Telehealth Billing After the Flexibilities Expired

During the emergency period, telehealth billing converged. Rules relaxed in similar directions and one internal approach mostly worked. That convergence has ended, and practices carrying the old habit are generating denials.

Where payers now differ

• Place of service. Which code to use, and whether it should reflect the patient's location or the provider's.
• Modifiers. Which one, whether one is required at all, and whether audio-only needs a different one.
• Audio-only coverage. Some payers cover it, some require video, and some cover it for defined services only.
• Originating site. Whether the patient may be at home, and whether geography matters.
• Service eligibility. Which services may be delivered remotely at all.

The licensure layer

Separately from billing, the provider generally must be licensed where the patient is located. A patient travelling out of state turns a routine visit into a licensure question, and the resulting claim can be denied for reasons that have nothing to do with the telehealth rules.

What a workable process looks like

A per-payer reference recording place of service, modifier, and audio-only position. Patient location captured at the visit rather than assumed. And denial monitoring specifically on telehealth claims, because when a payer changes its position the first signal is a cluster of denials rather than an announcement.

The rules are still moving. Building the per-payer reference is what makes the next change survivable.