Given that the technical assistance questions the Center for Connected Health Policy (CCHP) receives most often are related to cross-state practice via telehealth, CCHP has created several new resources related to licensure that are now available:
Out-of-State Telehealth Provider Policies Fact Sheet and Chart
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Limited Licensure Exceptions capture any kind of exception, no matter how limited or specific, including provider-to-provider consultation exceptions as well as broader allowances related to established relationships, infrequent interactions, and/or certain types of care. In addition, Telehealth License/Registration processes and Compacts may not always be active, however some type of authority or process was found to exist in state policy. These types of nuances demonstrate the complexities in trying to assess and categorize such policies, which is why CCHP always encourages readers to review each state’s policies closely to understand additional details and determine any particular requirements. For instance, even if a state is listed as having a limited licensure exception, registration process or being a member of a compact, the policy may not apply to all providers, patients, and circumstances. Additional policies may apply to the care as well (including policies related to malpractice coverage, consent and/or prescribing), therefore, it is always best for providers to check with both the appropriate board in their state and the state the patient will be located in at the time of the visit to ensure full compliance. It is also important to note that compliance with state licensure and practice requirements doesn’t necessarily guarantee insurer coverage of services provided.
For specific state policies and additional details, please review CCHP’s Cross-State Licensing web page and Licensure Compacts page. In terms of insurer coverage, locational limitations may apply to out-of-state providers. CCHP tracks Medicaid policies for out-of-state providers, whereas Medicare generally requires providers to comply with state licensure policies. Providers should check with private payers directly as their rules may vary. The policies surrounding licensure continue to evolve and can potentially change at any time. The information in CCHP’s new resources is based on the latest updates to CCHP’s Policy Finder as of July 18, 2024, with state updates made between May and July 2024. CCHP continually updates the information on our Policy Finder, therefore it is important to routinely check the state(s) in which one may be interested to ensure awareness of any recent developments.
Out-of-State Telehealth Provider Policies Policy Trend Map
To coincide with the fact sheet, CCHP has also 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. |
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Out-of-State Telehealth Provider Policies
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Cross-State Licensure & Compacts Webinar
The California Telehealth Policy Coalition, which is convened by CCHP, recently held a webinar regarding Cross-State Licensure and Compacts to discuss the cross-state licensure policy continuum with various experts and stakeholders. The webinar provides an overview of the licensure landscape nationally as well as in California, which historically has been one of the states with the least allowances for out-of-state providers, only having an exception for provider consultations until last year. Washington's experience in adopting various licensure exceptions and compacts is also provided by Micah Matthews, Deputy Executive and Legislative Director for the Washington Medical Commission. The speakers, including Dr. Helen Hughes, Medical Director of the Office of Telemedicine at Johns Hopkins Medicine, also cover many of the common concerns and policy intricacies to be addressed when adopting licensure policies that can serve as a model for states that are considering similar proposals. Also discussed in the webinar are various federal proposals impacting and addressing a primarily state focused regulatory area. Kelly Goss, Managing Director of Advocacy for the ALS Association, and Tyler Rinde, Director of Government Affairs for the California Psychological Association, provide additional patient and provider perspectives on licensure policy, as well as describe their experience working on licensure exceptions and compact legislation in California. Lending his own vast policy expertise to the conversation as moderator of the discussion panel is Mike Kurliand, Vice President of Clinical Quality and Integration for MedWand Solutions, Inc. For all the licensure policy insights provided, please view the webinar recording in its entirety.
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CCHP knows that telehealth policy can be a complicated subject and from time to time questions about policies related to your specific situation may arise.
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