Telehealth ABA Billing in 2026: Modifier 95 vs. 93, POS 02 vs. 10, and What CMS Made Permanent \| StreamABA [ ![StreamABA](https://streamaba.com/build/assets/logo-dark-Bta4omRy.svg) ](/) [Home](https://streamaba.com) [Blog](https://streamaba.com/blog) [ Log in ](https://streamaba.com/login) [ Goto the Live Demo ](#get-started) [Home](https://streamaba.com) [Blog](https://streamaba.com/blog) [Log in](https://streamaba.com/login) [ Goto the Live Demo ](#get-started) 1. [Blog](https://streamaba.com/blog) 2. / 3. Telehealth ABA Billing in 2026: Modifier 95 vs. 93, POS 02 vs. 10, and What CMS Made Permanent billing Telehealth ABA Billing in 2026: Modifier 95 vs. 93, POS 02 vs. 10, and What CMS Made Permanent ================================================================================================ Telehealth ABA billing in 2026 explained: modifier 95 vs. 93 vs. GT, POS 02 vs. POS 10, the CMS permanent telehealth list, state rules like Vermont's 97153 ban, and the modifier/POS mismatch that drives denials. 8 min read July 5, 2026 StreamABA Team Share [ ](https://x.com/intent/tweet?url=https%3A%2F%2Fstreamaba.com%2Fblog%2F2026%2F07%2Ftelehealth-aba-billing-2026-modifiers-pos&text=Telehealth+ABA+Billing+in+2026%3A+Modifier+95+vs.+93%2C+POS+02+vs.+10%2C+and+What+CMS+Made+Permanent) [ ](https://www.linkedin.com/sharing/share-offsite/?url=https%3A%2F%2Fstreamaba.com%2Fblog%2F2026%2F07%2Ftelehealth-aba-billing-2026-modifiers-pos) [ ](https://www.facebook.com/sharer/sharer.php?u=https%3A%2F%2Fstreamaba.com%2Fblog%2F2026%2F07%2Ftelehealth-aba-billing-2026-modifiers-pos) billing cpt-codes compliance payers ![](/images/blog/2026/07/telehealth-aba-billing-2026-modifiers-pos.jpg) CMS Made ABA Telehealth Permanent. That Settles Less Than You’d Think. ---------------------------------------------------------------------- Effective January 1, 2026, every ABA CPT code (97151 through 97158, plus 0362T and 0373T) is on Medicare’s permanent telehealth list. The final 2026 Medicare Physician Fee Schedule also eliminated the provisional designation system CMS had been using, so there is no more annual question of whether the codes will be renewed. The ABA Coding Coalition confirmed the change when the final rule published. Good news, but read it carefully. Medicare almost never pays for ABA. The typical ABA client is a child on a commercial plan or Medicaid, and Medicare’s fee schedule doesn’t govern either one. What the permanent list gives you is a reference point: commercial payers and state Medicaid programs borrow heavily from Medicare’s telehealth framework when they write their own policies, and “permanently approved by CMS” is a stronger foundation than “provisionally allowed through the end of the year.” What the permanent list does not give you is a coverage guarantee. Whether a specific payer pays for a specific ABA code delivered by telehealth still comes down to that payer’s policy, your state’s rules, and how you build the claim. Two states rewrote their ABA telehealth rules this year alone, in opposite directions. More on that below. First, the mechanics, because most telehealth denials in ABA are mechanical. The Modifier Answers One Question: How Was It Delivered? -------------------------------------------------------- Three modifiers show up in ABA telehealth billing, and they are not interchangeable. **Modifier 95** means synchronous, real-time audio and video. The BCBA can see the client or caregiver and vice versa, live. This is the workhorse modifier for ABA telehealth. A parent training session (97156) conducted over a video platform is 97156 with modifier 95. **Modifier 93** means synchronous audio only. A phone call, or a video session where the video never worked. Modifier 93 exists precisely so payers can distinguish (and price, and sometimes refuse) audio-only care. Billing 95 on a phone session misrepresents the delivery mode. Some payers cover audio-only for certain codes, many don’t, and several commercial plans cut audio-only reimbursement in 2026 on the theory that video is now table stakes. **Modifier GT** is the legacy telehealth modifier. CMS stopped requiring it on professional claims back in 