Telehealth will be a long-term element of how we deliver healthcare, and while telehealth creates a number of opportunities for NPs, it is creating a growing compliance issue. The 2026 cpt code set introduced 288 new codes, deleted 84 codes, and revised 46 codes — one of the largest increases in coding history. One of the biggest changes include the addition of new short duration remote patient monitoring codes and reduced timeframes that directly affect what NPs can bill.
While telehealth expands billing options for NPs, those same options create more stringent documentation standards and greater payer scrutiny. Telehealth claim denial rates are increasing as pandemic era flexibilities convert to permanent policy.
This document provides information on how to comply with the new telehealth billing regulations. Specifically, the guide covers medicare telehealth eligibility; documentation standards; and ways to keep your claims compliant.
Medicare telehealth eligibility: which distant sites may bill and where
Np’s are included in the list of distant site professions eligible to bill medicare for telehealth services. In total, the following professionals are considered eligible to bill medicare for telehealth services:
- Physicians
- NPs
- Pas
- Clinical cnss
- Cnms
- Crna’s
- Clinical psychologists
- Clinical social workers
- Registered dietitians/nutrition professionals
- Mental health counselors
- Marriage/family therapists
In addition, until january 30th, 2026, audiologists, occupational therapists, physical therapists, and speech-language pathologists are also able to bill medicare for telehealth services. Starting january 31st, 2026, these providers revert back to their permanent eligibility status.
Rules for originating site for 2026
Wherever a patient receives telehealth services matters for billing compliance.
Between january 30th, 2026 and january 30th, 2027, Patients can receive telehealth anywhere they choose without regard to their geographical location. This applies to all types of telehealth services.
On january 31st, 2026, rules divide depending on service type:
Non-behavioral/non-mental health telehealth services: originating site requirements exist as well as geographical location restrictions. Behavioral/mental health services: Patients may continue to receive treatment via telehealth regardless of where they are geographically located. Geographical restrictions do not exist nor is an originating site requirement necessary. A patient’s residence is an acceptable originating site for mental health disorders/substance abuse disorder and monthly ESRD-related clinical assessments .
An originating site facility fee (cpt code q3014) is reported when a patient receives telehealth in a healthcare facility. The value of the hcpcs code q3014 in 2026 is $31.85.
Requirements for telehealth equipment
Interactive telecommunications systems that include at a minimum: audio & video capabilities that permit two-way, real-time interaction between the patient and the distant site practitioner are required for medicare.
Effective january 31st, 2026, audio-only telehealth services remain permissible for behavioral health services to Patients in their homes; however, only under very specific circumstances. The furnishing practitioner must have technical capability to utilize audio-video technology and the beneficiary must either not be capable of utilizing audio-video technology or refuse to utilize audio-video technology.
Billing NP Telehealth Services: CPT Codes, Modifiers and pos
Most telehealth visits submitted by NPs contain three primary elements:
1. Correct cpt code describing the service(s) performed
2. Correct modifier (typically modifier 95)
3. Proper place of service (pos) code
Place of Service Codes for Telehealth
Use of a pos code informs medicare where the service could have been conducted in an in-person setting. Proper pos selection is necessary to assure proper reimbursement and distinguish telehealth from in-office encounters.
When reporting a synchronous audio-video telehealth encounter, report the pos code that would have been used had the service been furnished in-person. That is the distinguishing factor — you report where the visit could have taken place vs. Where the patient actually was during the visit.
Example: an np conducts a telehealth encounter with a patient from their respective homes that would normally have taken place in their office setting would report pos code “11” (office), rather than pos code “02” (telehealth) or pos code “10” (patient’s Home). If the service would normally take place in an on campus outpatient hospital department, then report pos code “22”. If the service would normally take place in an off campus outpatient hospital department, report pos code “19”.
For bh services where audio-only is allowed, the general rule continues to be to use the pos which identifies the setting in which the service would have taken place in an in-person encounter.
Modifier 95: when should i use it?
Modifier 95 (synchronous telemedicine service) is utilized to identify that a service was provided via a real-time interactive audio/video telecommunications system. Modifier 95 is generally accepted as the standard modifier for synchronous telehealth encounters under medicare and most private payers.
Verify requirements with each private payer as some may still require modifier 95 for telehealth claims even though CMS has stated that pos codes (02/10) will suffice as evidence of telehealth.
Note that while digital medicine services have their own unique CPT Codes dedicated to those services, those codes do not require traditional telemedicine Modifiers. Such services as remote physiological monitoring and remote therapeutic monitoring were developed with telemedicine inherently embedded into the services themselves.
