Modifier 95 vs Modifier 93: Telehealth Billing Rules for Mental Health Providers in 2026

Danielle Wagar
Jun 9
8 min read

If you are a solo therapist, LCSW, LPC, LMFT, or PMHNP billing telehealth sessions through insurance, there are two modifiers that live at the center of your claims workflow: Modifier 95 and Modifier 93. Getting them confused, or leaving them off entirely, is one of the most consistent sources of telehealth claim denials in mental health billing right now. The distinction between them is not complicated once you understand what each one is actually communicating to the payer, but the consequences of mixing them up are real and they compound quickly across a full caseload.

This post breaks down exactly what each modifier means, when to use it, how to pair it with the correct Place of Service code, and what you need to know about how major commercial payers are handling audio-only coverage in 2026. If you are also navigating the POS 02 versus POS 10 question, this post works as a companion to POS 10 vs POS 02: The Telehealth Billing Code That's Costing Therapists Thousands in Denials, which covers the place of service side of the same equation. If you are still deciding whether insurance panels are worth pursuing at all, Insurance Reimbursement Rates for Therapists in 2026 gives you the actual numbers to make that call.

What These Modifiers Actually Do

A modifier is a two-digit code appended to a CPT procedure code that gives the payer additional context about how a service was delivered. In telehealth billing, the modifier tells the payer whether your session was conducted via live audio and video or by audio only, meaning telephone. This matters because payers apply different coverage rules, reimbursement rates, and documentation requirements depending on the technology used.

Without the correct modifier, the payer has no way to distinguish your video session from an in-person visit, and that creates either a denial or a compliance risk depending on how the claim processes.

Modifier 95: Live Audio and Video Sessions

Modifier 95 applies to synchronous telehealth services delivered through real-time, interactive audio and video technology. When you conduct a therapy session over a HIPAA-compliant video platform and both the audio and video components are active throughout the encounter, Modifier 95 is the correct code to append to your CPT code. So a 60-minute individual therapy session billed as CPT 90837 becomes 90837-95 on your claim.

Two conditions must both be true for Modifier 95 to apply. The session must be synchronous, meaning provider and patient are communicating in real time rather than exchanging recorded messages or asynchronous notes. And both audio and video must be active throughout the visit. If the video drops mid-session and the remainder of the visit continues by phone only, the session technically no longer qualifies for Modifier 95 for that portion of care. This is worth documenting clearly in your session notes.

Modifier 95 is also only valid when used with CPT codes that appear in AMA Appendix P or on the Medicare Telehealth Services List. For mental health providers, the codes you use most frequently, including 90791, 90792, 90832, 90834, 90837, 90839, 90840, and 90853, are all eligible. If you are billing E/M codes such as 99214 for PMHNP medication management, those are also covered when paired correctly with the modifier and the appropriate place of service code.

Modifier 93: Audio-Only Sessions

Modifier 93 applies when a telehealth service is delivered exclusively by telephone, with no video component. The session must still be synchronous, meaning it is a live real-time phone call rather than a voicemail or recorded interaction, but there is no video requirement. If your patient cannot access video technology, declines the video component, or is calling from a location where video is not feasible, and you conduct the session by phone alone, Modifier 93 is the correct modifier.

For mental health providers specifically, audio-only telehealth has received meaningful

protection in federal policy. The Consolidated Appropriations Act, 2026 extended Medicare audio-only coverage through December 31, 2027, and behavioral health has permanent carve-out status that predates this extension. The reasoning is straightforward: many mental health patients face real barriers to video access, whether due to technology limitations, housing instability, or privacy concerns, and eliminating audio-only coverage entirely would create significant access gaps for vulnerable populations.

That said, audio-only does not mean audio-only is always reimbursable. Medicare supports it for behavioral health with Modifier 93 clearly documented. Commercial payers are a more complicated story, and that distinction matters significantly for your practice.

The Commercial Payer Problem with Audio-Only

Medicare's position on audio-only behavioral health is clear and relatively provider-friendly. Most commercial payers are considerably less generous. As of 2026, Aetna's commercial policy does not reimburse audio-only services billed with Modifier 93. Cigna's commercial virtual care policy has restricted audio-only reimbursement to specific eligible codes and select clinical scenarios. UnitedHealthcare aligns broadly with Medicare guidance but requires Modifier 93 on audio-only claims and uses its own eligible code list for covered services.

Blue Cross Blue Shield plans vary widely by state, and rules can differ meaningfully between your state's BCBS plan and an out-of-state plan that a patient carries through their employer. This is not a set-it-and-forget-it situation. Payer telehealth policies are updating multiple times per year, and the clinical goodwill earned during the public health emergency has been quietly rolling back on the commercial side for audio-only services specifically. If you are currently credentialed through Alma and billing Aetna specifically, there is a more immediate issue worth knowing about: Aetna Is Cutting Rates for Alma Therapists in 2026 covers what is changing and what the deadline looks like.

The practical implication for your practice is that you should not assume a phone-only session will reimburse under a commercial plan without verifying that payer's current telehealth policy first. For practices where a meaningful portion of the caseload uses audio-only sessions, this verification step belongs in your intake and benefits workflow, not as an afterthought after a denial.

Pairing Your Modifier with the Correct POS Code

Neither modifier operates in isolation. Every telehealth claim also requires the correct Place of Service code, and pairing the wrong modifier with the wrong POS code is one of the most reliable ways to generate a denial.

