Telehealth in Behavioral Health: Bridging the Gap in Mental Health Access
In recent years, telehealth has emerged as a crucial service delivery mechanism, particularly within the behavioral health sector. Behavioral health providers have embraced this medium to effectively reach vulnerable and underserved populations. This adoption is driven by the persistent challenges in accessing timely care, with logistical barriers often preventing individuals and families from receiving necessary support. Consider these statistics: over 60% of U.S. counties lack a psychiatrist, underscoring the critical need for expanded mental health access 1. Compounding this issue, the COVID-19 pandemic triggered a 25% global increase in anxiety and depression 2. Despite the prevalence of mental health conditions, nearly half of U.S. adults with mental illness do not receive treatment, a situation exacerbated by limited local resources. Telehealth, therefore, offers a viable solution to reduce these disparities and enhance engagement, effectively bridging gaps and delivering vital services to isolated communities.
Telehealth, or telemedicine, broadly encompasses two primary modalities: synchronous and asynchronous. Synchronous delivery involves real-time interactions, facilitated by tools such as video conferencing and telephone calls. Asynchronous telehealth, on the other hand, employs a “store-and-forward” approach, where information is collected, transmitted, and reviewed at a later time.
Synchronous delivery, characterized by real-time, two-way audiovisual interactions, allows for face-to-face consultations, crucial for visual assessments and detailed discussions. This format is frequently employed in behavioral health for medical provider appointments, individual and group therapy sessions, and pre-admission assessments. Additionally, audio-only telehealth services, which cater to populations lacking broadband internet or video-capable devices, provide access to a range of services via telephone.
Asynchronous delivery involves the transmission of recorded information, such as data, videos, and images, for later review. While this method lacks real-time interaction, it proves valuable for pre-admission screenings, inter-provider updates, and remote patient monitoring (RPM). RPM, in particular, offers significant potential in behavioral health by enabling the monitoring of patient vitals, activities, and patterns, thus complementing traditional treatment approaches.
The benefits of telehealth in behavioral health are multifaceted, primarily centered on enhanced access. For individuals in rural or remote areas, those with limited mobility, or those facing scheduling constraints, telehealth ensures access to necessary care. Moreover, telehealth can improve care quality and cost-effectiveness through regular follow-ups, enhanced medication adherence monitoring, and earlier intervention, all while reducing costs for both providers and patients.
Given these advantages, it’s unsurprising that many behavioral health organizations are integrating telehealth into their service delivery. However, providers must navigate a complex regulatory landscape. Federal regulations, including HIPAA, the Ryan Haight Act, DEA regulations, and guidelines from SAMHSA and The Joint Commission, are paramount.
Billing and Reimbursement
Billing and reimbursement for telehealth services vary across Medicaid, Medicare, and commercial payers but coverage exists across these payers. Medicaid policies are state-specific, while Medicare has expanded coverage, particularly for behavioral health. Commercial payers also have diverse policies, necessitating careful review of contracts and guidelines. Behavioral Health organizations should ultimately consult their contract, provider representative, and specific payer policies to determine the correct coding and billing processes for reimbursement as we will discuss only generally here; as the information is not exhaustive.
Medicaid reimbursement for telehealth varies significantly by state, including prior authorization requirements, CPT and HCPCS codes used, and modifiers used. It is important to check coding requirements with Behavioral Health organizations specific state Medicaid agency.
Medicare has expanded telehealth coverage, especially for those in rural areas and during the COVID-19 pandemic. There are very specific rules regarding originating sites for Medicare telehealth services that can be found on its website. Historically, Medicare had strict originating site requirements and limited telehealth services to specific rural areas or location types. The COVID-19 pandemic lead to certain flexibilities which has resulted in extensions to some of these flexibilities and other permanent changes to the rules. Through September 30, 2025, Medicare patients can receive telehealth services for non-behavioral/mental health care in their home. During this time, there are no geographic restrictions for originating sites for Medicare non-behavioral/mental telehealth services. Permanent changes include telehealth services for behavior/mental health being allowed in the patient’s home and no geographic restrictions for originating sites3. It will be noted how this affects the Medicare population utilizing services through their primary care provider later.
