Billing Pitfalls in Telehealth Services and How to Avoid Them
A Practical Guide to Avoid Costly Errors in Telehealth Billing
Telehealth has transformed healthcare delivery in the United States, offering physicians and surgeons the ability to extend care to patients across distances. However, while telehealth creates convenience for patients and revenue opportunities for practices, it also introduces a complex layer of billing challenges. Without careful navigation, physicians risk denied claims, revenue leakage, and compliance penalties.
At STAT Medical Consulting Inc., we specialize in helping small groups and solo practitioners streamline their billing processes. In this article, we’ll explore the most common billing pitfalls in telehealth services, the new coding trends shaping reimbursement, and practical ways to avoid costly mistakes.
Why Telehealth Billing Is Complex
Telehealth billing is more than just using the correct CPT codes. It involves:
Rapidly Changing Payer Policies
Medicare and commercial insurers continue to adjust coverage for telehealth.
Place of Service Codes
Virtual visits require different codes than in-person visits.
Modifiers
Billing may require modifier codes (e.g., 95, GT) to specify telehealth delivery.
Documentation Standards
Inadequate charting often leads to denials or audits.
For busy physicians, especially those running solo practices, keeping up with these changes can feel overwhelming.
Common Telehealth Billing Pitfalls
1. Incorrect Use of Telehealth Modifiers
Many claims are denied because providers either omit telehealth modifiers or misapply them. For instance:
- Modifier 95 is commonly used for real-time, interactive telehealth services.
- Specific payers require the modifier GT to indicate telecommunication-based services.
How to Avoid It
Review payer-specific policies before submitting claims, as requirements differ across insurers.
2. Confusion Over Place of Service (POS) Codes
Before 2022, many payers required POS 02 for telehealth. In recent updates, Medicare distinguishes between:
- POS 02: Telehealth provided outside the patient’s home.
- POS 10: Telehealth provided in the patient’s home.
How to Avoid It
Ensure your billing staff or billing service updates POS codes based on the latest CMS and payer guidelines.
3. Failure to Document Time and Method
Payers increasingly deny claims where documentation doesn’t reflect telehealth standards. Missing details include:
- Whether the visit was audio-only or audio-video.
- Start and stop times for time-based services.
- Patient consent for telehealth.
How to Avoid It
Incorporate standardized telehealth documentation templates into your EMR.
4. Not Accounting for New Coding Trends
The 2023 E/M coding changes introduced simplified guidelines for office and outpatient visits. These now rely more heavily on medical decision-making or total time spent rather than history and exam.
How to Avoid It
Align coding practices with updated AMA and CMS guidelines, especially for time-based telehealth visits.
5. Overlooking Audio-Only Coverage Rules
During the pandemic, audio-only visits were temporarily covered. Many payers still cover them under specific CPT codes (e.g., 99441–99443), but policies are not universal.
How to Avoid It
Track which payers reimburse audio-only telehealth and adjust billing accordingly.
6. Misunderstanding Cross-State Billing Rules
Telehealth allows providers to reach patients across state lines, but reimbursement rules vary. Physicians may need separate state licensure or may face payer restrictions.
How to Avoid It
Verify licensure and payer policies before providing cross-state telehealth services.

Table: Common Telehealth Denials and Solutions
Denial Reason | Example | Solution |
---|---|---|
Missing modifier | Claim lacks 95 or GT modifier | Review payer guidelines and always append required telehealth modifiers. |
Wrong POS code | POS 11 used instead of POS 02 or 10 | Train staff on new CMS POS code requirements. |
Incomplete documentation | Missing patient consent or visit method | Use EMR templates that prompt for consent, modality, and duration. |
Unsupported audio-only billing | Billed 99443 without coverage | Maintain a payer policy tracker for audio-only reimbursement. |
Cross-state service issues | Patient in a state where the provider lacks a license | Confirm licensure and payer rules before scheduling the telehealth visit. |
New Coding Trends in Telehealth Billing
E/M Code Updates
Recent Evaluation and Management (E/M) changes focus on:
- Time-based coding: Providers can bill based on total time, including telehealth preparation and documentation.
- Medical decision-making (MDM): Emphasizes the complexity of patient conditions, regardless of setting.
Chronic Care Management (CCM) and Remote Patient Monitoring (RPM)
Physicians can now capture revenue through CCM and RPM codes, which often involve virtual touchpoints rather than in-person visits.
- CCM Codes (99490, 99491): For ongoing management of chronic conditions.
- RPM Codes (99453, 99454, 99457): For remote patient monitoring programs.
Takeaway
Physicians who leverage these codes can expand telehealth reimbursement beyond simple video visits.
Top Denials in Telehealth Billing
According to CMS and industry data, the most frequent denials in telehealth billing include:
- Invalid modifiers or POS codes
- Insufficient documentation
- Non-covered services billed as telehealth
- Patient eligibility issues
- Duplicate claims
How to Avoid Them
Conduct regular denial audits and train staff in payer-specific telehealth policies.
Financial Impact of Telehealth Denials
Denied claims have significant consequences:
Delayed Revenue
Resubmissions add 30–60 days to reimbursement.
Increased Overhead
Practices spend more staff time correcting errors.
Lost Revenue
Some denials are never resubmitted, leading to unrecoverable losses.
One study found that 15–25% of claims are denied on first submission, and up to 60% of those are never corrected and resubmitted. For small practices, this revenue leakage can make the difference between profitability and loss.
Best Practices to Avoid Telehealth Billing Errors
1. Stay Current With Payer Policies
Insurers regularly release policy updates. Assign responsibility to a billing service or office manager to track these changes.
2. Standardize Documentation
Use EMR templates that prompt for all required telehealth details (time, modality, patient consent).
3. Conduct Regular Billing Audits
Audits help identify recurring mistakes before they snowball into systemic revenue loss.
4. Train Physicians and Staff
Provide ongoing training in coding updates, payer requirements, and telehealth compliance.
5. Outsource to a Professional Billing Service
Partnering with a specialized medical billing company can reduce denials, accelerate cash flow, and allow physicians to focus on patient care.
How STAT Medical Consulting Inc. Helps Physicians
At STAT Medical Consulting Inc., we understand the unique challenges physicians and surgeons face with telehealth billing. Our services include:
Comprehensive Claim Management
From coding to submission and follow-up.
Denial Prevention
Tracking payer updates and applying correct codes/modifiers.
Revenue Optimization
Identifying opportunities for CCM, RPM, and E/M coding.
Nationwide Expertise
Supporting small groups and solo practices across the United States.
Our team stays ahead of regulatory changes so you don’t have to.

Protect Your Revenue in the Telehealth Era
Telehealth is here to stay, but billing mistakes can undermine its benefits. Physicians who understand the common pitfalls of incorrect modifiers, POS confusion, inadequate documentation, and coding changes will protect their practices from revenue loss.
If you’re ready to strengthen your billing process, reduce denials, and secure consistent reimbursement, it’s time to partner with experts who specialize in physician billing.
Visit www.statmedical.net to learn how STAT Medical Consulting Inc. can streamline your telehealth billing and help your practice thrive.

