The rapid adoption of telehealth has revolutionized how healthcare services are delivered, improving access for patients and expanding practice opportunities for clinicians. Yet, as convenient as virtual care can be, it has introduced a new layer of complexity when it comes to billing and reimbursement. Regulations continue to evolve, payer rules differ widely, and proper coding requires constant vigilance. Understanding how to manage these factors is now essential for any practice offering remote care.

This guide provides a clear overview of the most common billing challenges, outlines key regulatory considerations, and shares strategies that can help healthcare organizations maintain compliance while ensuring fair reimbursement.

Common Billing Challenges in Telehealth

While telehealth improves patient engagement, it also brings distinct administrative hurdles. Among the most frequent issues are:

Constantly Changing Rules: Regulations governing telehealth reimbursement are fluid. Federal and state policies — including those from the Centers for Medicare & Medicaid Services (CMS) — are periodically revised, meaning billing teams must continuously track updates to avoid compliance problems. What was acceptable one year may no longer qualify for reimbursement the next.

Inconsistent Payer Policies: Because there is no unified standard for telehealth billing, every payer has its own rules. Medicare, Medicaid, and commercial insurers often differ in how they define covered services, which modifiers they require, and what rates they reimburse. This inconsistency often leads to confusion and claim denials if not managed carefully.

Detailed Coding Requirements: Accurate coding is critical in telehealth. Specific Place of Service (POS) codes and modifiers — such as POS 02, POS 10, and modifiers 95 or GT — determine how a claim is processed. A simple omission or error in these elements can delay or prevent payment altogether.

Comprehensive Documentation: Thorough documentation remains a cornerstone of compliance. Each encounter should clearly describe the communication method (video, phone, or asynchronous), the duration of the visit, patient consent, and justification of medical necessity. Missing or vague documentation is one of the top reasons telehealth claims are denied.

Understanding the Regulatory Environment

Federal and state policies continue to define how virtual care is billed. During the COVID-19 pandemic, several temporary flexibilities allowed broader telehealth coverage. Many of these measures, however, are scheduled to expire unless renewed by Congress.

The 2025 “Telehealth Policy Cliff”: If no legislative action is taken by September 30, 2025, pre-pandemic telehealth restrictions may resume. This could limit reimbursement for in-home visits, restrict telehealth coverage to rural areas, and reduce the range of eligible providers. Additionally, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) would no longer qualify as distant site providers after 2024 — changes that could significantly affect patient access.

Recent CMS Billing Updates: CMS continues refining billing procedures through updates to the Physician Fee Schedule (PFS). Recent updates have emphasized:

• Using modifier 95 with appropriate hospital POS codes for telehealth services.
• Recognizing POS 10 (patient’s home) as eligible for slightly higher reimbursement than POS 02 (outside the home).
• Tightened criteria for Remote Patient Monitoring (RPM), requiring at least 16 days of data collection per 30-day period.
• Allowing audio-only reporting when patients cannot or do not wish to use video, provided modifier 93 is applied.

Strategies for Improving Telehealth Billing Accuracy

To maintain a stable revenue cycle, practices must adopt proactive measures that streamline billing workflows and minimize avoidable denials.

Educate and Update Your Team: Establish an internal system for monitoring payer policy updates. A designated compliance coordinator or billing lead should regularly review CMS publications and insurer bulletins. Continuous training sessions keep staff informed about modifier changes, documentation expectations, and new CPT codes.

Standardize Documentation: Creating structured templates in your Electronic Health Record (EHR) can ensure consistency across providers. Templates should prompt clinicians to record patient consent, visit modality, time spent, and relevant clinical details.

Leverage Automation Tools: Modern billing platforms can automate eligibility verification, code validation, and claims scrubbing. These technologies flag potential issues before submission, reducing administrative workload and preventing denials related to incomplete or incorrect claims.

Analyze and Resolve Denials: Denials should not be treated as isolated incidents. Track them systematically to identify recurring issues by payer or error type. A small, dedicated team that reviews and corrects denied claims can substantially improve turnaround time and revenue recovery.

Preparing for the Future of Telehealth Billing

As virtual care continues to evolve, healthcare organizations should anticipate ongoing regulatory shifts. Preparing early for the 2025 policy changes will be vital. Practices should also participate in advocacy efforts that support permanent telehealth expansion, particularly in areas related to parity in reimbursement and cross-state licensure.

Investing in the right technologies, maintaining clear documentation standards, and prioritizing team education can build a resilient billing infrastructure that adapts to new challenges. For many organizations, partnering with a specialized billing service that understands telehealth intricacies can also optimize compliance and revenue integrity.

Path Forward

At Care Medicus, we recognize that telehealth is no longer a temporary solution—it is an essential component of modern healthcare delivery. To ensure its continued success, providers must take an active role in mastering the complexities of telehealth billing and compliance.

Now is the time to stay informed, organized, and proactive. Invest in systems and partnerships that simplify billing workflows, reduce claim denials, and strengthen financial sustainability. With the right guidance and technology, Care Medicus can help you navigate the evolving regulatory landscape and position your practice for long-term success in the digital era of healthcare.