How does Medicare telehealth reimbursement work for outpatient clinics in 2026?

Telehealth billing for Medicare in 2026 sits on three pillars: the covered services list, the place-of-service and modifier rules, and the statutory flexibilities that Congress has repeatedly extended. First, covered services. CMS maintains an explicit list of telehealth-eligible services published as part of the annual Physician Fee Schedule. The list includes most evaluation and management codes, behavioral health services, certain therapy services, chronic care management, transitional care management, and a growing set of remote monitoring codes (RPM and RTM). Services not on the list are generally not reimbursable when delivered via telehealth, with limited exceptions. Second, billing mechanics. The standard approach in 2026 is to bill the same CPT or HCPCS code you would use for the equivalent in-person service, with place-of-service code 10 when the patient is at home or place-of-service code 02 when the patient is in another non-home location, and modifier 95 to indicate the service was delivered via real-time interactive audio-video. Audio-only services (telephone visits, when permitted) use modifier 93 for many code categories. Reimbursement is at the non-facility rate of the Physician Fee Schedule when the patient is at home, which generally maintains parity with in-person office visits. Third, statutory flexibilities. The pandemic-era expansions, originating site restrictions waived, geographic restrictions waived, audio-only mental health coverage made permanent, and the ability for FQHCs and RHCs to serve as distant sites, have been extended in stages by Congress. The exact expiration dates of remaining flexibilities have shifted with each continuing resolution and budget cycle, so any clinic relying on telehealth revenue should check the current status quarterly with their MAC and CMS guidance. Commercial payers do not follow Medicare rules uniformly. Some maintain parity, some do not, and many have changed positions since 2022. Each commercial contract should be reviewed for its specific telehealth language: which services are covered, at what rate, with what modifiers, and whether audio-only is reimbursed. Behavioral health is the strongest telehealth use case in both Medicare and commercial. The clinical evidence base supports parity, payer policies generally support parity, and the operational economics often favor telehealth (no exam room turnover, lower no-show with reminders, broader catchment area).