 Today the Center for Connected Health Policy (CCHP) is releasing its Summary of state telehealth policy changes for 2024. Additionally, we are also making available a state summary chart showing where states stand on many key telehealth policies, as well as an infographic highlighting our key findings. As always, the most current information in CCHP’s online policy finder tool may be exported for each state into a PDF document. Note that the last review period for this report was late May through early September 2024. It is possible that in some cases, after a state was reviewed by CCHP, the state may have passed a significant piece of legislation or implemented an administrative policy change that CCHP may not have captured in this update of the report. Those types of changes will be incorporated into future updates of our online policy finder. |
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Traditionally, CCHP has released bi-annual summary reports each Spring and Fall to offer a snapshot of policy progress over the previous six months. However, last year CCHP announced a shift to an annual reporting schedule, with three rounds of updates to each jurisdiction within the online Policy Finder throughout the year.
Additionally, sections of CCHP’s policy finder addressing COVID temporary policy, as well as policy related specifically to federally qualified health centers (FQHCs) (which had been included as a separate category in CCHP’s online policy finder in previous years), have been phased out. COVID telehealth policies that have been made permanent or extended for multiple years have been incorporated into the appropriate relevant sections of the current policy finder categories. Some FQHC policy addressing telehealth policies explicitly can also still be found in CCHP’s policy finder, often under the Medicaid section in the applicable topic area.
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HIGHLIGHTED FINDINGS
MEDICAID REIMBURSEMENT
As telehealth evolves in the post-COVID era, states are increasingly consolidating and refining their Medicaid telehealth policies, though approaches vary widely. Some states, have recently updated their Medicaid manuals to include dedicated telehealth sections, including Delaware which updated their practitioner manual to include a telehealth section and New York which has a new telehealth policy manual. Still, other Medicaid programs, like Connecticut, maintain telehealth reimbursement information primarily within Medicaid bulletins. Recent policy updates and trends reflect an increased acceptance of diverse providers. |
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For example, Wisconsin Medicaid clarified through a Medicaid Update that qualified treatment trainees can provide telehealth services under proper supervision, and Utah Senate Bill 24 expanded telepsychiatric services to physician assistants. Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) have also been increasingly designated as distant site providers, allowing broader telehealth access within these essential healthcare hubs. Hawaii, for example, updated its Medicaid dental manual to allow FQHCs to submit telehealth claims under the Prospective Payment System (PPS), provided that both the patient and dentist are located at separate eligible FQHC or RHC sites. Out-of-state provider enrollment policies have also become more flexible in many states. For instance, Indiana Medicaid introduced a telehealth-only provider enrollment option in their Telehealth and Virtual Services Manual, while Michigan issued a Policy Update allowing out-of-state providers to participate if they meet state licensure requirements. Similarly, California, North Dakota and Utah, have established exemptions or streamlined requirements for certain remote service providers.
Telehealth services eligible for reimbursement are also expanding. Arkansas Medicaid now allows ambulance services to use telemedicine for triage and non-emergency cases, and Colorado Medicaid supports telehealth for school-based services. In addition, doula services have been added in New York and preventive counseling have been added in California, enhancing care options for vulnerable populations. Several states have introduced reimbursement for electronic consultations (e-Consults) as a way to facilitate interprofessional advice without a direct patient interaction. Since Fall 2023, states that have added e-Consults include Colorado, Maine, Michigan, and New York, though each state’s approach to implementation differs. |
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Remote patient monitoring (RPM) has also gained traction, particularly for chronic conditions. Some states, including Georgia, Missouri, and South Carolina, have recently introduced coverage specifically for continuous glucose monitoring. Colorado passed SB 24-168 mandating RPM reimbursement for specific outpatient clinical services, while South Dakota established RPM coverage in their Telemedicine Services Provider Manual for acute and chronic conditions when medically necessary. Restrictions on telehealth services still exist in many states, particularly regarding audio-only consultations. Some states, like Nevada, have expanded audio-only beyond behavioral health but maintain restrictions to ensure clinical appropriateness. States such as Vermont, Virginia, and Washington have designated specific CPT codes for audio-only services, often requiring modifier 93 to indicate the modality used.
States are also implementing new patient-centered regulations. For example, California now requires Medicaid providers to offer patients a choice between audio-visual and audio-only telehealth options and ensure access to in-person care if needed. Washington has enhanced its telehealth policies with a focus on accessibility and equity, requiring providers to assess patients' need for assistive devices. These measures aim to balance telehealth access expansions with service quality and patient rights protections. Nevertheless, instituting requirements specific to Medicaid patients may create confusion and access inconsistencies across providers and payers.
