OHP Telehealth Billing for Therapists

Last updated: July 5, 2026.

If you are a therapist billing the Oregon Health Plan (OHP) for a video or phone session, the two things that decide whether the claim is clean are the place of service (POS) and the modifier. Oregon spells both out in one administrative rule — OAR 410-120-1990. Get the POS and modifier right, document consent, and hold an active Oregon license plus OHP enrollment, and OHP telehealth billing is fairly mechanical.

This guide walks Oregon behavioral-health providers through the current version of that rule: who can deliver OHP telehealth, the consent and privacy basics, and — the part everyone searches for — when to use POS 02 vs POS 10 and modifier 95 vs modifier 93. It closes with a setup checklist and the CCO caveats that trip people up.

TL;DR: Under OAR 410-120-1990 (current version effective April 25, 2025), an OHP telehealth provider must hold an unencumbered Oregon license and be enrolled with OHA as an OHP provider. Get and document client consent before the first telehealth service and update it at least annually. On the claim, set the place of service by where the client is — POS 10 when they are at home, POS 02 when they are somewhere other than home — and add modifier 95 for real-time audio-and-video or modifier 93 for real-time audio-only (phone). Coordinated care organizations (CCOs) can layer their own rules on top, so confirm plan policy before you bill.

The one-line version: POS answers "where is the client?" and the modifier answers "audio-and-video, or audio-only?" — set both from the rule, not from muscle memory carried over from another payer.

The Rule to Know: OAR 410-120-1990

Oregon consolidates OHP telehealth policy into one rule, OAR 410-120-1990 (Telehealth), in the Oregon Health Authority (OHA) General Rules. It is the authority for the definitions, the provider requirements, the consent language, the privacy/security expectations, and the specific place-of-service codes and modifiers used on telehealth claims. The current version was last amended effective April 25, 2025. Because Oregon has revised this rule more than once, always open the live rule on the Oregon Secretary of State site and confirm the effective date before you rely on a specific detail.

The rule uses two related terms. "Telehealth" is the broad category — using electronic information and telecommunications technology to support remote clinical health services. "Telemedicine" is the narrower mode of delivering remote clinical services in real time. For an outpatient therapist, the practical upshot is that both real-time video and real-time audio-only encounters fall under this rule, each with its own claim coding.

Who Can Provide OHP Telehealth?

OAR 410-120-1990 sets baseline provider requirements. To deliver and bill OHP telehealth, a clinician must:

• Hold an unencumbered Oregon license. The rule requires a current, unencumbered Oregon license appropriate to the service. Telehealth does not waive Oregon licensure — the client is in Oregon, so you are practicing in Oregon.

• Be enrolled with OHA as an OHP provider. The rule points to OHP provider enrollment under OAR 410-120-1260. Enrollment (and an actively enrolled NPI for the dates of service) is what lets a claim adjudicate at all.

• Stay within your board’s scope of practice. Services must fall within your certification or licensing board’s scope. Telehealth is a delivery channel, not a license to provide services you could not provide in person.

One thing to keep separate: being enrolled with OHA does not, by itself, put you in-network with any coordinated care organization. Enrollment is the state lane; CCO participation is a separate contracting step. We map that split in the Oregon Medicaid credentialing pillar and in OHP enrollment vs. CCO credentialing.

Client Consent and Access Requirements

OAR 410-120-1990 requires client consent for telehealth. A few specifics worth getting right:

• Get consent before the service. Consent to receive services by telehealth must be obtained prior to delivering the telehealth service. The rule allows written, oral, or recorded consent.

• Refresh it at least annually. Telehealth consent must be updated at least annually thereafter — so this is not a one-and-done form. Build the annual refresh into your workflow.

• Meet the client where they are. Consent should be captured in a way the client understands, in their preferred language. Access and modality choices should support the client rather than create a barrier to care.

Practically, document the consent and its date in the chart the same way you document any other required intake element, and set a reminder so the annual update does not lapse quietly.

