PA Medicaid Mental Health Telehealth Billing: Current Rules

Last updated: October 9, 2026.

Start with OMHSAS behavioral health guidance

As of October 9, 2026, DHS’s behavioral health telehealth policy index links OMHSAS-22-02 and the March 2023 interim guidance. Use the behavioral health policy and the responsible plan’s instructions for the actual service. Our recommendation is to record the policy version used for the billing review.

DHS OMHSAS behavioral health telehealth policy index

Distinguish FFS claim fields from BH-MCO instructions

OMHSAS-22-02 directs FFS providers to use POS 02 when the member is outside the home and POS 10 when the member is at home, unless a service has other instructions. It identifies FQ for audio-only. HealthChoices providers must follow their BH-MCO’s billing instructions.

OMHSAS-22-02: behavioral health telehealth, July 2022

Check clinical appropriateness and audio-only conditions

The March 2023 guidance permits audio-only when clinically appropriate and the individual lacks video access or there is an urgent medical situation, consistent with applicable requirements. It also addresses an auditable record for consent, service verification, and treatment-plan approval. Do not treat a telephone appointment as automatically billable.

OMHSAS interim telehealth guidance, March 2023

Account for the 2025 change to clinic-location rules

OMHSAS-25-05, issued December 12, 2025 and effective November 12, 2025, authorizes mobile or telehealth services outside specified MA behavioral health clinics. It lists psychiatric outpatient 08/110, outpatient drug and alcohol 08/184, and methadone maintenance 08/084. Do not carry forward the old blanket four-walls prohibition.

OMHSAS-25-05: behavioral health clinic services outside the clinic

Outside-clinic flexibility still has conditions

The 2025 bulletin requires clinically appropriate services and beneficiary consent. Clinics must still make in-clinic services available when clinically appropriate or requested. It does not change the existing MMHT State Plan service. Follow the BH-MCO’s claim procedures for HealthChoices services.

OMHSAS-25-05: behavioral health clinic services outside the clinic

Prepare a service-specific billing review

Our suggested checklist: delivery method, member location, provider enrollment category, responsible payer, code and modifiers, authorization, consent, and supporting documentation. Use the linked policies together; ask the plan to resolve a coding question before applying a single modifier recipe across all mental health services.

DHS OMHSAS behavioral health telehealth policy index

Related Pennsylvania Medicaid guides

• PROMISe Provider Portal Login and Account Setup in PA

• PA Medicaid Enrollment for Therapists: PROMISe and ePEAP

• PA HealthChoices: Physical vs Behavioral Health MCOs by County

• Verify PA Medicaid Eligibility with PROMISe EVS

• PA Medicaid Behavioral Health Claims: PROMISe or BH-MCO?

• Add your biller as a PROMISe alternate

• Check a PROMISe application using the ATN

• Assign an individual clinician’s fees to a group

Frequently Asked Questions

Should I add modifier 95 to every PA Medicaid therapy claim?

Do not use a universal recipe. OMHSAS separates FFS billing instructions from BH-MCO requirements; check the actual service and plan.

Are behavioral health clinic services outside the clinic always prohibited?

No. OMHSAS-25-05 permits specified clinics to provide clinically appropriate mobile or telehealth services outside the clinic, with conditions.

Does that clinic bulletin authorize every independent therapist arrangement?

No. Its listed clinic provider types and specialties define its scope; check the rules for your own enrollment.