Telehealth Billing in Maryland: The Modifier, the Place of Service, and the Consent Line That Decide Whether You Get Paid

The session happened. The clinician was licensed, the service was authorized, the note was written the same day. Six weeks later the remittance comes back at zero, and the reason has nothing to do with the care. The claim went out with place of service 02.

Maryland Medicaid does not accept 02 on a fee-for-service claim. It never did. Most practices learn this one denial at a time.

Telehealth has been part of Maryland behavioral health long enough that it no longer feels like a special case, which is exactly the problem. The rules are specific, they are not the rules most billing software ships with by default, and the parts that changed in 2025 changed quietly.

What changed, and what did not

The Preserve Telehealth Access Act of 2025 (HB 869 and SB 372, Chapters 481 and 482 of the Acts of 2025) took effect June 1, 2025. Its job was mostly deletion. It struck the words "From July 1, 2021, to June 30, 2025" from three places in Maryland law.

The practical effect: audio-only telephone conversations are permanently inside the statutory definition of telehealth, and Medicaid and commercial carriers must permanently reimburse covered telehealth services on the same basis and at the same rate as in person. The sunset that had been hanging over the whole model is gone. MDH confirmed all of this to providers in PT 90-25 on June 27, 2025.

Two things did not change. Payment parity still excludes clinic facility fees, unless the provider is not authorized to bill a professional fee separately, and it excludes room and board entirely. And parity is about the rate, not about coverage. Whether a given service can be delivered audio-only is still decided program by program.

The act also repealed the flat ban on prescribing Schedule II opiates for pain through telehealth, leaving practitioners subject to the federal and state controlled substance rules that already applied. And it added a new requirement that the Maryland Health Care Commission report to the Governor and the General Assembly on telehealth by December 1, 2026, and every four years after.

Since then, two more things have landed. Carelon released version 5 of the Maryland PBHS Provider Manual on August 21, 2026, with a new standalone Telehealth chapter. And the proposed COMAR 10.63 rewrite, published in the August 21, 2026 Maryland Register, drops the blanket prohibition on audio-only telehealth to align the subtitle with SB 372.

The two modifiers

Maryland Medicaid uses GT and UB. Not 95 and 93.

Bill the usual procedure code, then append:

• GT for two-way audio-video telehealth
• UB for audio-only, meaning a telephone conversation

That is it. If your clearinghouse, your billing vendor, or a scrubber rule inherited from a multi-state configuration is putting 95 on Maryland behavioral health claims, those claims are wrong even when everything clinical about them is right. This is worth checking today rather than at the next denial review.

The place of service trap

This is the one that costs the most money, because it looks correct.

Maryland Medicaid's rule is that you use the place of service code you would have used if the encounter had not been telehealth, based on where the rendering practitioner is. A clinician working from an off-site office bills place of service 11.

Do not use 02 (telehealth other than home) or 10 (telehealth in the home) on Medicaid-only fee-for-service claims. The single exception is Medicare crossover claims, where you match the place of service already on the Medicare submission, and 02 and 10 are permitted.

Most EHRs and most billing staff coming from commercial or Medicare work reach for 02 and 10 automatically, because almost everywhere else that is the right answer. In Maryland Medicaid it is a denial.

Audio-only is covered, but not everywhere

The statute permanently includes audio-only. Coverage of any particular service by audio-only is program-specific, and MDH says so plainly: check your program regulations or manual.

So a PRP, an OMHC, an OTP, and a mobile treatment team can reach different answers for what looks like the same question, and all four can be right. Before you let a service line run by phone at volume, confirm it against the program's own rules and the Carelon manual chapter for that level of care, not against the general telehealth policy.

One useful edge case is settled. If a video session drops to audio because of bandwidth, the visit is still billable as an audio-only service, as long as that service can be fully and appropriately delivered that way. If technical problems stop you from completing the required components, you may not bill it at all.

What you cannot bill, at all

Maryland Medicaid lists these as non-billable for telehealth:

• Sessions where technical difficulties prevented delivery of all or part of the service
• Services that require in-person evaluation or cannot reasonably be delivered remotely
• Store-and-forward models, outside dermatology, ophthalmology, and radiology
• Provider-to-provider communication without the participant present
• Email between provider and participant
• Fax between provider and participant

The four walls waiver, for OMHCs

CMS approved Maryland's State Plan amendment on May 19, 2025, and MDH issued PT 86-25 on June 9, 2025. As of June 1, 2025, participating OMHCs may bill at clinic rates for services delivered via telehealth when both the practitioner and the participant are off site. This superseded the July 2024 guidance in PT 21-25. MDH is still pursuing separate waiver authority for local health departments, so this waiver is OMHC-specific.

The documentation angle

The billing rules get the attention. The documentation rules are what an audit actually pulls.

Consent, in the record, before the service. COMAR 10.09.49 requires the participant's consent to receive services via telehealth. If an emergency prevented obtaining it, the record has to say so and explain why. A consent form signed at intake two years ago, with no reference to modality, is thin. A line in the note confirming consent for this modality on this date is not.

Same standard as in person. Health Occupations Article 1-1003 holds telehealth practitioners to the same standards of practice as in-person care, and the record has to be maintained the same way, retained under Health-General Article 4-403.

Do not store the session. Providers may not store video images or the audio portion of a telehealth service for future use. This one catches practices that turn on cloud recording for training, supervision, or note generation and leave it on. If you use any tool that captures session audio, confirm what it retains and for how long, and confirm your BAA covers it. An AI-assisted draft built from a live transcript is fine when nothing is retained; a stored recording is a regulatory problem regardless of how useful it was.

Say the modality in the note. Nothing in the rules requires a specific sentence, but modality, participant location or confirmation that the location was secure and agreed, and the fact that the session was completed are the three facts a reviewer reconciles against the modifier on the claim. When the note says video and the claim says UB, the reviewer stops reading and starts sampling.

What to do this week

Monday. Pull thirty days of telehealth claims. Check three fields: modifier is GT or UB, place of service is not 02 or 10 unless it is a Medicare crossover, and the modifier matches what the note says happened. Any mismatch is a pattern, not an accident, and it is cheaper to find it yourself.

Tuesday. Open the new Telehealth chapter in version 5 of the Carelon PBHS Provider Manual and read it against your own telehealth policy. Version 5 also moved recoupment and offset rules into a new Provider Payments chapter and refreshed medical necessity criteria across most levels of care.

Wednesday. Confirm, per program, which of your service lines are actually covered audio-only. Write the answer down. Give it to scheduling, not just billing.

Thursday. Check what your video platform and any note-assist tool retain after a session ends.

By Sunday, September 21. The COMAR 10.63 comment period closes. The proposal's telehealth provisions are in scope, and BHA did not schedule a public hearing, so written comment is the only route. We covered the rewrite in The COMAR 10.63 Overhaul. Comments go to mdh.regs@maryland.gov.

Primary sources

• PT 90-25, Delivery of Services through Telehealth (June 27, 2025)
• Maryland Medicaid Synchronous Telehealth Policy Guide (updated May 15, 2025)
• PT 86-25, Waived Four Walls Requirement, OMHCs (June 9, 2025)
• HB 869, Preserve Telehealth Access Act of 2025, as enrolled
• COMAR 10.09.49 Telehealth Services
• Carelon Maryland PBHS Provider Manual
• COMAR 10.63 Proposed Regulations Announcement
• Maryland Medicaid telehealth page

Telehealth billing questions: mdh.medicaidtelehealth@maryland.gov. Behavioral health policy questions: mdh.mabehavioralhealth@maryland.gov.