Telehealth POS code (02 vs 10)
Two CMS-designated place of service codes used for telehealth claims, introduced to distinguish where the patient is located during a telehealth encounter. POS 02 (Telehealth Provided Other than in Patient's Home) applies when the patient is at a location other than their home during the telehealth visit, such as a clinic, rural health site, or telehealth originating site. POS 10 (Telehealth Provided in Patient's Home) applies when the patient receives the service from their own home. The distinction affects Medicare reimbursement rates.
Why this matters for your clinic
POS 02 and POS 10 are not interchangeable. For Medicare, the payment rate for a telehealth service delivered to a patient in their home (POS 10) is set at the facility payment rate for the CPT code, which is lower than the non-facility rate. Services delivered via telehealth to a patient at a designated originating site (POS 02) may pay at the non-facility rate depending on the service type and applicable telehealth policy. Getting the code wrong changes what you collect per visit.
CMS has been updating telehealth billing rules since the COVID-19 public health emergency expanded telehealth access. The rules around which services qualify for telehealth billing, what modifiers are required, and which POS codes apply to specific service types have changed multiple times. Relying on telehealth billing guidance from 2020 or 2021 without verifying current CMS policy is a common source of claims errors in 2025 and beyond.
Some commercial payers follow Medicare telehealth billing rules; others have established their own telehealth policies. A practice billing substantial telehealth volume to multiple commercial payers needs a payer-specific telehealth coding matrix that is reviewed when annual contract updates or payer policy bulletins are issued.
What good looks like
CMS publishes telehealth-eligible CPT code lists and place of service guidance in each annual Physician Fee Schedule final rule. The CMS Telehealth Services fact sheet is updated after each rule finalization. AAPC and AHIMA publish telehealth coding guides updated annually.
Example
A psychiatry practice bills a 45-minute psychotherapy session (CPT 90834) via telehealth. The patient is at home. The correct POS code is 10. If the biller defaults to POS 02, the claim may process incorrectly depending on the payer's adjudication logic. For Medicare, POS 10 triggers the facility payment rate; POS 02 may trigger a different rate depending on the service and the patient's location type. The rate difference on a high-volume telehealth practice can be meaningful in aggregate.
From Sorso
Telehealth billing is one of the highest-error categories we see in mental health and behavioral health practices. The policy has changed enough times that even billers who were up to date in 2022 are often working from outdated rules. We audit telehealth claims separately in every billing review.
Founder of Sorso. 19 years in corporate finance. Managed a $450M loan portfolio before building a fractional CFO firm exclusively for healthcare clinics.
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