Tool: Telehealth Policy Finder
Explore telehealth-related laws and regulations from all 50 states and the District of Columbia, as well as at the federal level, with the Policy Finder tool from PHI’s Center for Connected Health Policy.
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Center for Connected Health Policy
Across the country, no two states are alike in how they define and regulate telehealth. To help policymakers, health advocates and other health care professionals understand the policies and trends throughout the nation, the Telehealth Policy Finder tool compiles telehealth-related laws and regulations across all 50 states and the District of Columbia, as well as at the federal level.
Explore the Policy Finder toolMay 2025 Updates: Highlighting the Critical Roles of State Legislatures, Medicaid Programs & Regulatory Boards
These updates serve as a reminder that while national-level changes often make headlines, state-level actions also have a direct and immediate impact on care delivery. Highlighted changes from this group of states include:
• DISTRICT OF COLUMBIA – DC Medicaid released a transmittal regarding 2025 coding updates, which references that while the AMA added new telemedicine codes for 2025, DHCF did not cover these codes. Rather, DC Medicaid affirmed that previously issued guidance will remain in effect for telemedicine services. DC Medicaid also issued final rules around covering medication therapy management, including services via telehealth. Additionally, the DC Department of Behavioral Health renewed emergency regulations that updated when community support services may delivered via audio-only, as well as finalized Assertive Community Treatment regulations that updated when contacts can be delivered via telehealth.
• MASSACHUSETTS – MassHealth (MA Medicaid) released a regulation that stipulates that they now cover medically necessary doula services, including perinatal visits and labor and delivery support, when delivered either in-person or via telehealth.
• MICHIGAN – Michigan Medicaid issued a bulletin announcing that CPT codes 99441–99443 (audio-only E/M services) will be deleted effective December 31, 2024. Beginning January 1, 2025, providers must report the E/M code that best represents the services rendered. In accordance with current Medicaid policy, providers must include the place of service (POS) code as if the visit were in-person, along with modifier 93 for audio-only or modifier 95 for audio-visual telemedicine. Prepaid Inpatient Health Plan (PIHP) and Community Mental Health Services Program (CMHSP) providers must report POS 02 or 10, as applicable. Additional details are available in the “Telemedicine” chapter of the Medicaid Provider Manual and the referenced policies.
• MISSISSIPPI – Mississippi enacted several key health policy changes through recent legislation. First, SB 2415 the state eliminated the July 1, 2025 repeal date for its private payer telehealth coverage law, making the coverage requirement permanent. Mississippi also authorized prescribing for medical cannabis by enacting SB 2748. Additionally, Mississippi passed SB 2727, the Social Work Licensure Compact, allowing greater mobility for licensed social workers across member states.
• NEBRASKA – Nebraska updated its Medicaid administrative code to revise the definition of telehealth and incorporate audio-only services under specific conditions. Audio-only is now allowed for individual behavioral health or crisis management services, but only when clinically appropriate and when there is an existing provider-patient relationship. The update also outlines detailed provider practice guidelines, including a requirement that beneficiaries must not be forced to use telehealth and must be offered in-person services upon request. Telemonitoring provisions and informed consent requirements were also reaffirmed, with minor updates.
• NEW YORK – New York issued various Medicaid updates, including expanded eConsult coverage in outpatient settings, and enhanced reimbursement for integrated eConsults, Physical Health and Behavioral Health eConsults. Additionally, New York Medicaid released an update regarding the Chronic Disease Self-Management Program as well as an update regarding homeless healthcare services, both noting ability to deliver services via telehealth. New York also updated its Medicaid Telehealth Policy Manual to clarify various policies. The Department of Health adopted network adequacy regulations specific to behavioral health services, and the Department of Financial Services similarly adopted network adequacy regulations for mental health and substance use disorder treatment services.
• PENNSYLVANIA – Pennsylvania issued a regulation allowing Opioid Treatment Programs (OTPs) to conduct the initial physical examination via telehealth for patients being admitted with either buprenorphine or methadone, as long as the provider determines that a sufficient evaluation can be performed remotely. A full in-person exam must still be completed within 14 days of admission, and the telehealth evaluation must comply with federal standards under 42 CFR 8.12.
• SOUTH DAKOTA – South Dakota updated its telemedicine manual to clarify coverage and provider requirements. Certain services provided by Substance Use Disorder (SUD) Agencies, Community Mental Health Centers (CMHCs), and Independent Mental Health Practitioners (IMHPs) may now be delivered via telemedicine, but IMHPs cannot bill CPT codes 98966–98968 and may only provide services explicitly listed as allowable. For Diabetes Self-Management Training (DSMT), distant site practitioners must ensure the patient receives one hour of in-person training when indicated. Care coordination, prenatal, and postpartum doula services may be delivered via telemedicine, including audio-only when visual technology is unavailable, if documented. The state also expanded the list of eligible originating sites for the facility fee to include inpatient hospitals and hospital-based renal dialysis centers. Additionally, South Dakota joined the Dietitian Licensure Compact by enacting HB 1144.