Commercial payers’ policies vary widely by payer and plan. Many have increased coverage and flexibility for telehealth services following the COVID-19 pandemic. It is important to review Behavioral Health organizations’ contract with each payer, along with their specific rules for coding and service requirements. Organizations should consult their provider representative for assistance obtaining this information or getting clarification on available information.
Some general information and guidance on coding for telehealth services is provided below. However, we suggest consulting each payer’s guidelines before submitting billing as this information is subject to change and varies across payers. In Behavioral health many of the CPT and HCPCS codes remain the same for telehealth services as they are for in-person. Most commonly the place of service is changed to account for telehealth and many payers also require a modifier that indicates the type of service being provided. Below are some common CPT/HCPCS, modifiers, and place of service codes for telehealth services in Behavioral Healthcare.
CPT Codes (Common)
| CPT Code | Description |
| 90791 | Psychiatric diagnostic evaluation, without medical services. |
| 90792 | Psychiatric diagnostic evaluation, with medical services. |
| 90832 | Psychotherapy, 16-37 minutes. |
| 90834 | Psychotherapy, 38-52 minutes. |
| 90837 | Psychotherapy, 53 minutes or more. |
| 90846 | Family psychotherapy without patient present. |
| 90847 | Family psychotherapy with patient present. |
| 90849 | Multiple-family group psychotherapy. |
| 90853 | Group psychotherapy (other than of a multiple-family group). |
| 96150-96171 | range are used for health and behavior assessment and intervention (Consult payer guidelines). |
| 99202-99215 | These codes are used for office or other outpatient visits, which can be conducted via telehealth. These are often used for medication management. |
| Gxxxxx | There are also various G codes that are used for the treatment of substance use disorders (Consult payer guidelines). |
| H0010 and similar codes | Institutional billing such as Intensive Outpatient services provided via synchronous audio-visual telehealth. Medicaid, Medicare, and commercial payers may have specific guidelines for billing H0010 and similar services via telehealth |
Modifiers (Common)
| Modifier Code | Description |
| 95 | Synchronous Telemedicine Service Rendered Via a Real-Time Interactive Audio and Video Telecommunications System. |
| 93 | Synchronous telemedicine service rendered via telephone or other real-time interactive audio-only telecommunications system. |
| GT | No longer commonly used, though some commercial payers may accept – Telehealth service rendered via asynchronous telecommunications system. |
| GQ | No longer commonly used, though some commercial payers may accept – Telehealth service rendered via interactive audio and video telecommunications system. |
| FQ | A telehealth service was furnished using real-time audio-only communication technology. |
Place of Service (Common)
| Place of Service Code | Description |
| 02 | Telehealth Provided Other than in Patient’s Home – This code is used when telehealth services are provided in a location other than the patient’s home. This could include situations where the patient is at another healthcare facility, an office, or any other location that is not their residence. |
| 10 | Telehealth Provided in Patient’s Home – This code is used when telehealth services are provided while the patient is located in their home and this code specifically designates that the patient is receiving telehealth from their private residence. |
As with any billing for healthcare services, providers should consider appropriate documentation and service provisions that align with the payer’s guidelines and requirements. Ensure documentation includes the patient’s consent and location, any technical difficulties, and any actions or precautions required to maintain confidentiality. The codes provided above are a generalization and are subject to change. It is important that Behavioral Health organizations consult their specific payers on the proper coding for telehealth services and ensure they receive updates from the payers when their procedures change. Payer guidelines such as copayment and deductible collection should be adhered to, and this is another consideration for telehealth providers. Many systems make patient billing seamless allowing collections to occur automatically prior to an appointment, during the appointment, or following agreed payment plans and payment methods to collect co-payments, deductible amounts, and self-pay charges. Information on payer policies pertaining to documentation and patient billing can be obtained through the CMS website, State Medicaid Agencies, commercial payer websites, and the American Medical Association.
