Navigating Highmark's New Telehealth Policy Changes for 2026

By Tatyana Kantor, CFPC, CPB, Billing Supervisor WCH: AAPC Tashkent Chapter President

Telehealth has become a permanent part of healthcare delivery. What began as an emergency response during the pandemic has evolved into a core component of patient access, chronic care management, behavioral health treatment, and routine follow-up services.

Yet while telehealth itself is here to stay, the rules governing reimbursement continue to change.

Beginning September 1, 2026, Highmark will update its telehealth policy to align more closely with guidance from the Centers for Medicare & Medicaid Services (CMS) and the American Medical Association (AMA). For many providers, the transition will be relatively smooth. For others, it may expose workflow gaps, coding inconsistencies, and revenue risks that have gone unnoticed for years.

The good news is that organizations have time to prepare.

Why This Update Matters

The announcement may sound like a routine payer policy revision, but it reflects a larger trend occurring across the healthcare industry. Health plans are increasingly moving away from broad pandemic-era telehealth flexibility and toward standardized reimbursement frameworks based on nationally recognized coding guidance.

In practical terms, Highmark is narrowing telehealth eligibility to services specifically recognized by CMS and, for Commercial plans, certain telehealth Evaluation and Management (E/M) services approved by the AMA.

For providers, this means that historical assumptions about which services can be delivered virtually may no longer be sufficient. Every telehealth workflow should now be evaluated through the lens of payer-approved code eligibility.

The question is no longer: “Can this service be performed virtually?”

The question is: “Will this service qualify for reimbursement under current payer telehealth policy?”

Those are not always the same thing.

The New Telehealth E/M Codes Are Finally Arriving

One of the most significant aspects of the update is Highmark’s adoption of the AMA’s new telehealth E/M code family for Commercial plans. These codes were created to better distinguish telehealth encounters from traditional office visits and to recognize different modalities of virtual care.

The code sets include:

Synchronous audio-video visits CPT 98000–98007

Synchronous audio-only visits CPT 98008–98015

Providers in Highmark’s New York service areas have already been using these codes since 2025. However, practices in Pennsylvania, Delaware, and West Virginia will need to ensure their coding teams, billing staff, and EHR systems are ready before the September implementation date.

Organizations that fail to update charge capture workflows could experience increased claim rejections or delayed reimbursement.

The Hidden Risk: Legacy Telehealth Templates

Many practices built telehealth workflows rapidly during the pandemic. Those workflows often remain largely unchanged today.

Scheduling teams may still use old appointment types. Clinicians may rely on documentation templates created several years ago. Billing departments may continue submitting codes based on historical payer acceptance rather than current policy requirements. This creates a significant compliance risk. When payers update telehealth eligibility criteria, outdated templates can cause providers to submit claims for services that are no longer recognized as telehealth encounters.

The result may not be an immediate denial. In some cases, claims may process initially but later become subject to audit, recoupment, or documentation review. Organizations should use the September transition as an opportunity to conduct a comprehensive telehealth workflow assessment.

Questions worth asking include:

Are current telehealth visit types mapped to the correct CPT codes?
Do documentation templates identify whether the encounter was audio-video or audio-only?
Are coders trained on the new E/M telehealth code family?
Are billing edits configured to prevent submission of outdated telehealth codes?
Have providers been educated about services that now require in-person visits?

These operational reviews often reveal issues long before they become revenue problems.

Place of Service Codes Matter More Than Ever

One of the most overlooked aspects of telehealth billing continues to be Place of Service (POS) reporting. Highmark has reiterated that professional telehealth claims must follow CMS guidance regarding POS designation. The distinction is straightforward:

POS 02
Used when telehealth services are provided while the patient is located somewhere other than their home.

POS 10
Used when telehealth services are provided while the patient is in their home.

While the difference may seem minor, incorrect POS coding can affect reimbursement calculations, benefit application, and claims processing outcomes. Many organizations focus heavily on CPT code selection while paying insufficient attention to POS accuracy. Yet payer audits frequently identify POS discrepancies as a source of billing errors. A simple registration workflow update that captures patient location at the start of every telehealth visit can significantly reduce this risk.

Behavioral Health Providers May See Less Disruption

The announcement notes that many of Highmark’s most commonly utilized telehealth services, particularly those related to behavioral health, will remain eligible under the updated policy. This is consistent with broader industry trends. Behavioral health remains one of the strongest use cases for virtual care. Numerous studies have demonstrated improvements in access, patient engagement, and continuity of treatment when telehealth options are available.

However, behavioral health organizations should not assume that no action is required. Even when services remain eligible, documentation requirements, coding expectations, and POS reporting rules still apply. Maintaining eligibility is not the same as maintaining compliance.

Telehealth Strategy Is Becoming a Revenue Cycle Issue

Historically, telehealth decisions were often driven by clinical operations and patient access goals.

Today, they are increasingly becoming revenue cycle decisions.

Every virtual service line now sits at the intersection of:

Clinical appropriateness
Coding accuracy
Documentation standards
Payer policy requirements
Reimbursement eligibility

As payers continue refining telehealth policies, successful organizations will be those that establish governance processes capable of monitoring regulatory and payer changes on an ongoing basis. Rather than treating telehealth as a separate service category, forward-thinking practices are integrating telehealth oversight into their broader compliance and revenue integrity programs. This approach allows organizations to identify policy changes earlier, train staff more effectively, and reduce reimbursement disruptions when payer requirements evolve.

What Providers Should Do Before September 1

With several months remaining before implementation, providers should consider the following action plan:

Review Current Telehealth Services: Compare existing telehealth offerings against CMS-approved telehealth services and determine whether any currently scheduled virtual visits may become ineligible.
Update Coding Resources: Ensure coding teams understand the new AMA telehealth E/M code family and know when each code should be used.
Audit Documentation Templates: Verify that telehealth encounter templates capture modality, patient location, and all required documentation elements.
Validate EHR Configuration: Confirm that scheduling systems, charge capture tools, and billing software support the appropriate telehealth coding structure.
Educate Clinicians: Providers should understand which services remain eligible for telehealth reimbursement and which may require face-to-face encounters moving forward.
Monitor Early Claims: Following implementation, organizations should closely track denial patterns, claim edits, and reimbursement outcomes to identify any emerging issues.

***

Highmark’s September update is unlikely to be the last major telehealth policy change providers encounter.

Across the industry, payers are increasingly aligning reimbursement with standardized coding frameworks established by CMS and the AMA. The era of broad telehealth flexibility is gradually being replaced by more structured, rule-driven reimbursement models.

For providers, success will depend less on whether telehealth remains available and more on whether organizations can adapt quickly to changing requirements.

The practices that treat telehealth compliance as an ongoing operational priority—not a one-time implementation project—will be best positioned to protect revenue, maintain access, and avoid unnecessary billing complications as virtual care continues to evolve.

If you have any questions about these upcoming telehealth changes, contact the WCH team. We’ll help you assess the impact on your practice, update your workflows, and prepare for the transition before the new requirements take effect. https://wchsb.com/contact-form/

Sources

Highmark. Highmark Provider News: “Highmark’s Telehealth Policy Will Be Updated on Sept. 1” (May 26, 2026).
Centers for Medicare & Medicaid Services. CMS Telehealth Services List and Medicare Telehealth Guidance.
American Medical Association. CPT 2025–2026 Telehealth Evaluation and Management Code Set (98000–98015).
Centers for Medicare & Medicaid Services. Place of Service Code Set Guidance (POS 02 and POS 10).
American Hospital Association. Telehealth reimbursement and compliance resources.
Medical Group Management Association. Telehealth operational and revenue cycle management guidance.