Search for telehealth documentation requirements and you will find dozens of guides explaining place of service 02 versus 10, when to append modifier 95, and how to record consent. They are mostly correct.

Almost none of them mention that the rules they are describing expire on 31 December 2027 [1].

That gap matters more than it sounds. The things scheduled to change are not footnotes. They are whether your patient can be at home, whether your profession can bill Medicare for telehealth at all, whether a phone call counts, and whether a behavioral health patient has to be seen in person first.

Here is both halves: the coding rules you need today, and the expiry date that decides what you should be writing in the note right now.

Key Takeaway: Telehealth documentation has two halves and the internet only covers one. The first half is the codes. Use place of service 02 when the patient is somewhere other than their home, and POS 10 when they are at home, because since 1 January 2024 telehealth furnished to a patient at home is paid at the non-facility rate, which is the higher of the two [1][2]. Medicare identifies telehealth through place of service, while most commercial and Medicare Advantage payers still want modifier 95 for audio-video and 93 for audio-only [2]. The second half is that all of it has an expiry date. Current flexibilities run through 31 December 2027. On 1 January 2028, except for behavioral health, patients generally have to be in a medical facility in a rural area again, physical therapists, occupational therapists, speech-language pathologists and audiologists can no longer furnish Medicare telehealth at all, audio-only narrows to behavioral health, and the behavioral health in-person visit requirement switches on [1].

The Two Halves of Telehealth Documentation

A telehealth note carries everything an in-person note carries, plus a small block of fields that exist only because the visit was virtual. Most guidance stops there.

The complete picture has a second half, and it is the one with a deadline on it.

The Codes, Which Everybody Covers

This is the well-trodden part. Place of service 02 or 10 depending on where the patient sat. Modifier 95 or 93 depending on who is paying. Consent captured, identity verified, modality recorded, location documented.

All of it is real, all of it drives payment, and we will cover it precisely below. It is just not the whole job.

The Expiry Date, Which Almost Nobody Does

Medicare telehealth flexibilities are written into law with an end date attached. Congress extended them in early 2026, and the current set runs through 31 December 2027 [1].

So the note you write this year is evidence about a visit that may be audited under a different rulebook. That changes what belongs in it.

Patient Location Is a Payment Field

Where the patient physically sat during the visit is not a pleasantry. It picks the code, and the code picks the rate.

POS 02 and POS 10 Are Not Interchangeable

CMS is direct about the split. Use POS 02 for telehealth provided other than in the patient's home, and POS 10 for telehealth provided in the patient's home, meaning a private residence rather than a hospital or other facility where the patient receives care [1].

The distinction is about the patient's location, not yours. A patient joining from their kitchen is POS 10. The same patient joining from their employer's office or a clinic room is POS 02.

Since 2024, Home Pays More

In the CY 2024 Physician Fee Schedule final rule, CMS finalized that starting 1 January 2024, claims for Medicare telehealth services provided to patients in their homes are paid at the non-facility payment rate[1]. Telehealth provided at an originating site under POS 02 is paid at the facility rate [2].

The non-facility rate is the higher of the two. Which means a practice that defaults to POS 02 out of habit, for visits patients are taking from their living rooms, is taking a quiet pay cut on every claim.

The fix is not a billing rule. It is a documentation field. If the note says where the patient was, the coder has what they need.

Medicare Uses Place of Service, Commercial Payers Want Modifier 95

Here is where one visit turns into two different claims.

Medicare fee-for-service identifies telehealth through place of service. The AAFP puts it plainly: Medicare does not require a modifier for audio-video telehealth services, though it does require the appropriate place of service code [2]. For audio-only, append modifier 93 [2]. Federally qualified health centers and rural health centers use modifier FQ, 93, or both, since they carry the same meaning [2].

Commercial, self-funded, and Medicare Advantage policies vary, and many still expect modifier 95 on synchronous audio-video visits [2]. Treat that as payer convention rather than a CMS rule, and check the payer rather than applying one habit across the board.

Every Telehealth Rule You Are Following Has an Expiry Date

Telehealth is the only area of clinical documentation where the rules have a statutory expiry date printed on them, and essentially nobody writing about telehealth documentation mentions it.

The most thorough place-of-service guide in the search results runs 13 sections and three FAQs. It covers meaning, purpose, reimbursement impact, documentation requirements, when to use each code, what they cannot be used for, effects on claims, audits, and how to combine them. It never once says that the arrangement it describes ends on 31 December 2027.