For low-income patients providers should consider alternative resources such as Community Mental Health centers or similar providers. Some providers have developed sliding-scale fees to assist this population. When considering this method, Behavioral Health organizations should consult payer guidelines and a compliance professional to ensure their processes are within requirements. More and more telehealth grants and subsidies have also become available in order to meet the demands of mental health needs and availability of services.
Regulatory Considerations
HIPPA compliance mandates the safeguarding of personal health information (PHI) through secure technology and practices. This includes ensuring Behavioral Health organizations video conferencing platform is secure, Behavioral Health organizations data is encrypted and securely stored, that physical safeguards are in place, and that the appropriate patient consents for electronic communication and Business Associate agreements are obtained. Secure platforms such as Zoom for Healthcare, Doxy.me, VSee, Microsoft Teams for Healthcare, and Google Meet with HIPPA compliance are commonly used. Some of these platforms provide additional support and workflows for various specialties and practice types. Behavioral health organizations should thoroughly evaluate their needs and the capabilities of each. Features to consider include end-to-end encryption, HIPPA compliance, Access Controls, Audit Trail capabilities, and capabilities and tools that support Behavioral Health organizations workflows. In addition to secure platforms, an organization’s information technology system must be secure. Ensuring a safe connection is important and Behavioral Health organizations should use strong passwords, encryption, and network security measures (including patient education on safe internet use) to do so. While HIPPA does not provide a certification there are others that show a commitment to information security; certifications such as HITRUST CSF, ISO27001, and SOC 2 can provide a sense of security for Behavioral Health organizations patients and business partners. It is worth noting that according to guidance by the Department of Health and Human Services, audio-only phone calls made through traditional phone lines (landlines) are not subject to the HIPPA security rule4.
The Ryan Haight Act and prescribing controlled substances under DEA requirements are another important Federal regulation to consider when providing telehealth services. The Ryan Haight Act and DEA regulations are aimed at controlling online pharmacies and ensuring that legitimate prescribing for controlled substances, by appropriate licensed providers, is occurring. The regulation goes further to ensure a valid patient-physician relationship is fostered. During the COVID pandemic there were temporary waivers for the in-person requirement. Recently the DEA has extended these telemedicine flexibilities that were put in place through December 31st, 2025. In January of 2025, the DEA expanded buprenorphine treatment through telehealth (Medication assisted treatment for opioid dependency) which provides patients with remote access to this important modality. This change allows patients to receive a 6-month supply of buprenorphine through telehealth, with further prescriptions requiring an in-person visit5. In this New Rule, the DEA created various registration requirements to manage providers and platforms, including a national PDMP or Prescription Drug Monitoring Program for identifying abuse and diversion of controlled substances. The rule also expanded telehealth in the Veterans Affairs Department by exempting VA practitioners from special registration requirements; intended to improve the continuity of care for veterans via telehealth and increase available providers.
It is important to note that State laws also regulate telehealth practices, potentially adding further layers of complexity. Behavioral Health organizations should consult their state’s laws to identify how they may affect the organization’s program. The Center for Connected Health Policy (CCHP) is a national resource center dedicated to telehealth policy. They provide detailed information on state laws and Medicaid program policies surrounding telehealth and allow state by state comparisons6. While CCHP is a great resource, it is worth noting that State medical boards and licensing agencies have the ultimate authority on professional requirements and should be consulted. Other topics to consider as Behavioral Health organizations research their state are licensing requirements for out-of-state providers, specific laws regulating telehealth such as restrictions on certain modalities or services, and licensing agreements or compacts that allow reciprocal licensure from one state to another.
