Billing

September 2, 2026

7 min read

By Albert Wong, PhD · Clinical Psychologist

How to Bill 90837 for Telehealth (POS 10, Modifier 95) — and When 90834 Is Safer

The short answer

For a video session that ran 53 minutes or more with the client at home: CPT 90837, place of service 10, and — for most commercial payers — modifier 95. If the client was somewhere other than home, the place of service is 02. Under 53 minutes of face-to-face time, the code is 90834, telehealth or not. Modifier requirements vary by payer, so confirm against each payer's telehealth policy rather than a colleague's memory.

A telehealth session uses the same psychotherapy codes and the same time thresholds as an office session. What changes is exactly two claim fields — the place-of-service code and, for many payers, a telehealth modifier — plus a few lines of documentation. Here is the whole recipe, in order.

Step 1: Confirm the session is a 90837 at all

90837 requires 53 or more minutes of face-to-face psychotherapy — time on the video call with the client, not time writing the note afterward. A 50-minute video session is a 90834 (38–52 minutes). This threshold does not bend for telehealth in either direction. Write the start and stop times in the note; that one habit is what makes the code defensible. The full time rules, including where the 53-minute line comes from, are in our 90837 vs 90834 guide.

Step 2: Pick the place of service by where the client is sitting

  1. POS 10 — telehealth provided in the client's home. This is the common case for private-practice teletherapy.
  2. POS 02 — telehealth provided anywhere other than the client's home: their office, their car, a relative's house, a dorm room.

The distinction is about the client's location, not yours. Ask at the start of the session — "where are you joining from today?" — and note the answer. You need it for the claim, and you need it clinically anyway in case of an emergency during the session. The two codes can also reimburse differently: Medicare pays POS 02 at the lower facility rate and POS 10 at the non-facility rate, and some commercial payers follow similar logic. The full breakdown is in POS 02 vs POS 10 for telehealth.

Step 3: Add the telehealth modifier your payer wants

  • Modifier 95 — synchronous telemedicine via real-time audio and video. This is what most commercial payers expect on teletherapy claim lines.
  • Modifier GT — an older telehealth modifier a few payers still prefer. If a payer's telehealth policy names GT, use GT for that payer.
  • Modifier 93 — audio-only. A phone session is not a video session; it has its own modifier and much more restrictive coverage. Do not bill an audio-only session with modifier 95.

There is no universal rule here — modifier requirements are payer policy, not CPT law. When you join a panel, pull the payer's telehealth billing policy once, note what it wants for POS and modifier, and save it where you build claims. When a rule is ambiguous, check your payer contract or provider portal rather than guessing.

Step 4: Document the telehealth specifics

Beyond a normal psychotherapy note, a telehealth note should capture:

  1. Start and stop times (this substantiates the 53-minute threshold).
  2. The modality — "conducted via synchronous audio-video telehealth."
  3. The client's physical location during the session, at least city and state.
  4. Your location.
  5. That telehealth consent is on file (obtain it once, at intake).

The location line matters for licensure too: you generally must be licensed in the state where the client is physically located during the session, unless an interstate compact such as PSYPACT applies to you. A client who moves states mid-treatment is a licensure question before it is a billing question. Our telehealth documentation guide covers the full note template.

Step 5: Verify the benefit before you rely on it

When you check eligibility, confirm two things: that the plan covers telehealth for outpatient psychotherapy at all, and whether it applies any special handling to 90837 — a few plans have historically required prior authorization for the 60-minute code specifically. Coverage rules changed repeatedly in recent years, so verify against the current plan year rather than what the same payer did last time. Nothing in this article is a promise that any particular payer will reimburse any particular claim.

When 90834 is actually safer

Only two situations make 90834 the right call, and neither is fear:

  1. The clock says so. The session ran 38–52 minutes of face-to-face time. That is a 90834 by definition, and billing 90837 for it is upcoding.
  2. The plan requires an authorization you don't have. If a plan requires prior auth for 90837 and you haven't obtained it, the clean paths are to get the auth or to schedule the session as a 45-minute session and bill the code that matches. What you should not do is hold a 57-minute session and bill it as 90834 — that makes the note and the claim disagree.

Downcoding a documented 53-plus-minute session because 90837 "feels risky" is not caution — it is an inaccurate claim plus forfeited revenue. The code follows the clock. If you want a quick cross-check while building a claim, our free CPT code picker walks the session type and time to the right code.

Telehealth Claims Without the Field-by-Field Anxiety

Practice Harbor carries the session's documented time, place of service, and telehealth modifiers from the note onto the claim, so what you bill matches what you documented.

Frequently Asked Questions

Do I use POS 02 or POS 10 for a teletherapy session?

POS 10 when the client is in their own home during the session; POS 02 when they are anywhere else (work, car, a relative’s house). The choice is determined by the client’s physical location, not the therapist’s. Ask where the client is at the start of each session and record it in the note, since the two codes can reimburse at different rates under some payers.

Do I need modifier 95 on a 90837 telehealth claim?

For most commercial payers, yes — modifier 95 indicates a synchronous session conducted over real-time audio and video. A few payers still prefer the older GT modifier, and audio-only sessions use modifier 93 where they are covered at all. Modifier requirements are payer policy rather than CPT rules, so confirm against each payer’s published telehealth billing policy.

Can I bill 90837 for an audio-only phone session?

Not the same way as a video session. Audio-only psychotherapy is billed with modifier 93 rather than 95, and coverage is significantly more restrictive — many plans limit or exclude audio-only psychotherapy. Check the specific payer’s current audio-only policy before the session, and never bill a phone call with the video modifier.

Is 90837 riskier to bill for telehealth than 90834?

No. 90837 is a standard code for 53 or more minutes of face-to-face psychotherapy, and the threshold is identical for telehealth and office sessions. The code becomes risky only when documentation cannot support it — a note without start and stop times, or content inconsistent with an hour of therapy. Record the session time in every note and bill the code the clock supports.