2018, and most commercial payers followed. It survives in pockets: a handful of state Medicaid programs and commercial plans still want GT instead of 95. If a payer’s manual says GT, bill GT. The manual beats the trend. The pattern to internalize: the modifier describes how the service was delivered. Audio plus video is 95. Audio only is 93. Whatever the payer’s manual demands overrides both. POS 10 vs. POS 02: The Difference Shows Up in the Payment --------------------------------------------------------- If the modifier answers “how,” the place-of-service code answers “where the client was.” **POS 10** means telehealth provided in the patient’s home. For ABA, this is the common case: the caregiver is on video from the living room. POS 10 claims are generally paid at the non-facility rate, the same rate as an in-person home or office visit. **POS 02** means telehealth provided somewhere other than the patient’s home: a school, a clinic, a relative’s house. POS 02 is typically paid at the facility rate, which is lower. That rate difference is why POS errors are expensive even when they don’t trigger a denial. Bill POS 02 for a client who was at home and many payers will quietly pay you the facility rate. Nothing bounces. No one appeals. You just collect less than the contract allows, session after session, and the shortfall never shows up on a denial report because there is no denial. Bill the wrong direction, POS 10 for a client who was actually at school, and you have a documentation mismatch waiting for an audit. The Denial Trap: A Modifier and POS That Don’t Agree ---------------------------------------------------- Payer claim systems cross-check the telehealth signals on a claim, and the classic ABA telehealth denial is internal inconsistency. A 97156 with modifier 95 and POS 11 (office) tells the payer the session was simultaneously telehealth and in-office. Denied, or pended for records. A 97155 with POS 10 and no modifier tells the payer a telehealth-place-of-service claim wasn’t telehealth. Denied. Modifier 93 sent to a payer whose policy covers no audio-only ABA at all. Denied, correctly. Each of these is a five-second fix at claim creation and a 30-to-60-day fight after adjudication. The rule is simple to state and tedious to enforce by hand: every telehealth claim needs a delivery-mode modifier and a telehealth POS that agree with each other and with the session note. Both also have to follow the specific payer’s published policy. That last clause is where it gets hard. Why There’s No Single National Answer ------------------------------------- Medicare’s rules anchor telehealth policy for most of medicine. ABA is the exception: Medicare rarely covers it, so there is no national default for ABA telehealth billing. Every commercial payer and all 50-plus Medicaid programs write their own rules, and they differ on every axis: - **Which codes are telehealth-eligible.** Caregiver guidance (97156) is the most widely allowed. Many payers allow 97155 (protocol modification by the BCBA). Direct treatment by a technician (97153) is the contested one, and assessment (97151) is increasingly contested too. - **Which modifier they want.** Usually 95, sometimes GT, occasionally a state-specific modifier on top. - **Which POS they accept.** Some payers accept both 02 and 10; others recognize only one of them. - **Whether audio-only counts at all.** So the honest answer to “can I bill 97155 via telehealth?” is always the same: for which payer, in which state, as of what date? Verify per payer, in writing, and keep the source. A payer rep’s verbal “yes” is worth exactly what it costs. States Rewrote the Rules This Year, in Opposite Directions ---------------------------------------------------------- If you want proof that telehealth eligibility depends on the payer and the date, 2026 has already supplied two examples. **Vermont** banned telehealth delivery of 97153, technician-delivered direct treatment, in its Medicaid program effective January 1, 2026, as part of the same ABA policy revision that [banned concurrent billing](/blog/2026/04/vermont-concurrent-billing-ban-aba-medicaid). This was not a rounding error