Privacy, Security, and Documentation Basics

The rule ties OHP telehealth to the same privacy, security, and recordkeeping standards as in-person care:

• HIPAA and OHA privacy rules apply. Telehealth services must comply with HIPAA and the Authority’s privacy rules. Use a platform and workflow that protect protected health information.

• Have policies to prevent a breach. The rule expects providers to maintain policies and procedures to prevent a privacy breach, not just to react to one.

• Keep the same clinical and financial documentation. Telehealth encounters must be documented and records retained under the general documentation rule (OAR 410-120-1360). A telehealth note should stand on its own for an audit, including that the service was delivered via telehealth and how (video vs. audio-only).

A useful habit: note the modality inside the progress note, not only on the claim. If the claim shows modifier 93 (audio-only) but the note reads like a video visit, that mismatch is exactly what a post-payment review flags.

POS 02 vs. POS 10

Oregon sets the telehealth place of service by where the client is located at the time of the session — not where you, the provider, are sitting. Under OAR 410-120-1990:

• POS 10 — client is in their home. Use place of service code 10 when the client or member is located in their home during the telehealth service.

• POS 02 — client is somewhere other than home. Use place of service code 02 when the client or member is located in a place other than their home (for example, at work, at school, or in another facility).

The common mistake: defaulting every telehealth claim to POS 02 out of habit. For outpatient therapy, most sessions are with a client at home, which is POS 10. Confirm the client’s location as part of the visit and let that drive the POS — do not hard-code one code for all telehealth.

Modifier 95 vs. Modifier 93

Where POS captures the client’s location, the modifier captures the modality. OAR 410-120-1990 uses two:

• Modifier 95 — real-time audio and video. Append modifier 95 when the telehealth service uses a real-time, interactive audio-and-video telecommunication system. This is the standard video therapy session.

• Modifier 93 — real-time audio-only. Append modifier 93 when the same service is delivered by real-time, interactive audio-only (for example, a telephone session with no video).

So OHP does recognize audio-only therapy: the encounter is billed with the appropriate service code plus modifier 93, and the POS is still set by where the client is (POS 10 at home, POS 02 otherwise). The modifier tells the plan how the service was delivered; the POS tells it where the client was. You typically need both, and they should agree with your note.

Quick reference: Client at home + video = POS 10, modifier 95. Client at home + phone only = POS 10, modifier 93. Client not at home + video = POS 02, modifier 95. Client not at home + phone only = POS 02, modifier 93. Confirm covered service codes and any plan-specific overrides before submitting.

CCO Caveats: Do Not Assume Every Plan Bills the Same

OAR 410-120-1990 is the OHA baseline, and it governs fee-for-service (Open Card) OHP telehealth. But most OHP members are enrolled in a coordinated care organization (CCO), and each CCO administers its own provider network, prior-authorization rules, covered-code lists, and billing guidance. A CCO generally follows the state telehealth framework, but it can add requirements — a specific portal, its own telehealth policy, or plan-level documentation expectations.

Two practical rules of thumb:

• Check eligibility and the plan on the date of service. Whether a member is Open Card or in a CCO — and which CCO — determines where the claim goes and whose telehealth policy applies. See verifying OHP eligibility (CCO vs. Open Card).

• Confirm the CCO’s telehealth policy, do not assume it. Two CCOs can handle the same audio-only session slightly differently. When in doubt, confirm with the plan before you submit, and track it. Our Oregon Medicaid claims guide (Open Card vs. CCO) covers claim routing in more detail.

EHR and Billing Setup Checklist

A little configuration up front prevents most OHP telehealth denials. Before you bill your next telehealth session, make sure your setup handles:

• An active Oregon license on file and an actively enrolled OHP NPI for the dates of service.

• A telehealth consent captured before the first telehealth service, with an annual-update reminder so it does not lapse.

• A note template that records the modality (video vs. audio-only) and the client’s location during the session.

• POS logic driven by where the client is: POS 10 for home, POS 02 for other locations.

• Modifier logic driven by modality: modifier 95 for audio-and-video, modifier 93 for audio-only.

• A HIPAA-compliant telehealth platform and privacy/security policies.

• Per-CCO billing notes so a member’s plan drives any plan-specific handling.