While not law or regulation there are agencies that provide best practices and ethical considerations for telehealth services. Providers should consider how their informed consent explains the risks and benefits of telehealth, whether their maintaining confidentiality in a virtual setting both at the patient’s location and the providers, and how certain services such as crisis management and emergencies will be handled in this setting of care. Organizations like the Substance Abuse and Mental Health Services Administration (SAMHSA) provide best practices for telehealth services for substance use disorder as well as their role in crisis intervention7. Other organizations like SAMHSA can provide best practices across specialties concerning service provision, confidentiality, and other key information.
Current and Future Landscape
So, who’s using telehealth services today? Telehealth as a mechanism of service delivery in the Behavioral health space has continued to expand in recent years. In Mental Health, patients can access psychiatric services and medication management. Mental health psychotherapy for individuals, groups, and families can be obtained virtually anywhere. Substance Use Disorder services have also begun to incorporate telehealth in the provision of services. SUD, like Mental Health, provides virtual psychotherapy for individuals, families, and groups along with medical care for services such as Medication Assisted Treatment or MAT. These services help the SUD population address stigma and barriers to accessing quality care while allowing remote monitoring and connections with other resources like peer and community support. Child and Adolescent Behavioral Health has adopted telehealth service provisions to address access issues and continuity of care needs. Providers have continued to adapt practices to adapt to the virtual environment, ensuring group dynamics are managed virtually, that family involvement takes place when services are delivered through this medium, that therapeutic techniques are adapted for virtual sessions, and that services such as interventions, remote monitoring, and crisis interventions are delivered in a way that ensures they are effective in the virtual setting.
This expansion of telehealth services in recent years has helped millions access care and improve care continuity that might otherwise not exist. This is especially true considering the COVID-19 pandemic that paralyzed much of the healthcare system, which in turn became a catalyst for the rapid adoption of virtual care settings across healthcare. During the pandemic CMS expanded telehealth coverage and loosed restrictions around onsite requirements while increasing provider participation including Behavioral Health providers. Many states followed CMS and loosened Medicaid restrictions for telehealth providers. The Department of Health and Human Services also waived technology requirements to allow patients to access services on platforms such as smartphones and personal tablets. Waivers also included broader requirements for telehealth to include the same rates as in-person visits.
Following the COVID-19 pandemic many of the temporary waivers were subject to removal or revision. Some of these revisions will require congressional approval to become permanent with many bills being introduced in the past 4 years. Particularly, there is movement from Congress to make permanent provisions such as allowing Medicare Beneficiaries to access services without regard to their location. HIPPA regulations were also relaxed for telehealth providers under the pandemic waivers. There are also state level concerns regarding licensure and location such as whether or not the provider needs to be licensed in the state of practice and the state where they reside? There is a push for interstate compacts for providers in order to mitigate this licensing concern.
A permanent change under Medicare is the allowance of Behavioral Health via telehealth if performed by a licensed behavioral health provider. However, a large population of Medicare beneficiaries access Behavioral health care through their Primary Care Physician (PCP). This is the looming issue with the expiration of Medicare telehealth coverage and its implications for behavioral health providers. Behavioral Health explicitly is not part of this expiration due to the permanent change allowing access. The issue at hand is that many Medicare patients receive behavioral health through a PCP, such as the management of their SSRIs, psychoeducation, etc. The loss of PCP coverage or general medical coverage via telehealth may prevent access to management of behavioral health medications by those Medicare patients who do not use typical behavioral health channels to access behavioral health services, which is very common in certain populations due to the stigma surrounding behavioral health providers. For example, Patient X is prescribed Wellbutrin by her PCP. Patient X cannot drive and does not have family to transport her. She has utilized telehealth with her PCP for the past 4 years. Patient X would lose the ability to see her PCP/prescriber of her NDRI. Her provider may choose not to refill her NDRI without a visit and Patient X now has an access issue to care. It is more than likely that patient X will need to find a Behavioral health provider to continue this care and while the permanent change has allowed for telehealth services for Behavioral Health services, many areas already experience a shortage of these specific providers.