That silence has a cost. A practice documenting only to today's rules, without recording which side of the line each patient sits on, will spend early 2028 reconstructing it from memory.

Four things change. All four are quoted from the CMS Telehealth FAQ.

Geography Comes Back on 1 January 2028

Through 31 December 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and its territories. Starting 1 January 2028, except for behavioral health services, beneficiaries will generally need to be in a medical facility and in a rural area [1].

For a virtual-first practice, that is the whole operating model, with a date on it.

Four Professions Lose Telehealth Billing Entirely

Starting 1 January 2028, physical therapists, occupational therapists, speech-language pathologists, and audiologists can no longer furnish Medicare telehealth services [1].

This is the largest single change in the set and the least reported. Outpatient therapy furnished remotely by hospital staff to patients at home follows the same pattern: billable through 31 December 2027, not billable from 1 January 2028 [1].

Audio-Only Narrows to Behavioral Health

Audio-only is permitted in the patient's home through 31 December 2027. From 1 January 2028, physicians and practitioners may use two-way, real-time audio-only technology for behavioral health servicesin the home, and only where the clinician is technically capable of audio-video and the beneficiary is not capable of it or does not consent to using it [1]. New and established patients both qualify.

Read that condition closely. It makes the reason a visit was audio-only part of the coverage rule, which makes it a documentation requirement rather than a courtesy.

Behavioral Health Gains an In-Person Requirement

Under section 1834(m), an in-person, non-telehealth visit within six months prior to the first mental health telehealth service becomes effective after 31 December 2027. After that first service in the home, an in-person service is required within 12 months of each mental health telehealth service, with limited exceptions [1].

Those in-person visits may be performed by a physician or practitioner of the same specialty in the same group practice if the treating clinician is unavailable [1].

And the part worth acting on today: patients who began receiving mental health telehealth at home on or before 31 December 2027 are considered established, skip the prior six-month requirement entirely, and need one in-person visit every 12 months after that date [1].

Whether a 2028 claim is billable is partly decided by what a 2026 note recorded.

Free Telehealth Note Templates

We built three telehealth templates that carry the fields above as structure rather than memory. Each is a branded, print-ready PDF.

• Telehealth visit note template, a standard visit note plus the five fields that exist only because the visit was virtual, including patient location with its place-of-service consequence.

• Behavioral health telehealth note template, with a mental status exam, a remote-specific risk assessment, and an in-person visit tracker built for the requirement arriving in 2028.

• Telehealth compliance checklist, a practice-level readiness sheet organised around what changes on 1 January 2028.

Three Changes That Already Happened in 2026

Not everything moved in the restrictive direction. Three changes took effect on 1 January 2026, and they went largely unnoticed because they loosened rules rather than tightening them.

Frequency Limits Are Permanently Gone

Telehealth frequency limits on subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations were permanently removed [1].

Permanently is the operative word. This one does not expire with the rest.

Direct Supervision Can Be Virtual

The presence required for direct supervision may now be met through real-time audio-video technology, excluding audio-only, for services without a 010 or 090 global surgery indicator [1].

For practices running incident-to billing, that changes where the supervising clinician has to physically be.

Teaching Physicians Can Be Virtually Present

Teaching physicians may have a virtual presence in all teaching settings, but only for Medicare telehealth services, and only during the key portion of the service [1].

What to Put in the Note Now

The practical payoff. None of this costs more than a few seconds per visit, and some of it is impossible to recreate later.

The Five Fields That Only Exist Because It Was Virtual

Every telehealth note should carry these, ideally as discrete fields rather than a sentence buried in the narrative.

1. The patient's physical location at the time of service, specific enough to pick POS 02 or 10 and to send help in an emergency.

2. Your location and state licensure. Telehealth is considered rendered at the patient's physical location, so the clinician typically needs a license in the patient's state [3]. Multi-state practice is common enough that most states now participate in a licensure compact of some kind [3][4].

3. The modality, audio-video or audio-only, and the platform used.

4. Consent to telehealth and identity verification, with the date consent was obtained.

5. Anyone else present on either side of the call, including family members, interpreters, and trainees.

One more field belongs alongside them, and it is the one that protects the claim clinically: what you could not assess remotely, and whether it mattered to the decision you made [5]. That converts an incomplete exam from an audit vulnerability into documented clinical judgment.

