Telehealth billing rules for behavioral health changed significantly during and after the COVID-19 public health emergency. Florida providers who set up telehealth billing during the PHE and haven't audited it since are likely billing with outdated place-of-service codes and modifiers — and generating preventable denials.
Current CMS Telehealth Rules for Behavioral Health (2025)
As of 2025, CMS has made permanent several behavioral health telehealth flexibilities. Originating site restrictions for mental health telehealth have been permanently removed — patients can receive behavioral health services via telehealth from their home without a facility-based originating site. This applies to Medicare and influences Florida Medicaid policy.
Place of Service Codes for Telehealth — What to Use in 2025
- ✓POS 02 (Telehealth provided in other than patient's home) — use when the patient is at a location other than their home, such as a school, workplace, or other facility
- ✓POS 10 (Telehealth provided in patient's home) — use when the patient is at home. This distinction matters for Florida Medicaid reimbursement rates and payer-specific rules.
- ✓POS 11 (Office) — do NOT use for telehealth services. Using POS 11 for a remote service is a billing error that creates audit risk.
Modifier Requirements for Telehealth in Florida 2025
- ✓Modifier 95 (Synchronous telemedicine service rendered via real-time interactive audio and video) — the standard telehealth modifier for commercial payers and Medicare
- ✓Modifier GT (Via interactive audio and video telecommunication system) — some Florida Medicaid FFS payers still require GT; verify with AHCA for current requirements
- ✓Do NOT interchange 95 and GT without confirming which the specific payer requires — this is a common CO-4 denial source in Florida behavioral health billing
- ✓Modifier 93 (Audio-only) — for audio-only services when video is not available; Florida Medicaid and commercial payers have different rules for audio-only coverage
Florida MMC Telehealth Policies — What Differs by Plan
- ✓Sunshine Health: covers telehealth for most behavioral health services; uses POS 10/02 distinctions; requires prior auth for same services that require auth in person
- ✓Humana Medicaid Florida: has specific telehealth code lists; not all behavioral health CPT codes are covered via telehealth under Humana; verify against their telehealth approved code list
- ✓Molina Healthcare Florida: has specific modifier requirements that differ from CMS standard; using 95 where Molina requires GT generates CO-4 denials
- ✓Simply Healthcare: follows AHCA guidelines for Medicaid-covered telehealth; commercial telehealth rules apply to their Medicare Advantage products
Documentation Requirements for Telehealth Claims
Telehealth claims are more likely to be audited than in-person claims. Documentation must include: statement that the service was delivered via telehealth, the technology platform used, confirmation that the patient was in Florida at the time of service, documented patient consent for telehealth services (required annually by most Florida payers), and clinical documentation that meets the same standard as in-person services.
Leymax stays current on Florida telehealth billing rules for behavioral health. If your telehealth claims are generating CO-4 or CO-97 denials, request a free audit.
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