For nearly six years, telehealth has transformed the way behavioral health providers deliver care. Psychotherapy, psychiatric medication management, substance use treatment, and integrated behavioral health services all experienced unprecedented growth through virtual care.
Now, the landscape is beginning to shift.
While Hawaii has continued to protect access to behavioral health services through expanded telehealth legislation, as a rural island nation, telehealth is, at times, the only way some can obtain services. Especially when your closest Psychiatrist is 3 hours away, or IOP services for substance use disorder are not available on the island you live on. Nationally, this is not the case, and many commercial insurance carriers are narrowing virtual care policies, tightening documentation standards, and increasing scrutiny over audio-only services, making the bureaucracy and compliance requirements, if telehealth is allowed, all the more confusing for providers, leaving pre and post-pay reviews and audits an opportunity for recoupment without proper guidance.
For behavioral health organizations, free-standing facilities, private practices, and psychiatric providers, understanding these changes is essential to protecting reimbursement and avoiding unnecessary claim denials and takebacks.
Hawaii Continues to Support Telebehavioral Health Through 2027
The good news for Hawaii providers is that the State has extended several important telehealth protections through December 31, 2027.
Under Hawaii law:
- Commercial insurers must continue reimbursing telehealth services delivered through real-time audio and video at parity with comparable in-person services.
- Audio-only behavioral health services remain reimbursable for the diagnosis, evaluation, and treatment of mental health disorders at 80% of the comparable in-person reimbursement, provided statutory requirements are met.
- Audio-only visits generally require an established clinical relationship, meaning the patient must have previously completed either an in-person visit or an audio-video telehealth encounter within the required timeframe before ongoing audio-only treatment is eligible for reimbursement.
These protections are particularly important for Hawaii’s rural communities, neighbor islands, kūpuna, military families, and patients with limited broadband access.
Medicare Provides Additional Stability
Behavioral health providers serving Medicare beneficiaries also received welcome news in 2026.
Congress extended many Medicare telehealth flexibilities through December 31, 2027, including:
- Patients may continue receiving behavioral health services from home.
- Geographic restrictions remain eliminated.
- Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) remain recognized Medicare telehealth practitioners.
- Behavioral health services continue to allow audio-only communication when appropriate.
- The previously scheduled in-person visit requirement for behavioral health telehealth remains suspended through the extension period.
For psychiatric medication management and psychotherapy practices, this provides much-needed operational certainty.
Nationwide Commercial Payers Are Taking a Different Direction
Although Hawaii law continues to protect access, commercial insurance companies are increasingly refining—and in some cases narrowing—their telehealth policies.
For our clients nationally or those that serve both Hawaii and the continental United States, it is critical to note that across the commercial market, several common trends are emerging:
1. Increased Preference for Audio-Video Visits
Many commercial payers now distinguish between:
- Audio-video telehealth
- Audio-only services
Several carriers reimburse audio-only only for limited CPT codes or specific benefit designs, while others require interactive video for routine medical management visits.
2. Stricter Documentation Requirements
Behavioral health documentation increasingly must demonstrate:
- Patient consent for telehealth
- Technology utilized
- Patient location
- Provider location
- Clinical appropriateness of telehealth
- Why audio-only was medically necessary when applicable
Incomplete documentation is becoming a common reason for post-payment review.
3. Greater Use of POS Codes and Modifiers
Commercial payers continue refining requirements surrounding:
- POS 02 versus POS 10
- Modifier 95
- Modifier 93 for audio-only services
Submitting the incorrect combination may result in denials or delayed reimbursement, even when the underlying service is covered.
4. Narrower Eligible Code Lists
Many commercial plans are moving away from broad “all behavioral health services are telehealth eligible” policies and instead publishing specific lists of:
- Covered psychotherapy codes
- Psychiatric medication management services
- Audio-only eligible CPT codes
- Telehealth-specific billing requirements
Providers should avoid assuming that every CPT code previously allowed during the Public Health Emergency remains covered virtually.
What This Means for Psychiatric Medication Management
Psychiatric medication management remains widely supported through telehealth.
However, commercial plans are increasingly expecting:
- Interactive audio-video technology whenever possible
- Appropriate documentation supporting medical necessity
- Accurate coding of telehealth modifiers
- Proper Place of Service reporting
- Documentation supporting any prolonged audio-only encounter
Practices relying heavily on telephone-only medication management should carefully review payer-specific policies before assuming continued reimbursement.
Psychotherapy Remains Well Positioned
Individual psychotherapy continues to be one of the strongest-supported behavioral health telehealth services across both Medicare and commercial markets.
Providers should still ensure documentation clearly reflects:
- Therapeutic interventions performed
- Clinical necessity
- Time requirements
- Patient participation
- Telehealth modality
- Appropriate diagnosis coding
The trend is not toward eliminating virtual psychotherapy—it is toward requiring stronger documentation supporting it.
Top 4 National Payers Tightening up on Telehealth
- UnitedHealthcare
UnitedHealthcare continues to cover telehealth services for many commercial plans, including behavioral health. However, its reimbursement policy now includes:
- A published list of CPT codes eligible for telehealth reimbursement.
- A separate list of CPT codes eligible for audio-only services.
- Modifier 93 is accepted only for designated audio-only services.
- POS 02 and POS 10 remain acceptable depending on where the patient is located.