• TEXAS – Texas Medicaid added teledentistry as a reimbursable service in the Children’s Services manual. Procedure codes D0120 or D0140 must be billed with teledentistry code D9995 when delivered via synchronous, real-time audiovisual technologies. These services must meet the same standard of care as in-person visits, and for dental maintenance organization (DMO) members, coverage depends on the specific benefit package. Texas also updated its Behavioral Health manual to clarify that Case-Focused Parenting (CFP) services must be accessible and family-centered, with the mode of delivery based on the parent’s, legal authorized representative’s (LAR’s), or caregiver’s preference—not provider convenience. CFP services may be delivered via telehealth or telemedicine, including synchronous audiovisual technology, if clinically appropriate and documented in the child’s plan of care. Services delivered this way must be billed using modifier 95. Audio-only use is also addressed in the manual. Additionally, Texas adopted a regulation clarifying prescription requirements. A valid prescription must be based on a physician-patient relationship and comply with all relevant laws, including the Medical Practice Act and Texas Health and Safety Code Chapters 481 and 483. For chronic pain treatment via telemedicine, physicians must use two-way audio and video communication unless the patient is already under their care, is receiving the same prescription as at their last visit, and has been seen by the physician (or delegate) within the past 90 days—either in person or via two-way audiovisual technology.
• VIRGINIA – Virginia enacted two bills directing Medicaid policy updates related to remote patient monitoring (RPM). Under HB 1976, the Department of Medical Assistance Services (DMAS) will update regulations and manuals to clarify that RPM services for high-risk pregnant patients include those with maternal diabetes and maternal hypertension. DMAS must also report on utilization and costs to state leadership by November 1, 2025. Separately, SB 843 requires DMAS to develop a plan and cost estimate for expanding RPM eligibility to individuals with chronic conditions, with a report due to the Joint Commission on Health Care by October 1, 2025.
• WASHINGTON – Washington Medicaid (Apple Health) issued an alert to clarify that Medicaid does not pay for audio-only telemedicine under the birth doula benefit. The eligible Apple Health audio-only codes were updated, and another provider alert announced Medicaid coverage of community health worker services, some of which can be provided via telehealth, though limitations apply. An alert regarding availability of a Perinatal Psychiatry Consultation Line states that Perinatal PCL offers free provider-to-provider consultations to health care providers in Washington State. The Washington Health Care Authority renewed emergency rules to implement the agency's apple health expansion program to provide health care coverage for adults who qualify. The rules state that the agency's rules related to the authorized use of telemedicine and store and forward technology are found in WAC 182-501-0300 and are applicable to Washington apple health expansion benefits, including those administered by the health plan. The Department of Health published final rules regarding medical assistants. Consistent with recent statutory changes, the rules update the definition for "telemedicine supervision" to include "interactive audio or visual" when referring to telemedicine technology as it relates to the purpose of treating a known or suspected syphilis infection.
Fall 2024 Updates
As some states have implemented targeted exceptions from licensing requirements for out-of-state telehealth providers since Fall 2023 (as discussed above), other states have implemented special registrations or licensure processes for out-of-state telehealth providers, allowing an alternative process to full in-state licensure to offer telehealth services within the state in certain instances and subject to specific requirements. Twenty-two states, as well as the Virgin Islands now offer special telehealth licenses, or registration processes for out-of-state providers. To be counted in this number, the licenses/registrations did need to specifically reference telehealth (or remote care) in some way. A recent state to implement this is Arizona, which introduced new regulations (implementing a previously passed law) that establishes a telehealth provider registration process for out-of-state providers, outlining practice standards such as consent and liability insurance requirements within it. In Washington, SB 5481 enacted the Uniform Telehealth Act, which in addition to adopting limited licensure exceptions for out-of-state providers, encourages a review of the Uniform Law Commission’s proposal for an out-of-state provider registration process, signaling the state’s interest in developing a more formalized approach. Delaware also adopted regulations that allow social workers practicing via interstate telehealth to bypass the need for a full Delaware license if they are registered under the state’s telehealth registration system.
Although states have introduced specific provisions for out-of-state providers, interstate compacts remain the most common method for enabling out-of-state practitioners to work across multiple professions and states. These compacts typically allow specific healthcare providers to practice in states where they are not licensed, provided they hold a valid license in their home state, and possess a special ‘compact’ license. Currently, CCHP monitors twelve different Compacts, each with its own distinct eligibility criteria and process. For instance, the Interstate Medical Licensure Compact streamlines the licensure process, although physicians are still required to apply for licenses in individual states. We saw the largest jump in participation in the Social Work Compact, Counseling Compact and Physician Assistant Compact during this Fall 2024 edition of the report. Since last year, a new Compact was also added to CCHP’s tracking, the Dietitian Compact. So far, only three states (Alabama, Nebraska and Tennessee) are member states. In addition, as some compacts are relatively new, not all are currently considered active and/or issuing licenses at this time.
