Services

To maintain compliance with CMS telehealth policies for behavioral health services, providers must be aware of the following ongoing requirements:

Technology Readiness

If the service is provided via audio-only, the practitioner must still be able to offer real-time audio/visual technology if needed.

Initial In-Person Visit

The patient must have had a face-to-face visit with the clinician (or another clinician of the same specialty in the same group) within six months before starting telehealth services.

• Exceptions: This requirement does not apply to patients receiving treatment for substance use disorders or those living in geographically underserved areas.

Annual In-Person Requirement

Patients must be seen in person at least once every 12 months.

• Per the 2025 Physician Fee Schedule (PFS) Final Rule, this rule has been delayed until January 1, 2026.
• If an in-person visit does not occur, the reason must be documented in the patient's medical record, citing that it is "inadvisable or impractical" for the beneficiary.

CMS-Approved Telehealth Services for Behavioral Health in 2025

The following behavioral health services remain on CMS’s approved telehealth list for 2025, ensuring continued access and flexibility in care delivery:

• Psychiatric Diagnostic Evaluation: 90791, 90792
• Psychotherapy: 90832, 90833, 90834, 90836, 90837, 90838
• Psychotherapy for Crisis: 90839, 90840
• Interactive Complexity: 90785
• Psychoanalysis: 90845
• Family Therapy: 90846 (without patient), 90847 (with patient)
• Group Therapy: 90853
• Evaluation and Management (E/M) Services for Medication Management: 99202, 99215
• Hospital Services: Initial, subsequent observation, and discharge visits
• CMS also permits billing for other behavioral health assessment and intervention codes via telemedicine, expanding opportunities for virtual care across various settings.

Behavioral Health Telemedicine & Private Payers Codes

During the public health emergency (PHE), most commercial payers expanded their telehealth coverage to include psychotherapy and other behavioral health services. Many of these flexibilities have continued post-PHE, but policies differ by payer, so providers must confirm specifics with each insurance company.

Place of Service (POS) Codes

• POS 02: Telehealth provided outside the patient’s home
• POS 10: Telehealth provided in the patient’s home

Common Telehealth Modifiers

• Modifier 93: Audio-only real-time communication
• Modifier 95: Audio/visual real-time communication
• Modifier FQ: Audio-only behavioral health services

Simplify Your Behavioral Health Billing with BillingFreedom’s Telehealth Solutions

At BillingFreedom, we specialize in providing comprehensive mental health billing services tailored to meet your practice's unique needs. With telehealth becoming a key component of behavioral health care, our team ensures that your practice stays ahead of the latest billing regulations, including updates to CPT codes and telehealth modifiers. We navigate complex billing systems to provide accurate claim submissions and maximize reimbursements for telehealth services, including psychiatric evaluations, psychotherapy, and medication management.

Our experienced billing professionals are well-versed in the waiver guidelines and evolving telehealth requirements, ensuring seamless claim processing for audio-visual and audio-only telehealth services. By partnering with BillingFreedom, you can focus on providing exceptional care while we handle the intricacies of mental health billing, ensuring timely and accurate payments. Trust us to streamline your billing process and increase your practice’s revenue with our dedicated support.

For more details about our exceptional mental health billing services, please don't hesitate to email us at info@billingfreedom.com or call us at +1 (855) 415-3472. 

Your financial tranquillity is our priority!