POS 02 vs 10 vs 11 in 2026: Telehealth Coding After the PHE Cliff

Before the COVID public health emergency, POS coding was a one-line decision. The patient was in the office, you billed POS 11 and the claim paid at the non-facility rate. The patient was in the hospital outpatient department, you billed POS 22 and the claim paid at the facility rate. Telehealth was a thin slice of services billed by a tiny minority of practices. The PHE flipped this overnight. By 2021, every specialty was billing telehealth, and CMS had created POS 10 to distinguish patient-at-home telehealth from POS 02 patient-not-at-home telehealth. The reimbursement difference between the two is significant. POS 02 pays at the facility rate, which runs 10 to 25 percent below the non-facility rate. POS 10 pays at the non-facility rate, matching what the same E/M code would pay if performed in office. The choice is not stylistic. Selecting the wrong POS undervalues the claim by $15 to $50 per encounter on E/M codes alone. On a behavioral health practice billing 200 telehealth visits per month, the difference between consistent POS 10 and accidental POS 02 reaches $40,000 per year in unrecovered revenue. The PHE-era flexibilities expired in 2024, but the POS rules CMS finalized in CY 2025 and CY 2026 remain in force. Most practices have not updated their workflows to match. The result is silent revenue leak that practice owners never see because the claim pays. It just pays at the wrong rate.

POS 11 means office. The patient was physically present in the practice's office space and the service was delivered in person. This is the default for any in-office encounter, in-office procedure, or in-office E/M visit. Reimbursement is at the non-facility rate, which includes practice expense RVUs to compensate the practice for overhead. POS 02 means telehealth provided other than in patient's home. The patient was at a remote site that is not their home (a school, a workplace, a clinic, a community center, an originating site like a critical access hospital) and the service was delivered via interactive audio video. POS 02 pays at the facility rate, which excludes the practice expense component. The rationale is that the originating site, not the distant site provider, bears the overhead cost. POS 10 means telehealth provided in patient's home. The patient was physically located at their place of residence and the service was delivered via interactive audio video. POS 10 pays at the non-facility rate, matching in-office reimbursement. The CMS rationale for POS 10 paying at the higher rate is that home-based telehealth still requires the distant site provider to maintain office overhead, technology infrastructure, and clinical staff. POS 12 means home, used for in-person home visits (house calls). POS 22 means on-campus outpatient hospital. POS 19 means off-campus outpatient hospital. POS 53 means community mental health center. POS 50 means federally qualified health center. POS 71 means state or local public health clinic. The two codes that cause the most billing errors in 2026 are POS 02 and POS 10. Practices that default to POS 02 for all telehealth (the PHE-era habit) leave non-facility-rate dollars on the table. Practices that default to POS 10 for all telehealth, including non-home telehealth, get audited.

Where is the patient at the time of service. If the patient is in the practice's office, use POS 11 and add no telehealth modifier. If the patient is at home, use POS 10. If the service was synchronous video, append modifier 95. If the service was audio-only and the payer accepts audio-only telehealth (Medicare for behavioral health and a subset of E/M codes, most state Medicaid programs, most commercial payers for behavioral health), append modifier 93. If the patient is not at home but is at a remote site (workplace, school, community location, critical access hospital), use POS 02. Modifier 95 applies if synchronous video, modifier 93 if audio only. If the patient is in their home for a non-telehealth in-person home visit, use POS 12. If the patient is in a hospital outpatient department, use POS 22 (on campus) or POS 19 (off campus). If the patient is in a community mental health center, use POS 53. The ambiguous cases that produce most denials. Patient at a senior living facility. CMS treats most senior living as the patient's home for telehealth purposes (POS 10). Some commercial payers treat skilled nursing as a facility (POS 31) and assisted living as home (POS 10). Verify by payer. Patient at work. Workplace is not the patient's home. Use POS 02. Patient in a hotel room while traveling. Hotel is not the patient's home. Use POS 02. Patient in a parking lot using their phone. The patient is not in a structured location. Use POS 10 if the parking lot is at their residence, POS 02 otherwise. Use the [decision table from our telehealth coding guide](/blog/telehealth-coding-2026-after-phe-cliff) for additional edge cases.

The Medicare Physician Fee Schedule assigns each CPT code a non-facility rate and a facility rate. The non-facility rate includes practice expense RVUs that compensate the practice for office overhead, support staff, technology infrastructure, and clinical equipment. The facility rate excludes most of these practice expense RVUs because the assumption is that the facility bears the overhead. For 99213, the 2026 non-facility rate is $95.19 and the facility rate is $63.92. The difference is $31.27 per encounter. For 99214, the gap is $135.61 versus $96.34, a $39.27 difference. For 99215, the gap is $192.39 versus $137.84, a $54.55 difference. The CY 2025 final rule clarified that POS 10 (patient home) pays at the non-facility rate because the distant site provider maintains the practice overhead even when the patient is remote. POS 02 (patient not at home) pays at the facility rate because the originating site is presumed to bear the overhead. For specialties with high telehealth volume (behavioral health, primary care, dermatology, endocrinology), this difference compounds dramatically. A behavioral health practice billing 90837 (60-minute psychotherapy) at 200 sessions per month with consistent POS 10 collects $43,860 per month at the 2026 Medicare rate. The same volume billed POS 02 collects $36,460. The annual gap is $88,800 on a single CPT code. Practices submitting telehealth claims should run a quarterly audit of POS 02 versus POS 10 distribution and confirm each POS 02 claim was actually performed at a non-home site.

