Texas Medicaid Telehealth: Therapy Billing Rules

Last updated: October 9, 2026.

For Texas Medicaid therapy delivered remotely, use the current Behavioral Health and Telecommunication Services handbooks together. As of October 9, 2026, the manual hub identifies policy through October 1, 2026. Open the current Texas Medicaid manual.

Start with the actual service, clinician, member coverage and delivery method. A general statement that Medicaid covers telehealth does not establish that every therapy service can be billed by every remote modality.

Modifier 95 or FQ for outpatient mental-health services?

The Behavioral Health handbook identifies modifier 95 for covered synchronous audiovisual services and FQ for covered audio-only outpatient mental-health services. Check its current service-specific rules and eligible codes. Do not apply a generic modifier 93 instruction to every therapy claim. Read section 4.2.1 and its modality requirements.

The Telecommunication handbook addresses consent, documentation and service/provider conditions. Review those requirements alongside the specific behavioral-health benefit. Read the Telecommunication Services Handbook.

Audio-only therapy has a prior-relationship requirement

TMHP’s HB4 notice describes an in-person or audiovisual outpatient mental-health visit with the same billing entity within the six months before the initial audio-only service. That initial six-month requirement cannot be waived. The current Behavioral Health handbook retains the relationship framework. Review the audio-only policy explanation.

The policy also requires an in-person or audiovisual visit within a rolling 12-month period after the initial audio-only service. The member and billing provider must agree that an in-person or audiovisual visit is clinically contraindicated or its risks or burdens outweigh the benefits. Document the basis for waiving the later requirement for that particular 12-month period. Do not carry that exception backward to waive the initial six-month requirement.

Recommended scheduling check: establish the qualifying encounter and billing entity before treating a new audio-only visit as payable. If the record does not establish the required relationship, resolve the modality and coverage question before submitting a claim.

Consent and documentation before claim creation

Texas allows verbal consent for audio-only services under the Telecommunication handbook’s documentation rules. Apply the current consent requirements for the actual service and method. Check consent and documentation requirements.

Recommended encounter-to-claim worksheet:

• Identify the service and whether it is covered by the intended video or audio-only method.

• Confirm the clinician’s applicable scope and license requirements and the relevant patient-location rules.

• Record the delivery method and required consent in the approved clinical record.

• For audio-only services, verify the initial relationship and any required follow-up or documented exception.

• Confirm the current code, modifier, place-of-service instructions and authorization for the responsible payer.

Managed care: confirm the plan’s claim instructions

For managed-care benefits, use the responsible plan’s provider requirements and claims route. State enrollment is separate from plan participation. Review the managed-care framework.

This guide does not prescribe a universal POS 02 or 10 for every Texas therapy claim. Resolve the actual service, setting and payer instructions together rather than guessing from the telehealth modifier alone.

Identify the TMHP or MCO claim route

Verify eligibility for the service date

Frequently Asked Questions

Which modifier applies to covered audio-only outpatient mental-health services?

The current Behavioral Health handbook identifies FQ. Confirm the service is eligible for audio-only delivery and that the relationship requirements are met.

Can the initial six-month audio-only relationship rule be waived?

No. The documented exception concerns the later rolling 12-month visit requirement, not the initial six-month prerequisite.

Should every Texas Medicaid telehealth therapy claim use the same POS?

Use the current instructions for the actual service, setting and responsible payer. This guide does not establish a universal POS rule.