Home session
POS 10 plus 95 or 93; non-facility rate, so POS 02 here changes the price.
Home / Newsletters / The Mental Health Operator
The Mental Health Operator · Issue 2 · Late November 2026
The behavioral health telehealth POS and modifier map for 2027
Issue 2. One grid for Medicare behavioral health telehealth in 2027: POS 02 versus 10, modifiers 95, 93, BB and BC, audio-only and the in-person clock.
POS 10 home · 02 elsewhere
93 audio-only · 95 audio and video
In-person rule · after Dec 31, 2027
Edition
2 · late Nov 2026
Focus
Telehealth claim fields
Payer
Medicare
POS
10 · 02
Modifiers
95 · 93 · BB · BC
Effective
BB, BC Jan 1, 2027
Medicare BH telehealth, 2027 dates of service
| Field | Value | Rule |
|---|---|---|
| POS | 10 | Patient at home (a private residence, not a facility); non-facility rate since January 1, 2024. [1] |
| POS | 02 | Patient anywhere other than home [1] |
| Modifier | 95 | Synchronous audio and video [2] |
| Modifier | 93 | Synchronous audio-only, telephone or other real-time audio-only system [2] |
| Modifier | BB | Through a contracted virtual platform; required from January 1, 2027; no payment effect [1] |
| Modifier | BC | Incident to a practitioner's service; required from January 1, 2027; no payment effect [1] |
| Audio-only | Allowed at home | Through December 31, 2027 generally; from January 1, 2028 for behavioral health when the practitioner is video-capable and the patient cannot or does not consent [1] |
| Geography | None | CAA, 2021 removed geographic and place-of-service limits for behavioral health [1] |
| In-person visit | None through Dec 31, 2027 | From January 1, 2028: within 6 months before the first home service, then within 12 months of each; started by December 31, 2027 means established [1] |
| FQHC and RHC | PPS and AIR | Behavioral visits by telecommunications paid under PPS and AIR since January 1, 2022; no in-person requirement until at least January 1, 2028 [1] |
POS 10 versus 02: the field that sets the rate [3] [1]
Patient at a clinic or other site
POS 02 plus 95 or 93.
From January 1, 2027
Add BB or BC where the platform or incident-to condition applies [1].
Modifier 93 and the audio-only rules
For behavioral health audio-only is permanent; from January 1, 2028 the conditions are a video-capable practitioner and a patient who cannot or does not consent [1] [2].
The in-person windows from January 1, 2028, in months
Look-back before a first home servicenew patients
6 months50% of the interval
Maximum gap after each servicelimited exceptions
12 months100%
0612 months
Pre-visit look-backAnnual interval
Takeaway
Document why the session was audio-only: patient could not use video, or declined. That sentence supports modifier 93 after 2027.
The in-person clock and the FQHC proposal
Section 1834(m): an in-person visit within 6 months before the first home mental health telehealth service after December 31, 2027, then within 12 months of each; patients who began by then are established [1]. FQHCs and RHCs: the CY 2027 PFS proposed rule keeps it off through December 31, 2027 [4].
- 1Jan 1, 2027Modifiers BB and BC required [1]
- 2Dec 31, 2027Last day without the in-person rule [1]
- 3Jan 1, 2028In-person rule applies; audio-only continues for behavioral health at home [1]
The 2028 countdown has the quarter-by-quarter plan.
ASP update
Issue 1 covered the parity enforcement pause. These fields are now in the pre-submission checks our mental health billing and psychiatry billing teams run; the behavioral health payer matrix keeps state and payer notices beside the federal rule.
Sixty days, three fields
Pull 60 days of Medicare telehealth linesPsychotherapy, E/M and assessment codes.
Check three fields on eachPOS matches where the patient was; modifier matches the session; the note supports 93.
Count POS 10 patients by first telehealth dateYour established panel for January 1, 2028.
If the count surprises youThe 2027 buyer's guide has the telehealth questions for any biller.
Frequently asked questions
When do I use POS 10 instead of POS 02?
POS 10 when the patient is in their home, a private residence rather than a facility; POS 02 anywhere else. Home telehealth pays the non-facility rate.
What is the difference between modifier 93 and modifier 95?
93: synchronous telemedicine via telephone or other real-time audio-only system. 95: synchronous via real-time audio and video. Both from CR 14468.
Are modifiers BB and BC going to change what I am paid?
No. Required from January 1, 2027, no payment implications. BB: a virtual platform the practitioner contracts or has a payment arrangement with; BC: incident to a physician's or practitioner's service.
Does this grid apply to Medicaid and commercial payers?
No, the grid is Medicare. State Medicaid programs and commercial plans publish their own POS and modifier rules; check the behavioral health payer matrix and the payer's policy page first.
- CMS Telehealth FAQ, updated October 8, 2026 (posted October 9, 2026)
- CMS Transmittal 13776, Change Request 14468: distant site telehealth billing in RHCs and FQHCs (effective October 1, 2026)
- CMS MLN901705, Telehealth and Remote Monitoring booklet (December 2025)
- CMS fact sheet: CY 2027 Medicare Physician Fee Schedule proposed rule (July 14, 2026), proposed
Checked October 25, 2026. Confirm against the source; items marked proposed may change in the final rule.
Want the 60-day telehealth field check run on your claims?
Send the Medicare telehealth lines. We return POS and modifier exceptions, audio-only notes needing support, and the established-panel count.