With the passing of the March 2025 deadline, behavioral health providers face significant uncertainty. Without congressional action to extend these provisions permanently, the telehealth landscape will revert to pre-pandemic restrictions, which were far more limited. Perhaps the most concerning impact will be on patients in rural and underserved communities. Prior to the pandemic, telehealth was primarily allowed only in designated rural areas and required patients to travel to specific healthcare facilities. The expiration means Behavioral health providers serving rural populations may lose the ability to treat many of their current patients, patients in mental health professional shortage areas will face renewed barriers to care, and providers who expanded their practices to serve these populations may need to scale back. This could have practices restructuring to avoid financial losses impacted by the reduction in telehealth services and may disrupt the continuity of care for many individuals and families. For many Medicare beneficiaries with mental health conditions, the relationship with their provider is crucial to recovery. The expiration threatens to disrupt these therapeutic relationships.
Telehealth is an effective tool that expands access to behavioral health services. To support access to behavioral telehealth care, telehealth policies allow Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to permanently serve as a Medicare distant site provider for behavioral and mental telehealth services. Medicare patients can permanently receive telehealth services for behavioral and mental health care in their home (Non-PCP). There are no geographic restrictions for originating site for Medicare behavioral/mental telehealth services on a permanent basis. Behavioral and mental telehealth services in Medicare can permanently be delivered using audio-only communication platforms. Marriage and family therapists and mental health counselors can permanently serve as Medicare distant site providers. An in-person visit within six months of an initial Medicare behavioral or mental telehealth service, and annually thereafter, is not required. For FQHCs and RHCs, the in-person visit requirement for mental health services furnished via communication technology to beneficiaries in their homes is not required until January 1, 2026.
Behavioral health providers can take several steps to address these changes and prepare for the other potential expirations. Organizations should stay informed; the situation remains fluid, with various bills in Congress that could extend telehealth flexibilities permanently or temporarily. Join professional associations actively lobbying for extensions and monitor CMS announcements for any transition guidance. Communicate with patients; open communication with Medicare patients is essential. Inform them about the potential changes and timeline. Discuss contingency plans, including transition to in-person care when possible. Identify patients who will face the greatest access challenges and prioritize solutions. Evaluate the impact on Behavioral Health organizations business and plan accordingly. Organizations need to understand the specific impact on their practice; calculate the percentage of revenue from Medicare telehealth, assess capacity for increasing in-person visits, consider hybrid models where initial assessments and periodic visits occur in-person, and explore commercial payer policies, which may continue telehealth coverage.
While the expiration presents significant challenges, behavioral health providers have demonstrated remarkable adaptability throughout the pandemic. The widespread adoption of telehealth has forever changed the landscape of mental healthcare delivery, and many commercial insurers will likely maintain expanded telehealth coverage regardless of Medicare’s decisions. For the long term, the behavioral health community should continue advocating for evidence-based policies that support patient access and provider sustainability. The demonstrated success of telehealth during the pandemic has built a strong case for permanent policy changes. As we navigate this transition, maintaining focus on patient needs will remain paramount. Behavioral health providers should approach this challenge with the same creativity and resilience they’ve shown throughout recent years of healthcare transformation and become informed and prepared utilizing the resources and information provided herein.
Author: Scott McKinney, SVP of Behavioral Health RCM
Resources and References:
- HRSA Data Warehouse: https://data.hrsa.gov/, National Rural Health Association: https://www.ruralhealthweb.org/ ↩︎
- World Health Organization (WHO): https://www.who.int/news-room/detail/02-03-2022-covid-19-pandemic-triggers-25-increase-in-anxiety-and-depression-worldwide ↩︎
- Telehealth.HHS.gov: https://telehealth.hhs.gov/ ↩︎
- https://www.hhs.gov/hipaa/for-professionals/security/laws-regulations/index.html ↩︎
- https://www.dea.gov/press-releases/2025/01/16/dea-announces-three-new-telemedicine-rules-continue-open-access ↩︎
- The Center for Connected Health Policy: https://www.cchpca.org/ ↩︎
- https://library.samhsa.gov/sites/default/files/pep21-06-02-001.pdf ↩︎