Remote patient monitoring: 2026 code changes
The AMA/CMS Updates to RPM CPT Codes in 2026 represent one of the greatest expansions to this billing framework since RPM codes were initially created in 2019. These Updates demonstrate AMA/CMS’ recognition that true clinical monitoring may not always adhere to strict pre-defined time constraints.
Short duration monitoring codes
For 2026, five new codes are added for RPM services over durations of 2-15 days within a thirty day period. The creation of these recurring monitoring codes address the growing body of clinical research that demonstrates that Patients benefit from being monitored on a shorter term basis than previously possible with existing CPT Codes.
These recurring monitoring codes acknowledge the importance of post discharge monitoring of acute conditions (heart failure exacerbation, adjustment of diabetes management, etc.) and chronic conditions (hypertension monitoring) that are commonly overseen by NPs. Short-term intense clinical oversight can now be properly billed via dedicated CPT Codes.
Reduced time frames
Two new codes report remote treatment management via RPM after ten minutes of service per calendar month; down from twenty minutes. Recognition exists that clinically effective treatment plans can sometimes involve less frequent but more repetitive interventions especially when facilitated by advanced monitoring technologies and automated data collection systems.
Lowering time frames enable NPs to bill for short periods of clinical significance such as medication adjustments based upon remote monitoring data; educating Patients about concerning trends identified via remote monitoring; coordinating with other providers if remote monitoring indicates the need for modification to a patient’s care plan.
Documentation requirements for new short term RPM codes
Unlike legacy RPM codes, the new short duration RPM codes require more detailed documentation. NPs must retain:
- Device transmission logs listing daily dates and physiologic values received
2. Logs detailing data collected/staff involved/start/end times/cumulative minutes of service
3. Proof of at least one real-time interactive communication (phone/video/secure chat) per calendar month
4. Narrative providing medical necessity for the RPM service
These documentation guidelines support updated CMS compliance requirements starting january 1st, 2026.
Incident-to billing of np telehealth services
Virtual Direct Supervision
Effective january 1st, 2026, CMS permits NPs to bill incident-to services under a physician’s supervision using Virtual Direct Supervision using real-time, two-way audio/video communications technology.
Prior to january 1st, 2026, direct supervision required the supervising professional to be physically present in the office suite and readily available throughout the performance of the service to assist/direct staff. From january 1st, 2020 – january 1st, 2025, CMS temporarily waived direct supervision requirements allowing professionals to supervise remotely. Beginning january 1st, 2026, CMS permanently waived direct supervision requirements using virtual presence via real-time two-way audio/video communications technology — excepting certain surgical procedures with global surgery indicator values 010 or 090 due to higher risk — requiring in-person supervision.
Impact on NPs
Accordingly, unless excluded by specific exceptions; for most services listed at 42 cfr §410.26; “immediately available” component of direct supervision may be met using virtual presence via real-time audio/video communications technology — excluding audio-only communications.
Important exception for incidental telehealth billing
Flexibility granted regarding virtual supervision applies to incidental billing for services performed in an office/clinical environment; however, this exception does not apply to telehealth services delivered from outside an office environment when both the supervising physician and the np are remote.
Therefore, all medicare telehealth services must still comply with all applicable requirements for coverage/payment — including originating site requirements and geographical limitations for non-behavioral services.
Psychotherapy for Crisis via Telehealth
NPs are among the recognized practitioners who can furnish psychotherapy for crisis services (CPT codes 90839 and 90840) via telehealth.
Covered Services
Psychotherapy for crisis services help reduce a patient’s mental health crisis through:
- Urgent assessment and history of a crisis state
- Mental status exam and psychotherapy
- Mobilizing resources to defuse the crisis and restore safety
- Interventions to minimize the potential for psychological trauma
Where Services Can Be Furnished
NPs can furnish these services in facility or non-facility locations, including hospitals, skilled nursing facilities, physician’s offices, and patient’s homes. They can also furnish these services via telehealth if all requirements are met.
Billing Psychotherapy for Crisis
- 90839: Psychotherapy for crisis; first 60 minutes
- 90840: Each additional 30 minutes (use in conjunction with 90839)
These codes report the time spent with the patient, even if the time on the date of service is not continuous .
Audio-Only Telehealth Rules for 2026
Non-Behavioral Services
Through January 30, 2026, beneficiaries may continue to receive audio-only telehealth services in their homes. Starting January 31, 2026, audio-only services for non-behavioral telehealth are no longer permitted.
