Missouri Telehealth Billing and Policy
Missouri telehealth billing and policy covers how telehealth services are defined, delivered, and reimbursed across Medicaid and private payers. This page outlines key requirements, billing practices, and considerations for providers delivering care in Missouri.
IMPORTANT UPDATE! Effective August 28, 2026, physicians may establish a patient-provider-relationship through a telemedicine encounter, as long as the standard of care does not require an in-person encounter, and in accordance with evidence-based standards of practice and telemedicine practice guidelines that address the clinical and technological aspects of telemedicine. To ensure a complete understanding of this policy change, read the official language from Missouri House Bill No. 2372 here.
Rules and Regulations
Telehealth is treated as a method of delivery, and Missouri telehealth billing and policy follows standard coding and reimbursement practices.
Definition & Scope of Telehealth/Telemedicine
Under Missouri law, “Telehealth” or “telemedicine”, is the delivery of health care services by means of information and communication technologies which facilitate the assessment, diagnosis, consultation, treatment, education, care management, and self-management of a patient’s health care while such patient is at the originating site and the health care provider is at the distant site. Telehealth or telemedicine shall also include the use of asynchronous store-and-forward technology.
“Distant site” is a site at which a health care provider is located while providing health care services by means of telemedicine.
“Originating site” is a site at which a patient is located at the time health care services are provided to him or her by means of telemedicine. For the purposes of asynchronous store-and-forward transfer, originating site shall also mean the location at which the health care provider transfers information to the distant site;
Provider Licensing & Eligibility
- Providers must be fully licensed in Missouri to deliver telehealth services to Missouri patients.
- Out-of-state providers generally cannot practice telehealth in Missouri unless they meet very narrow statutory exceptions (e.g., informal consultation or emergency response without compensation).
- House Bill 2794 passed through the Missouri House in March 2026, and clarifies that telehealth providers who received their licenses in Missouri via the state reciprocity law are allowed to provide their services.
Standards of Care
Telehealth services must meet the same standard of care that would be expected in an in-person encounter.
For certain acts — especially prescribing medications including controlled substances — a valid physician-patient relationship must be established. This may require sufficient history, examination, dialogue about treatment options, and documentation, and sometimes an in-person encounter depending on clinical judgment and legal requirements. Currently, federal waivers loosen much of these restrictions.
Informed Consent & Patient Rights
Telehealth providers shall obtain patient’s or the patient’s guardian’s consent before telehealth services are initiated and shall document the patient’s or the patient’s guardian’s consent in the patient’s file or chart. All telehealth activities must comply with the requirements of the Health Insurance Portability and Accountability Act of 1996, as amended and all other applicable state and federal laws and regulations.
Note: State Medicaid and private insurers may have specific consent requirements — check payer policies.
Documentation
- Maintain complete medical records for telehealth visits, including clinical notes, consent documentation, and communications.
- MO HealthNet requires providers to maintain records accessible for inspection and audit upon request.
Technology & Privacy
- Telehealth platforms should be secure and HIPAA-compliant to protect patient privacy.
- Technology must allow for sufficient communication to support clinical decision-making and the standard of care — this includes video quality, audio clarity, and secure data transmission.
Prescribing
- Missouri law prohibits prescribing based solely on online forms, questionnaires, or brief calls. A valid provider-patient relationship must be established before prescribing; generally this can be done through an appropriate telehealth encounter. Currently, federal waivers loosen these restrictions.
- Prescribing decisions should be supported by adequate clinical evaluation.
- Controlled substances should follow state law and federal DEA rules.
- Telehealth prescribing policies should be consistent across providers.
Reimbursement
- For Missouri Medicaid, Telemedicine services are reimbursed the same way as in-person services if delivered via telemedicine and are covered services.
- There is no separate telehealth fee schedule — payment equals the fee schedule amount for the procedure code billed.
Private Payers
Private health carriers must cover telehealth services if the same services are covered when delivered in person. Telehealth services cannot impose higher cost-sharing (copayments, coinsurance, deductibles) than equivalent in-person services.
Billing for Telehealth in Missouri
Missouri telehealth billing and policy requires accurate use of place of service codes, modifiers, and payer-specific billing rules.
MO HealthNet (State Medicaid) Overview
- Missouri’s Medicaid program reimburses telehealth services if they meet the same standard of care and are within scope of practice as in-person services.
- There is no geographic distance requirement between the patient and provider for Medicaid telehealth.
- Providers must be enrolled as MO HealthNet providers before billing telehealth services.
- Billing uses standard CPT/HCPCS codes with telehealth modifiers (e.g., place of service 02).
Medicare
- Medicare reimbursement rules are federal, separate from state statutes. National Medicare telehealth policies have evolved since the COVID-19 emergency; providers should consult the latest CMS guidance for eligible services and billing rules.
Source: MO Revisor of Statutes
Procedure Codes
Use the same CPT/HCPCS service codes you would for in-person services when delivering services via telehealth/telemedicine — there is no unique separate MO HealthNet telehealth CPT code list:
- Standard CPT/HCPCS clinical service codes for the actual service provided — e.g., E/M, therapy, consultation, etc.
- MO HealthNet reimburses telehealth services at the same rate as the corresponding in-person service if the service is covered and within provider’s scope.
Important: There isn’t a separate “telehealth only” CPT code list for MO HealthNet — telehealth is treated as a delivery method. The actual service code must itself be covered by Medicaid and meet telemedicine criteria.