Read the full Fall 2024 report, and explore the state summary chart showing where states stand on many key telehealth policies, as well as an infographic highlighting key findings.
Additional findings:
- Fifty states, Washington DC and Puerto Rico provide reimbursement for some form of live video in Medicaid fee-for-service. The Virgin Islands does not explicitly indicate they reimburse for live video in their permanent Medicaid policies.
- Thirty-seven state Medicaid programs reimburse for store-and-forward. Colorado, Delaware, New Hampshire, and Pennsylvania are the states which added reimbursement for store-and-forward, although each in a limited capacity. Note that some states only reimburse store-and-forward through specific communication technology-based service (CTBS) codes.
- Forty-two state Medicaid programs provide reimbursement for remote patient monitoring (RPM). Five states, (Delaware, New Hampshire, New Jersey, Pennsylvania and South Dakota) added reimbursement for RPM since Fall 2023.
- Forty-five states and DC Medicaid programs reimburse for audio-only telephone in some capacity; however, often with limitations. Two states, Delaware and West Virginia, added reimbursement for audioonly telehealth in some capacity since Fall 2023.
- Thirty-one state Medicaid programs including Alaska, Arizona, California, Colorado, Delaware, Hawaii, Illinois, Iowa, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, New Hampshire, New York, North Carolina, North Dakota, Ohio, Oregon, Pennsylvania, South Carolina, South Dakota, Texas, Utah, Vermont, Virginia, Washington, West Virginia, and Wisconsin reimburse for all four modalities (live video, store-and-forward, remote patient monitoring and audio-only), although certain limitations may apply.
- Forty-four states, the District of Columbia, Puerto Rico and the Virgin Islands have a private payer law that addresses telehealth reimbursement. Not all of these laws require reimbursement or payment parity. Twenty-three states have explicit payment parity. Both Puerto Rico and Pennsylvania are the two new states that have added private payer policies since Fall 2023.
- Forty-seven states, DC, and Puerto Rico include some sort of consent requirement in their statutes, administrative code, and/or Medicaid policies. South Dakota and Montana added consent requirements since Fall 2023.
- Thirty-eight states, as well as DC offer some type of exception to licensing requirements. Note that while CCHP’s search of statute and regulations was confined to telehealth, if we happened to come across a more general licensing exception, we did include it in our reporting, and in this number. CCHP also found that twenty-two states as well as the Virgin Islands have telehealth-specific special registration or licensure processes as an alternative to full licensure for certain providers or as an additional requirement to utilize telehealth. To be counted in this number, the licenses/registrations did need to specifically reference telehealth (or remote care) in some way.
- Many states continue to implement telehealth practice requirements for various professions. While the majority of states have telehealth practice standards in place for certain providers, such as physicians and mental health professionals, more state boards are starting to adopt professional standards for other types of practices, for example acupuncture providers and dietitians.
- While CCHP doesn’t keep specific counts of states with prescribing requirements (because there are so many caveats and exceptions), we do include it as a category under Professional Requirements in our Policy Finder. Since Fall 2023, several states have implemented new rules around prescribing via telehealth, especially for controlled substances.
Out-of-State Policy Trend Map
CCHP has added an Out-of-State Telehealth Providers policy trend map to the CCHP website which color codes states based on the presence of limited licensure exceptions, telehealth registration processes, or both. This webpage also provides a link to CCHP’s Interstate Licensure Compacts information, showing Compact participation status by state.
Getting started with the Policy Finder
Launched in Spring 2021 by PHI’s Center for Connected Health Policy (CCHP), the Policy Finder tool is a searchable, easy-to-use database that is updated consistently throughout the year. Formerly known as the State Telehealth Laws and Reimbursement Report, the information from the online database can be exported for each state into a PDF document using the most current information available on CCHP’s website.
Use the Policy Finder tool to:
- Look up telehealth-related laws and regulations by topic, including COVID-19, Medicaid & Medicare, Private Payer and Professional Requirements
- Explore all current laws, temporary COVID-19 actions, and pending legislation in all 50 states and the District of Columbia, as well as at the federal level
- Compare the policy of any of the topic areas for any two states
- View color-coded maps recapping policy trends by state across topic areas, including Medicaid reimbursement for live video, store and forward and remote patient monitoring
The Policy Finder is designed to provide timely policy information that is easy for users to navigate and understand. Watch a quick tutorial to explore the tool, see how to use it and learn about its features:
Please note: this information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.
Originally published by Center for Connected Health Policy
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