Behavioral Health Services
Starting January 31, 2026, two-way, real-time audio-only communication technology may be used for behavioral health services furnished to a patient in their home, provided that :
- The furnishing practitioner is technically capable of using audio-video communication technology
- The beneficiary is not capable of or does not consent to using audio-video communication technology
Audio-only can be used for both new and established patients for behavioral health services.
The 12-Month Relationship Rule (Australia)
For NPs practicing in Australia, a significant change took effect November 1, 2024. Nurse practitioners are now subject to the same existing relationship rule for telehealth appointments that applies to GPs .
What This Means
Under this rule, a practitioner cannot bill the MBS for a telehealth appointment with a patient they have not seen face-to-face in more than 12 months. GPs and nurse practitioners are the only practitioners subject to this rule; non-GP specialists and other eligible allied health professionals can still technically bill the MBS for telehealth appointments with patients they have not met face-to-face.
Exemptions
The eligible telehealth practitioner requirement does not apply to certain populations, including:
- A person under the age of 12 months
- A person experiencing homelessness
- A person living in a natural disaster affected area
- A person receiving treatment through Blood Borne Virus, Sexual or Reproductive Health telehealth
- A person isolating because of a COVID-related public health order
For behavioral health services, nurse practitioners are not able to access the same mental health item number exemptions that apply to GPs, because nurse practitioners do not have specific mental health item numbers and instead bill using timed consultation items.
Key Documentation Requirements for Telehealth
To support telehealth claims and survive audits, NPs must ensure documentation includes:
- Medical necessity for the telehealth service
- Date and time of the service (start and end)
- Patient location at the time of service
- Provider location at the time of service
- Communication method (video, audio-only, secure chat)
- Patient consent to receive services via telehealth
- Clinical content of the encounter (history, exam, medical decision-making)
- Time tracking for time-based services
RPM Documentation Requirements
For the new short-duration RPM codes, NPs must document:
- Device transmission logs showing daily dates and physiologic values received
- Time-tracking logs documenting data, staff member, start/end times, and cumulative minutes of service
- Proof of at least one real-time interactive communication (phone, video, or secure chat) per calendar month
- A narrative establishing medical necessity for the RPM service
Vague notes are a red flag for auditors. “Worked on coping skills” does not justify a 90837-telehealth claim. “Patient reported anxiety 8/10. Used deep breathing exercise for 10 minutes. Post-exercise anxiety reduced to 4/10. Patient verbalized understanding of technique” tells a story and supports medical necessity.
Telehealth Audit Risks and Compliance
Rising Denial Rates
Telehealth claim denials are increasing as pandemic-era flexibilities transition into permanent policy frameworks. Common denial reasons include:
- Incorrect place of service coding
- Missing or incorrect modifiers
- Inadequate documentation of medical necessity
- Failure to meet originating site requirements
- Improper billing of audio-only services
- Non-compliance with state scope of practice laws
Compliance Recommendations
To minimize compliance risk, consider the following recommendations:
- Verify payer-specific requirements: Telehealth policies vary by payer. Check each plan’s telehealth policy for modifier and POS requirements.
- Update telehealth policies: Ensure your practice policies reflect 2026 rule changes, including virtual supervision and audio-only limitations.
- Train staff regularly: Provide annual training on telehealth billing requirements and documentation standards.
- Conduct internal audits: Review a sample of telehealth claims quarterly to identify documentation gaps or coding errors.
- Document all telehealth encounters thoroughly: Include the communication method, patient location, provider location, and clinical content in each note.
- Monitor state scope of practice: Telehealth billing must comply with both Medicare requirements and state scope of practice laws.
Conclusion
Telehealth billing for nurse practitioners in 2026 requires understanding a complex set of rules that vary by payer, service type, and patient location. The permanent expansion of virtual direct supervision for incident-to billing, new short-duration RPM codes, and the extension of telehealth flexibilities through 2027 create significant billing opportunities.
However, these opportunities come with increased documentation requirements and compliance risks. Accurate claims require the correct POS codes, appropriate modifiers, and thorough documentation. The 12-month relationship rule in Australia adds another layer of compliance for NPs practicing in that region.
The key to successful telehealth billing is staying current with policy changes, verifying payer-specific requirements, and maintaining documentation that justifies every service. When in doubt, consult the official CMS guidelines or your local Medicare Administrative Contractor. The rules are detailed, but following them keeps your claims clean and your revenue flowing.
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