RHCs and FQHCs- Originating Site
Originating site means a site at which a patient is located at the time healthcare services are provided by means of telemedicine. Authorized originating sites do not currently include a person’s home.
- Q3014 — RHCs and FQHCs are eligible to receive reimbursement for a facility fee for Telehealth services when operating as the originating site. Claims must be submitted with HCPCS code Q3014 (Telehealth originating site facility fee). Effective for dates of service on or after July 1, 2016, FQHC providers must bill no more than $16.97 in order to receive the $15.61 maximum reimbursement. Claims will be subject to post payment review and those reimbursed more than $15.61 will be adjusted to recoup the difference. (see Provider Bulletin Vol. 9 No. 28, Nov. 9 2016)
- This is billed in addition to the clinical service code where applicable.
- Not billable when the participant is at home.
RHCs must bill with their non-RHC number to receive reimbursement for a facility fee for the Telehealth services when operating as the originating site.
Place of Service (POS) Codes
When billing MO HealthNet for telemedicine services, use the appropriate POS based on where the patient is located during the encounter:
General | |
|---|---|
| POS Code | Meaning |
| 02 | Telehealth provided while patient is not at home |
| 10 | Telehealth provided while patient is at home |
| 27 | Telehealth outreach site/street (e.g., non-permanent location) |
| 03 | School-based telehealth (use GT modifier) |
| 99 | Telehealth provided in private space within a public setting (e.g., a private room in a public library) |
Modifiers
Missouri MO HealthNet generally follows standard telemedicine billing practices for distant site claims (the provider site remote from the patient), so your billing may include:
- GT — Telemedicine service via interactive audio/video system (often used for distant site when required)
- Modifiers for POS/claim context as defined by the provider manual and claim type.
School Grounds: For distant site services provided on school grounds (POS 3) use GT modifier.
Residential/Inpatient: Behavioral Health services at POS codes 14, 21, 33, 51,5 5, 56, or 61 must bill with GT modifier.
Rural Health Clinics: Bill with GT modifier for distant site services billed on the UB04 claim form.
- PBRHC/UB04: Rev code + CPT+ GT+ billed charge
- IRHC/UB04: Rev code+T1015+GT
Note: While Federal Medicare commonly uses 95 or 93 modifiers for telehealth, specific Medicaid plan policies may vary; managed care plans may have additional requirements. Always verify with your specific MO HealthNet managed care plan if billing through one.
Additional Notes
- Missouri Medicaid telehealth guidelines and POS updates are published by the Missouri Department of Social Services and in provider bulletins — refer to those and the MO HealthNet Provider Manuals for the most current instructions and allowable CPT/HCPCS codes.
- Some services (e.g., behavioral health in residential or inpatient settings) may have specific modifier/POS combinations; check the telemedicine overview and manual pages.
- Managed Care Organizations (MCOs) under MO HealthNet may have additional billing policies for telehealth services — always verify with the payer’s provider manual.
Example Quick Billing Summary
Scenario: Telehealth office visit for a MO HealthNet participant
✔ Bill the appropriate CPT/HCPCS code for the office visit
✔ Use POS 02 (telehealth not in patient’s home) or POS 10 (telehealth at patient’s home)
✔ Include any required telehealth modifier per payer guidance (Use GT for exceptions- school, residential/inpatient, or rural health clinic)
✔ Add Q3014 for originating site facility fee when applicable
✔ Submit through your MO HealthNet billing system or managed care plan portal
Distant site means a site at which the healthcare provider is located while providing healthcare services by means of telemedicine.
Originating site means a site at which a patient is located at the time healthcare services are provided by means of telemedicine. Authorized originating sites do not currently include a person’s home.
Checklist for a Primary Care Clinic
Understanding Missouri telehealth billing and policy helps ensure services are delivered and billed appropriately.
To implement telehealth in Missouri lawfully, your clinic should ensure:
- Licensure Compliance
- All providers are licensed in Missouri or have appropriate telehealth waivers/licensure via compact.
- Telehealth Policy & Consent
- Written telehealth policies, patient consent procedures, and documentation practices are established.
- Clinical Standards
- Telehealth services follow the same standards as in-person care, including reporting and follow-up protocols.
- Technology & Privacy
- Only HIPAA-compliant platforms for video visits.
- Billing & Reimbursement
- Proper coding, payer requirements understood (e.g., Medicaid, private insurance). Telehealth Certification Institute
- Prescribing Requirements
Policies for telemedicine prescribing align with state board rules.
References
Rules and Regulations
- State telehealth insurance coverage & parity: RSMo §376.1900. MO Revisor of Statutes
- Missouri telehealth statutes: RSMo §191.1145 and §208.670. MO Revisor of Statutes
- Missouri telehealth prescription statutes: RSMo Section 334.108. MO Revisor of Statutes
- MO HealthNet telehealth reimbursement & service delivery standards. CCHP
- Federal licensure and telehealth legal considerations. telehealth.hhs.gov
- Telemedicine. MO Department of Social Services
- Missouri Telemedicine Reimbursement/Insurance Guide MO Rural Health Association
- Legal Requirements for Telehealth. American Association of Family Physicians.
Billing
- Consolidation Appropriations Act extending Medicare flexibilities.
- Missouri Medicaid
- Center for Connected Health Policy
Providers should regularly review Missouri telehealth billing and policy to stay aligned with Medicaid and payer updates.
