Telehealth Coverage Extended, Meaning the Need to Get it Right Becomes Key

While the coverage of telehealth is definitely a good thing, it has caused needless confusion. I would like to address a little of that today.  

First, repeating what Cate Brantley and Adam Brennan from Zelis have reported, we can now rely on Medicare telehealth coverage through the end of 2027. But when providing telehealth, organizations often struggle with a variety of basic questions.

Perhaps the biggest is determining the location of the service. If the physician is at their home, must that home be enrolled? If the patient is in Texas, but the physician is in Florida, which Medicare Administrative Contractor (MAC) gets the claim? Because these questions are so basic and so universal, one would think that the answers would be clearly established in regulation by now. But that is not the case.

Hopefully, by now you have heard us say that manuals and FAQs are not binding in the way that a regulation is. The lack of a relevant regulation means that you should never be refunding money simply because you billed a telehealth service using a location someone thinks is improper.  

The absence of regulations is problematic enough, but sadly the guidance the Centers for Medicare & Medicaid Services (CMS) has issued is far from clear. Consider this difficult-to-read sentence:   

“Physicians and/or practitioners should use POS 02 for Telehealth Provided Other than in Patient’s Home or POS 10 for Telehealth Provided in Patient’s Home (which is a location other than a hospital or other facility where the patient receives care in a private residence).” 

It feels like whoever wrote that was doing a Mad Libs puzzle. While it isn’t obvious, if the patient is sitting in their office, a hotel room, or their car when a telehealth service is performed, you would bill POS 10 for “home” because it is “a location other than a hospital or other facility.” Basically, everything other than a “hospital or a facility” is “home.” Perhaps the codes should be “hospital/SNF (skilled nursing facility)” or “outside of a hospital/SNF.” That would be much clearer and understandable.   

That sentence appeared in an FAQ issued by CMS on February 4: https://www.cms.gov/files/document/telehealth-faq-updated-02-04-2026.pdf

Question 15 on the FAQ makes it clear that practitioners can provide telehealth from their home and generally don’t need to report their home address. Basically, if they ever provide services in an office, they can use the office location. I am glad that CMS has adopted this policy, and a quick reminder that it makes a lot of sense, because otherwise physicians could perform telehealth in locations with higher Medicare reimbursement, effectively performing arbitrage. This is why if the patient is in Texas and the professional is in Florida, billing the service in Texas makes sense.   

Finally, a note about all Internet research. If you look at the FAQ, I suggest that you save a PDF of it to your computer. Government links are routinely updated, and the old ones often disappear.

In theory, the Wayback Machine can help you find old versions, but it is not perfect, and it can be a bit of a pain. If you ever rely on Internet postings in any shape, way, or form, I would save a version to your computer in a way that you will be able to find it again.