Record Why, Not Just What, for Audio-Only

Today, an audio-only visit in the home is billable and the reason is optional. From 1 January 2028, coverage depends on the clinician being capable of video and the patient not being capable of it or not consenting [1].

So write the reason now. "Patient does not have a smartphone" and "patient declined video" are one-line entries that become the justification for the claim under the next rulebook.

For Behavioral Health, Start Tracking the In-Person Date Now

If you see behavioral health patients virtually, add three items to the chart: the date of the last in-person, non-telehealth visit, who furnished it, and when the next one is due.

Then record whether the patient began at-home mental health telehealth on or before 31 December 2027, because that single line decides whether they ever need a prior in-person visit at all [1].

This field costs nothing today. Reconstructing it across a panel in 2028 is the expensive version.

Where Sully.ai Fits in a Virtual Care Practice

A template makes the fields exist. Something still has to fill them in, and after a full day of virtual visits that is where the plan usually breaks down.

A telehealth visit is unusually well suited to ambient capture. The whole encounter is conversation, on a platform, with both parties speaking clearly into a microphone. The patient says where they are. Consent is given out loud. The clinician says what they cannot assess over video.

Sully's AI Scribe, which captures the visit and writes the structured note into your EHR, keeps that virtual encounter block as discrete fields rather than prose. The AI Coder, which extracts the ICD-10 and CPT codes and submits the claim, is exactly where the place of service and the payer-appropriate modifier have to land correctly. And the AI Receptionist, which handles scheduling and patient outreach, is what a practice needs when an in-person visit becomes a recurring compliance requirement rather than a clinical preference.

They run on one integration across Epic, Cerner, Meditech, and Athenahealth, across 5,000+ providers and more than 50 million hours of AI work, at 80 to 90 percent below the cost of the equivalent human role.

If you are still deciding which tool fits, our comparison of the best AI scribes for telehealth covers the vendor landscape. If you already know what you need, see how the AI Scribe handles a virtual visit and bring the hardest case you have: an audio-only behavioral health visit with the patient at home.

FAQ

Q: What has to be documented in a telehealth visit note? Five things that would not appear on an in-person note: the patient's physical location at the time of service, your location and whether you are licensed in the patient's state, the modality used, that consent to telehealth was obtained and the patient's identity verified, and who else was present on either side. Add the ordinary clinical content, plus a note of what could not be assessed remotely.

Q: When do you use place of service 02 versus 10? POS 02 is telehealth provided somewhere other than the patient's home. POS 10 is telehealth provided in the patient's home, meaning a private residence rather than a hospital or other facility. Since 1 January 2024, Medicare telehealth furnished to a patient at home is paid at the non-facility rate, which is higher than the facility rate paid under POS 02, so the location field has a direct payment consequence [1][2].

Q: Do you need modifier 95 for Medicare telehealth? Medicare does not require a modifier for audio-video telehealth services, because it identifies telehealth through place of service instead. Audio-only services take modifier 93, and FQHCs and RHCs use FQ, 93, or both [2]. Most commercial and Medicare Advantage payers do still want modifier 95 on synchronous audio-video, so the same visit gets constructed two different ways depending on who is paying.

Q: When do the current Medicare telehealth rules expire? 31 December 2027. On 1 January 2028, except for behavioral health, beneficiaries will generally need to be in a medical facility in a rural area, physical therapists, occupational therapists, speech-language pathologists and audiologists can no longer furnish Medicare telehealth, audio-only narrows to behavioral health in the home with a documented reason, and an in-person visit requirement applies to mental health telehealth [1].

Q: Do you have free telehealth note templates? Yes. Sully.ai publishes three: a telehealth visit note with the five virtual-specific fields, a behavioral health telehealth note with an in-person visit tracker for the 2028 requirement, and a telehealth compliance checklist organised around what changes on 1 January 2028. All three are free to download.

Sources

[1] Centers for Medicare & Medicaid Services — Telehealth FAQ, updated 26 February 2026 [2] American Academy of Family Physicians — Coding for Telehealth: Audio, Video, and Virtual-Digital Visits [3] Center for Connected Health Policy — States with Telehealth Licensure Compacts [4] American Medical Association — Licensure and Telehealth Issue Brief [5] The Doctors Company — Telehealth Clinical Documentation Strategies