for providers. In written testimony to the Vermont legislature this February, one provider reported that the newly restricted services made up 73% of its telehealth ABA delivery and 30% of its total annual ABA services. **South Carolina** went the other way on supervision and training while tightening assessment. Its rewritten ASD provider manual, effective July 1, 2026, makes 97156 permanently telehealth-eligible and 97155 permanently telehealth-eligible with prior authorization. It also removes 97151 from telehealth entirely. A practice that leaned on remote assessments in South Carolina had until last Wednesday to move them in person. Same CPT codes. Same year. One state concluded technician-delivered telehealth treatment shouldn’t be paid for; another concluded BCBA-delivered telehealth direction deserves permanent status. Neither state is bound by what CMS put on the permanent list, and neither is yours. Documentation Has to Prove the Modifier --------------------------------------- When a telehealth claim gets audited, the session note either supports the modifier or it doesn’t. To defend modifier 95, the note needs to establish synchronous audio-video delivery, not merely imply it. At minimum: - **Mode of delivery.** State it plainly: “Session conducted via synchronous, real-time audio and video.” If the video dropped and the session finished by phone, the note should say so, and the modifier should change to 93 (or the claim shouldn’t go out, depending on the payer). - **Patient location.** This is what justifies your POS code. “Client and caregiver at home” supports POS 10. A note that never says where the client was leaves the POS unsupported. - **Provider location.** Several states and payers require it, and it costs one line. - **Consent.** Documented consent to receive services via telehealth, per your state’s requirements. - **Start and stop times and clinical content** held to the same standard as an in-person session. Telehealth changes the delivery mode, not the documentation bar. A note template that prompts for these five items turns an audit finding into a non-event. How StreamABA Handles This -------------------------- Telehealth billing rules are exactly the kind of payer-by-payer, date-sensitive configuration StreamABA was built around. **Payer-specific rules.** Modifier requirements are configured per code, per payer. The payer that wants 95 and the Medicaid program that wants GT each get their own rules, and claims inherit them automatically instead of relying on a biller’s memory. **Fee schedules with effective dates.** When a state flips a rule mid-year, the way South Carolina just did, you set the new configuration with a July 1 effective date. Claims before the cutover follow the old rules; claims after follow the new ones. **Claim validation before submission.** Claims are checked before they go out, which is where a modifier/POS mismatch should die – at creation, not at adjudication 30 days later. **Telehealth recorded on the session.** Telehealth is a location type on the appointment, and place of service carries through to the billing line, so the claim reflects how the session was actually delivered. What to Do This Month --------------------- You don’t need a policy change to act on this. A few hours of review will tell you whether telehealth billing is leaking money or carrying risk right now. 1. **Pull 90 days of telehealth claims** and check every one for internal consistency: telehealth modifier present, POS is 02 or 10, and the pair matches the session note’s stated location. Mismatches are your denial and audit exposure. 2. **Check paid amounts on POS 02 claims.** If clients were actually at home, you may have been collecting the facility rate on sessions that qualified for the non-facility rate. That’s recoverable on some contracts and fixable on all future claims. 