The COVID-19 Public Health Emergency (PHE) transformed the way psychiatry was delivered across the United States—especially in Pennsylvania. As in-person visits declined, telepsychiatry rapidly became a lifeline for patients and providers alike. But with the PHE officially ending in May 2023, many temporary billing flexibilities began to expire or shift, leaving behavioral health practices scrambling to keep up with new requirements.

If you’re billing for telepsychiatry services in Pennsylvania, understanding what has changed—and what hasn’t—is critical to staying compliant and getting paid.

What Stayed the Same (For Now)

The good news: Medicare has extended many telehealth flexibilities through December 31, 2024, thanks to provisions in the Consolidated Appropriations Act of 2023. This includes allowing patients to receive telehealth psychiatric services from their homes, rather than requiring in-person visits at an originating site.

Pennsylvania Medicaid has also maintained strong support for telepsychiatry, continuing to reimburse for both audio-video and, in some cases, audio-only services when clinically appropriate. Most Behavioral Health Managed Care Organizations (BH-MCOs) in Pennsylvania—such as Community Care Behavioral Health and Magellan—have issued guidance indicating that they will continue to cover telepsychiatry services under current payment models, but this may vary slightly by region and plan.

What Changed: Place of Service (POS) and Modifiers

One of the most significant changes post-PHE involves how providers report the Place of Service (POS) on claims.

• During the PHE, many payers instructed providers to use POS 02 (telehealth) for all telehealth services.
• Post-PHE, Medicare now requires POS 10 for services provided to a patient in their home via telehealth and POS 02 for services provided to a patient in a facility or other location.

Private insurers in Pennsylvania may follow Medicare’s lead or set their own guidelines. Blue Cross Blue Shield, Aetna, and UnitedHealthcare all have different interpretations, so it’s crucial to verify POS requirements with each payer.

In terms of modifiers, most payers—public and private—still require:

• Modifier 95to indicate a synchronous telemedicine service rendered via real-time interactive audio and video telecommunications.
• Modifier GT is largely being phased out by Medicare but may still be required by some commercial plans or Medicaid MCOs.

Using the correct POS and modifier combination is essential to avoid unnecessary denials or downcoding.

Audio-Only Services: Still Covered?

During the PHE, audio-only services became a necessity. Post-PHE, Pennsylvania Medicaid and many MCOs still allow audio-only telepsychiatry in certain situations, especially for rural or underserved populations.

Medicare has also temporarily extended coverage for audio-only visits (e.g., CPT code 99441-99443), but only when video isn’t feasible and documentation justifies the modality. Be sure to clearly document why video wasn’t used, especially if you're billing higher-level services like 90837 (60-minute psychotherapy).

Platform and Technology Requirements

While some federal HIPAA enforcement was relaxed during the PHE, those waivers have now expired. As a result:

• Providers must use HIPAA-compliant telehealth platforms (Zoom for Healthcare, Doxy.me, etc.)
• Public-facing apps like FaceTime or Skype are no longer acceptable under compliance standards.

Final Thoughts

Telepsychiatry isn’t going away—but the way providers bill for it in Pennsylvania has definitely changed. Staying up to date with place of service codes, modifier usage, audio-only rules, and platform requirements can mean the difference between timely payments and costly rework.

Need help optimizing your telepsychiatry billing? Instapay Healthcare Services, specializes in behavioral health billing across Pennsylvania. Let our experts help you navigate the new normal, stress-free.