PRIVATE PAYER |
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While the majority of states already had laws on the books requiring private payers to cover telehealth services, a few jurisdictions did add laws recently. Notably, Puerto Rico and Pennsylvania both added new policies. Pennsylvania’s new law (Senate Bill 739) ensures coverage for medically necessary telemedicine services and prevents insurers from requiring proprietary telemedicine platforms, supporting flexibility for providers. Puerto Rico’s new regulation around telehealth further expanded access by allowing telehealth billing to both private insurers and Medicaid. Additionally, New York extended its temporary COVID-era reimbursement parity law to April 1, 2026. These developments reflect an ongoing trend toward making telehealth a viable, accessible option for both patients and providers.
PROFESSIONAL REQUIREMENTS |
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States are refining telehealth policies across professions to ensure safe, high-quality care, and expanding telehealth standards while acknowledging hands-on limitations. Arkansas, for instance, introduced telehealth standards for dietitians and audiologists, while West Virginia now excludes telehealth for massage therapy and acupuncture. Additional specialties are also starting to incorporate telehealth into their professional requirements, addressing healthcare providers that previously may have been untouched by telehealth regulation. Colorado, for example, passed House Bill 24-1048 which outlines telehealth standards for veterinarians, and Michigan adopted a new administrative code for chiropractors. Where prescribing is concerned, we see that states are adapting to federal guidelines, especially concerning controlled substances. For example, Montana aligned with U.S. Drug Enforcement Administration (DEA) regulations, removing in-person requirements for Schedule II drugs, while Alaska reinstated stricter oversight for buprenorphine post-pandemic for advanced practice registered nurses.
LICENSING |
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| With the growth of telehealth, many states now allow exceptions to in-state licensing requirements, permitting out-of-state providers to offer care under specific conditions. CCHP identified 38 states, along with DC, that have adopted such exceptions. For example, California permits treatment by out-of-state marriage and family therapists, clinical social workers, and counselors, as well as physicians treating patients with life-threatening conditions, provided certain conditions are met. Similarly, the District of Columbia allows out-of-state providers to treat patients temporarily present in the District for up to 120 days without a local license under specific circumstances. Oregon permits follow-up care for established patients temporarily in the state. |
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Additionally, 22 states and the Virgin Islands have established special telehealth registration processes as an alternative to standard licensure processes, such as Arizona’s telehealth provider registration, which also outlines specific practice standards. Washington additionally describes certain situations where an in-state license is not necessary, and Delaware has also introduced streamlined processes for out-of-state telehealth practitioners through an interstate telehealth registration process. These trends highlight states’ careful expansion of cross-state telehealth access while maintaining oversight and standards.
Despite these individual state allowances for out-of-state telehealth providers, interstate licensure compacts continue to be the most widely used tool to allow for out-of-state practice in various professions. We saw the largest jump in state participation within the Social Work Compact, Counseling Compact and Physician Assistant Compact during this Fall 2024 edition of the report. See the full report for specific state participation numbers within each individual Compact.
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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. 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).
- Forty-five states and DC Medicaid programs reimburse for AUDIO-ONLY telephone in some capacity; however, often with limitations.
- 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.
- Forty-seven states, DC, and Puerto Rico include some sort of CONSENT requirement in their statutes, administrative code, and/or Medicaid policies.
- 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.
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VIEW & DOWNLOAD YOUR COPY OF THE NEW RESOURCES:
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The U.S. Drug Enforcement Agency (DEA) has officially issued the anticipated third temporary rule extending the COVID-19 telemedicine flexibilities for the prescription of controlled medications through December 31, 2025. Earlier this year, the DEA drafted a set of permanent rules with substantial limitations (as reported by news outlets, though it was never released publicly), but it stalled due to concerns from the U.S. Department of Health and Human Services (HHS). Last year, a similar proposal generated nearly 40,000 public comments, leading to the ongoing temporary extension. Although the DEA is expected to make another attempt at establishing permanent regulations next year, this third temporary rule ensures that the COVID-era flexibilities for prescribing controlled substances via telehealth will remain in place throughout 2025. It's important to note that this extension applies solely to the waiver of the in-person requirement for controlled substance prescriptions and does not impact the Medicare telehealth requirements set to take effect on January 1, 2025, unless Congress intervenes with new legislation.
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