3. **Build a per-payer telehealth grid**: for each payer, which ABA codes are telehealth-eligible, which modifier, which POS, and whether audio-only is covered. Source each cell from the payer manual or bulletin, with a date. 4. **Search your state Medicaid ABA manual** for telehealth language, and set a reminder to re-check it quarterly. Vermont’s change landed with weeks of notice; South Carolina’s took effect four days ago. 5. **Audit your telehealth note template** for the five documentation items above. If your notes don’t state delivery mode and patient location, fix the template today, not claim by claim. Telehealth ABA is past the emergency-flexibility era. The codes are permanently on the CMS list, the payers have put their rules in writing, and the denials now go to practices treating telehealth billing as an afterthought. --- Questions about setting up payer-specific telehealth rules for your practice? Reach out at **hello@streamaba.com**. Follow us on [LinkedIn](https://www.linkedin.com/company/stream-aba) and [X](https://x.com/streamaba) for more industry updates. [ All posts ](https://streamaba.com/blog) ![]() Related posts ------------- [Browse all posts](https://streamaba.com/blog) - [ ![](/images/blog/2026/02/aba-2027-cpt-code-changes.jpg) billing ### 2027 ABA CPT Code Overhaul: What's Changing and Why StreamABA Is Ready The biggest update to ABA billing codes in years takes effect January 1, 2027. Here's what we know, what it means for your practice, and why StreamABA customers won't miss a beat. Feb 10, 2026 4 min read ](https://streamaba.com/blog/2026/02/aba-2027-cpt-code-changes) - [ ![](/images/blog/2026/04/vermont-concurrent-billing-ban-aba-medicaid.jpg) billing ### Vermont Banned Concurrent ABA Billing. Revenue at Affected Clinics Dropped 17%. Your State Could Be Next. Vermont Medicaid banned concurrent billing of CPT codes 97153 and 97155 on January 1, 2026, citing an OIG audit that flagged $18.5 million in improper Wisconsin payments tied to the practice. Clinic revenue at affected providers dropped 16–17% within 60 days. CASP says the interpretation is wrong. Oregon allows it with documentation requirements. Most states have said nothing — and silence is now an audit risk. Apr 21, 2026 8 min read ](https://streamaba.com/blog/2026/04/vermont-concurrent-billing-ban-aba-medicaid) - [ ![](/images/blog/2026/02/idaho-aba-billing-code-switch.jpg) billing ### Idaho's ABA Billing Code Switch Is a Warning for Every Practice Idaho eliminated ABA from its managed care program and forced providers onto HCPCS codes with less than 30 days' notice. No crosswalk. No guidance on supervision billing. It's a warning shot for the entire industry. Feb 13, 2026 5 min read ](https://streamaba.com/blog/2026/02/idaho-aba-billing-code-switch) Live demo · No sales call Ready to Streamline your practice? ------------------------------------ Get instant access to a live demo of the all-in-one ABA platform built by clinicians, for clinicians. No sales call. HIPAA compliant · Signed BAA · Built for ABA Website Work email Goto the Live Demo ![](https://streamaba.com/build/assets/icon-BglRoXWC.svg) [ ![StreamABA](https://streamaba.com/build/assets/logo-dark-Bta4omRy.svg) ](/) The all-in-one practice management platform built specifically for ABA therapy providers. Website Work email Get Demo [ ](https://x.com/streamaba) [ ](https://www.linkedin.com/company/stream-aba) [ ](https://instagram.com/streamaba) [ 👍 ](https://www.facebook.com/people/Stream-ABA/61587347484176/) #### Product - [Intake](https://streamaba.com/features/intake) - [Communication](https://streamaba.com/features/communication) - [Pipeline Boards](https://streamaba.com/features/pipeline-boards) - [Tasks & Automation](https://streamaba.com/features/tasks-automation) - [Integrations](https://streamaba.com/features/integrations) - [Analyst Scorecard](https://streamaba.com/features/analyst-scorecard) - [Practice Marketing](https://streamaba.com/aba-practice-marketing) #### Resources - [Free ABA resources](https://streamaba.com/resources) - [ABA Medicaid rates](https://streamaba.com/tools/aba-medicaid-rates) - [Revenue Calculator](https://streamaba.com/tools/aba-revenue-calculator) #### Company - [Blog](https://streamaba.com/blog) #### Contact - [ Contact Support ](https://streamaba.com/support) © 2026 STREAM ABA LLC. All rights reserved. [Privacy Policy](https://streamaba.com/legal/privacy-policy) [Terms of Service](https://streamaba.com/legal/terms-of-service)