The rule is straightforward. POS 10 applies when the patient is at home during the telehealth encounter, and it reimburses at the higher non-facility rate. POS 02 applies when the patient is at any other location, such as a clinic, school, or workplace, and it reimburses at the lower facility rate. The modifier you use, either 95 or 93, tells the payer what technology was used. The POS code tells the payer where the patient was located. Both pieces of information are required and they must be internally consistent on the claim.

The combination you will use for the vast majority of outpatient telehealth mental health sessions is Modifier 95 paired with POS 10, because most patients are at home and most sessions are conducted via video. Modifier 93 with POS 10 covers the telephone-only sessions where the patient is at home. Modifier 93 with POS 02 would be the appropriate pairing only for a phone session where the patient is at a location other than their private residence, which is relatively uncommon in outpatient mental health.

One important Aetna-specific note: Aetna's commercial policy does not impose a strict POS 02 or POS 10 requirement as a prerequisite for telehealth reimbursement, so the POS code is less of a denial trigger with that payer than with Medicare or some other commercial plans. Verify current Aetna telehealth guidance against your specific plan before drawing conclusions either way.

What Your Documentation Needs to Cover

Correct modifier and POS code selection protects your claims at submission. Strong documentation protects you in an audit. For every telehealth session billed with Modifier 95 or Modifier 93, your clinical note should confirm the platform used for the session, the patient's location at the time of service, verbal confirmation that the patient consented to telehealth, whether the session was audio-video or audio-only, the start and end times of the session, and your provider location at the time of service.

The platform and modality details are particularly important because they are what justify the modifier selection if a payer requests medical records. A note that simply says "session conducted via telehealth" without specifying the technology gives an auditor nothing to work with and leaves a correctly coded claim exposed to recoupment. If you are also navigating Medicare enrollment alongside commercial credentialing, PECOS vs CAQH: What Is the Difference and When Do You Need Each? explains how documentation and data accuracy requirements differ across those two systems.

A Note on Modifier GT

You may still see Modifier GT referenced in older billing guides or discussed in provider Facebook groups as a video telehealth modifier. GT predates Modifier 95 and was the standard audio-video telehealth modifier before the AMA introduced 95 in 2017. For Medicare Part B professional claims, CMS retired GT in 2018. For most commercial payers, 95 is now the standard and GT is obsolete. The one exception is Critical Access Hospital Method II institutional claims, where GT remains required. If you are a solo or small group outpatient mental health provider, GT does not belong on your claims. If you are still in the early stages of setting up your practice and want to understand how all of these billing systems fit together before you start submitting claims, Your Guide to Choosing the Right Private Practice Model is worth reading first.

Frequently Asked Questions

What is the difference between Modifier 95 and Modifier 93?

Modifier 95 applies to synchronous telehealth sessions conducted with both live audio and video. Modifier 93 applies to synchronous sessions conducted with audio only, meaning telephone without video. Both require the session to be real-time and interactive. The choice between them is determined entirely by the technology present during the visit.

Do I need to use Modifier 95 on every telehealth session?

Only if the session was conducted via live audio-video technology and the CPT code you are billing is eligible for telehealth. If the session was audio-only, Modifier 93 applies instead. If the payer does not require a telehealth modifier for a specific code, appending one can sometimes cause processing issues. Verify your major payers' current requirements and build those rules into your billing workflow rather than applying modifiers uniformly across all claims.

Can I bill audio-only sessions to commercial insurance using Modifier 93?

It depends entirely on the payer. Medicare covers audio-only behavioral health services through 2027 with Modifier 93. Most major commercial payers have restricted audio-only reimbursement as of 2026, and some, including Aetna commercial, do not reimburse audio-only services at all. Before billing audio-only sessions to a commercial plan, verify that plan's current telehealth policy specifically for behavioral health codes.

Does Medicare require an in-person visit for telehealth mental health services?

Technically yes, but enforcement has been delayed until 2028. Federal statute requires an in-person visit within six months before a new Medicare patient's first home-based mental health telehealth service, and at least one in-person visit every twelve months after that.

However, Congress delayed enforcement of these requirements until after December 31, 2027, meaning CMS is not currently acting on non-compliance. Patients who were already receiving behavioral health telehealth services on or before January 30, 2026 are considered established patients and are only subject to the annual visit requirement, not the six-month initial visit rule. This area of policy has moved multiple times and will likely move again, so it is worth monitoring CMS guidance before assuming the current enforcement delay holds indefinitely.

Do I need a physical address even if I only practice via telehealth?

Yes. Payers require a valid physical location to complete your credentialing profile and process your enrollment, regardless of whether you ever see patients in person. A standard Post Office Box does not qualify. Virtual Providers: You Still Need a Physical Address covers exactly what qualifies and what your options are as a fully remote practice.

What happens if video drops mid-session and I finish by phone?

Strictly speaking, if the video component fails and the remainder of the session is audio-only, the entire session does not qualify for Modifier 95 as billed. The correct approach is to document what happened in your session note, including when the video dropped and how the session continued. In practice, many providers bill the session under whichever modality was in place for the majority of the encounter, but this is a gray area worth discussing with your biller. Consistent, clear documentation of the technical circumstances gives you the best protection.

Telehealth billing for mental health is genuinely one of the more forgiving specialties when it comes to payer coverage, but that advantage evaporates quickly when the modifier and POS code do not match what actually happened in the session. If you want to make sure your telehealth claims are coded correctly from intake through submission, book a strategy call and we can walk through your current workflow together.