The two telehealth modifiers that matter in 2026 are 95 and 93. Modifier 95 means synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system. This is the standard modifier for video telehealth and applies whenever audio video is the service modality. Modifier 93 means synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. This is the audio-only modifier. Coverage of audio-only varies. Medicare covers audio-only for behavioral health services year-round (90791, 90792, 90832, 90834, 90837, 90839, 90840, 90846, 90847, 90853, and related codes) without site restrictions. Medicare covers audio-only for a subset of E/M codes only when the patient cannot or will not use video. Most commercial payers cover audio-only behavioral health, with reimbursement typically 70 to 100 percent of the audio-video rate depending on the payer contract. Most state Medicaid programs cover audio-only behavioral health. Modifier GT was deprecated by CMS in 2017 but persisted in legacy commercial payer systems for years afterward. As of 2026, GT should not appear on any new claim. Some commercial systems still accept it without rejection, but its use signals an outdated billing process. New telehealth modifiers FQ (audio-only telehealth) and FR (substitute for clinic-only audio video) are used in specific Medicaid programs and federally qualified health center scenarios. For commercial and Medicare claims, 95 and 93 cover almost every telehealth case. Modifier choice does not affect POS coding. POS 10 with modifier 95 is the most common telehealth claim configuration in 2026. POS 10 with modifier 93 is the second most common. POS 02 with modifier 95 covers non-home video telehealth. POS 02 with modifier 93 covers non-home audio-only telehealth, an unusual configuration that warrants chart review.

Behavioral health is the largest beneficiary of POS 10 plus modifier 95 reimbursement parity. Medicare requires POS 10 with modifier 95 for video psychotherapy and modifier 93 for audio-only psychotherapy. Aetna, UHC, BCBS, and Cigna all reimburse behavioral health telehealth at parity with in-office rates when POS 10 is used. The behavioral health practices that win on revenue document the patient's home location explicitly in the chart and confirm POS 10 on every claim. Primary care telehealth coverage for E/M codes ramped down after the PHE expiration. Medicare permanently covers a limited set of E/M codes via telehealth (annual wellness visits remain in person only, most office visits require POS 11 with in-person service). Commercial payer coverage of primary care telehealth varies widely and depends on the contracted plan and state telehealth parity laws. Dermatology uses telehealth for follow-up visits, lesion review, and post-procedure check-ins. POS 10 applies for home-based teledermatology. Live video is preferred over store-and-forward for reimbursement parity. Endocrinology runs telehealth diabetes management visits at high volume. Connected glucose monitor data feeding into 99457 RPM codes layers on top of telehealth E/M visits for substantial monthly revenue. Cardiology telehealth covers post-procedure follow-up, AFib management, and heart failure monitoring. POS 10 with modifier 95 is standard. Substance use disorder treatment leverages telehealth heavily for medication-assisted treatment maintenance visits. CFR 42 Part 2 confidentiality rules add documentation requirements but do not change the POS code. Each specialty should run a telehealth POS audit at least quarterly. Our [behavioral health billing guide](/blog/behavioral-health-billing-complete-guide) and [telehealth billing 2026 guide](/blog/telehealth-billing-guide-2026) cover specialty-specific edge cases.

Run a CPT-by-POS report from your practice management system for the past 90 days. Filter for telehealth-eligible codes. The list includes the E/M codes 99202 to 99215, the behavioral health codes 90791 through 90853, the RPM codes 99457 and 99458, and any specialty-specific telehealth codes you bill. Group by POS code. Calculate the percentage of claims billed under POS 02, POS 10, and POS 11. For practices that have transitioned to home-based telehealth as the dominant modality, expect POS 10 to dominate POS 02 by a 5 to 1 ratio or higher. If POS 02 is more than 25 percent of total telehealth claims, audit the chart documentation on a sample to confirm the patient was actually at a non-home location. The most common error pattern is provider habit. Providers who started billing POS 02 during the PHE often continue defaulting to POS 02 even when the patient is at home. Updating the EHR template default from POS 02 to POS 10 catches this pattern at the source. The second most common error pattern is incorrect modifier-POS pairing. POS 11 with modifier 95 is incorrect (POS 11 means in-office, modifier 95 means telehealth). POS 10 without any telehealth modifier is incorrect (POS 10 means home telehealth, which requires either 95 for video or 93 for audio). Run the audit, identify the error patterns, and update your charge capture rules. The recovered revenue from a single audit cycle typically exceeds $20,000 for a practice billing 100-plus telehealth visits per month. Larger practices recover six figures from a single audit. For ongoing POS audit and revenue recovery support see our [A/R recovery service](/medical-accounts-receivable-services).