- Providers are expected to follow the payer’s code-specific telehealth policy rather than assuming all services qualify.
- Aetna
Aetna has generally maintained telehealth coverage but increasingly distinguishes between:
- Audio-video telehealth
- Audio-only telephone encounters
Certain policies specify that audio-only services are reimbursed only under specific circumstances, and providers should review plan-specific policies because requirements vary by product and state.
For behavioral health, many Aetna plans continue covering psychotherapy and psychiatric services via telehealth, but documentation and coding expectations have become more stringent.
- The Cigna Group (Evernorth)
Cigna has also moved toward more defined telehealth policies.
Industry guidance notes that Cigna has narrowed reimbursement for audio-only encounters, with behavioral health remaining one of the primary areas where audio-only services may continue to be reimbursable under appropriate circumstances. Providers should verify eligibility by plan
- Blue Cross Blue Shield Association (BCBS)
Blue Cross Blue Shield plans are administered independently, meaning telehealth rules vary by state and by individual Blue plan.
Common trends include:
- Publication of payer-specific telehealth CPT lists
- Required modifier 95 or 93
- Required POS reporting
- Increasing documentation expectations
- More frequent post-payment audits
Rather than assuming “BCBS covers telehealth,” providers should verify each local Blue plan’s reimbursement policy.
What we’re seeing across commercial payers in geneal
1. Audio-only is becoming more limited
During COVID, many insurers paid for virtually every behavioral health visit performed by telephone.
Today, most commercial payers:
- Limit which CPT codes qualify
- Require modifier 93
- Restrict reimbursement to behavioral health or other defined clinical situations
- Require documentation supporting why audio-only was appropriate
2. Telehealth code lists are replacing blanket coverage
Instead of saying
“All psychotherapy may be billed via telehealth”
Many insurers now publish:
- Eligible CPT codes
- Eligible HCPCS codes
- Eligible provider types
- Eligible modifiers
This means providers must confirm that each billed service appears on the payer’s current telehealth policy.
3. Documentation scrutiny is increasing
Commercial payers increasingly expect documentation to include:
- patient consent
- patient location
- provider location
- telehealth platform
- medical necessity
- audio-only rationale when applicable
These items are becoming common targets during audits.
4. Modifier accuracy matters more than ever
Incorrect reporting of:
- POS 02
- POS 10
- Modifier 95
- Modifier 93
can result in denials even when the underlying service itself is covered.
Our Recommendations for Behavioral Health Practices
At Access Revenue Hawaii, we recommend that every behavioral health organization complete a telehealth compliance review before evolving payer policies lead to avoidable denials.
- Ask for a random chart audit:
Check with your Account Success Manager to ensure your documentation is audited and that your facility or practice meets documentation standards. While Access Revenue recommended a few important modifications to session notes, the list grows as more and more payers look for that one sentence that failed to meet criteria and recoup funds post-payment - If you’re providing telehealth, especially in higher levels of care such as ASAM 0.5, 1.5, 2.1, or a LOCUS level of care
Make sure your VOB shows that telehealth is specifically covered for the services you’re providing across payers. - Request a Provider Sync meeting to discuss telehealth in Hawaii, CMS, and National payers.
Your account success manager will always be sure to inform you of major changes but if you’re curious, ask; get an audit, and request an in-service with one of our Utilization Review team members.
The Bottom Line
Telehealth is not disappearing.
Rather, insurers are transitioning from the broad emergency flexibilities of the pandemic era toward more permanent, structured reimbursement policies.
For Hawaii behavioral health providers, the State’s continued commitment to telehealth through 2027 provides significant protection for patient access. At the same time, commercial payers are increasingly emphasizing documentation quality, appropriate technology, and accurate billing practices.
Organizations that proactively adapt their workflows today will be best positioned to maintain reimbursement, reduce denials, and continue delivering accessible behavioral health care throughout Hawaii.
2026 Hawaii Behavioral Health Telehealth Guide
| Payer | Audio-Only | Video Telehealth | Modifier | Notes |
| HMSA | ✓ | ✓ | 95 / 93 | Hawaii-specific requirements |
| AlohaCare | ✓ | ✓ | Plan-specific | QUEST considerations |
| UHC Commercial | Limited CPT list | ✓ | 93 / 95 | Code-specific policy |
| UHC Community Plan | Varies | ✓ | Plan-specific | Medicaid rules differ |
| UHA | Limited | ✓ | 95 | Hawaii commercial |
| HMAA | Limited | ✓ | 95 | Hawaii commercial |
| TRICARE West | Limited | ✓ | Per policy | Behavioral health exceptions |
| Medicare | Permanent BH audio-only | ✓ | AO/AV guidance | Extended through 2027 |
Need Help Navigating Telehealth Billing Changes?
Access Revenue Hawaii helps behavioral health organizations stay ahead of evolving payer requirements through comprehensive revenue cycle management, payer policy monitoring, claim audits, denial prevention, and billing compliance reviews.
Whether your practice provides psychotherapy, psychiatric medication management, intensive outpatient services, or substance use treatment, our team can help ensure your telehealth workflows remain compliant and reimbursement-ready.
Schedule your complimentary Revenue Cycle Assessment today and let our experts identify opportunities to reduce denials and strengthen your revenue cycle before payer changes impact your bottom line.