Action Steps for Providers

1. Open the live rule and confirm the effective date. Read OAR 410-120-1990 on the Oregon Secretary of State site before relying on any POS/modifier detail.

2. Confirm your license and OHP enrollment are active. Unencumbered Oregon license plus an enrolled NPI for the dates of service.

3. Get and document consent — then diarize the annual refresh. Written, oral, or recorded consent before the first telehealth service, updated at least annually.

4. Set POS by client location. POS 10 when the client is home; POS 02 when they are not.

5. Set the modifier by modality. Modifier 95 for real-time audio-and-video; modifier 93 for real-time audio-only.

6. Make the note match the claim. Document modality and location so the note supports the POS and modifier.

7. Check the member’s plan before billing. Open Card vs. CCO — and which CCO — decides where the claim goes and whose telehealth policy applies.

Where Bomi Fits

Bomi helps therapy practices keep the operational side of OHP telehealth billing straight — eligibility checks to confirm a member’s plan on the date of service, claim setup so POS and modifiers match the rule and the note, denial follow-up, EOB review, and credentialing and payer follow-up — inside the EHR you already use. For Oregon telehealth specifically, that means catching a POS/modifier mismatch before it becomes a denial and keeping per-CCO quirks from turning into rework.

You can see how we approach billing operations and credentialing, or start from the Oregon overview.

The honest version: no billing partner can guarantee a claim pays or that a CCO accepts you into its network. What Bomi can do is keep enrollment, consent, coding, and per-plan rules in the right order so fewer OHP telehealth dollars fall through the gaps.

Want help keeping Oregon Medicaid billing and credentialing workflows straight? Bomi helps therapy practices with eligibility checks, claims, denials, credentialing, payer follow-up, EOB review, and revenue operations so clinicians can spend more time with clients.

FAQ

What POS code should Oregon therapists use for OHP telehealth?

Set the place of service by where the client is located during the session. Under OAR 410-120-1990, use POS 10 when the client is in their home and POS 02 when the client is somewhere other than their home. The POS is not based on where you, the provider, are located.

When should I use modifier 95?

Use modifier 95 when the telehealth service is delivered by a real-time, interactive audio-and-video telecommunication system — the standard video therapy session. Pair it with the POS that matches the client’s location.

When should I use modifier 93?

Use modifier 93 when the same service is delivered by real-time, interactive audio-only — for example, a telephone session with no video. The POS is still set by the client’s location (POS 10 at home, POS 02 otherwise).

Does OHP cover audio-only therapy?

Yes. OAR 410-120-1990 recognizes real-time audio-only telehealth and provides modifier 93 for it. Bill the covered service code with modifier 93 and the appropriate POS, document the modality in the note, and confirm the member’s plan (Open Card or CCO) handles audio-only as expected.

Do CCOs follow the same telehealth rules?

OAR 410-120-1990 is the OHA baseline and applies to fee-for-service (Open Card) OHP. Coordinated care organizations generally follow the state framework but can add their own portal, prior-authorization, covered-code, or documentation requirements. Do not assume every CCO processes telehealth identically — confirm the specific plan’s policy before you bill.

What do I need to bill OHP telehealth at all?

An unencumbered Oregon license, active enrollment with OHA as an OHP provider (with an enrolled NPI for the dates of service), documented client consent obtained before the first telehealth service and updated at least annually, HIPAA-compliant delivery, and claims coded with the correct POS and modifier.

This post is for general operational education and is not legal, compliance, or billing advice. Always confirm current OHA and CCO requirements before submitting enrollment, claims, or authorizations.

Sources

• OAR 410-120-1990 (Telehealth) — Oregon Secretary of State

• OAR 410-120-1260 (Provider Enrollment) — Oregon Secretary of State

• OHA: Billing for OHP services

• OHA: Professional Billing Instructions (PDF)

• OHA: OHP provider enrollment

• OHA: Oregon Medicaid (MMIS) Provider Portal

• OHA: Coordinated care organizations (CCOs)

• Oregon Medicaid credentialing pillar

• Bomi Billing

• Bomi Credentialing