Latest Developments in CCHP’s Telehealth Policy Finder
CCHP’s Telehealth Policy Finder look-up tool and Policy Trend Maps were updated throughout the past month based on the latest information from our ongoing state telehealth policy tracking. The latest states to be updated include Alabama, Alaska, Arizona, Arkansas, Colorado, Florida, Hawaii, Idaho, Illinois, Louisiana, Maine, Montana, New Mexico, North Dakota, Ohio, Oklahoma, Rhode Island, and Wyoming.
Multiple states have recently made changes to their telehealth policies in an array of policy areas, including their Medicaid programs, private payer laws, professional regulations, and cross-state licensing. Highlighted changes from this group of states include:
- ALABAMA: The Alabama Medicaid Agency has updated its Remote Patient Monitoring (RPM) Manual to clarify the validity period for provider orders. Initial and annual RPM provider orders are now valid for one calendar year, and new orders must be obtained at least annually, but no later than 30 calendar days from the date of the previous order. Additionally, beginning July 1, 2025 according to a Medicaid Provider Alert, the Alabama Medicaid Provider Directory will include an indicator showing whether a provider offers telehealth-covered services, helping patients more easily identify virtual care options.
- ALASKA: Alaska Medicaid has released a new telehealth fee schedule, now available on its Fee Schedule page. Effective for dates of service on or after January 1, 2025, CPT codes 99441–99443 (audio-only E/M services) have been discontinued. Providers must now use problem-focused exam codes (99202–99205 and 99212–99215) for all modes of telehealth. All required components of these codes must be met to bill appropriately. These changes are effective for billing beginning May 5, 2025. In addition, Alaska updated its statute pertaining to out-of-state provider policy, allowing an exception for ongoing treatment or follow-up care provided by an out-of-state physician or a member of their multidisciplinary care team when addressing a suspected or diagnosed life-threatening condition.
- ARKANSAS: New legislation (SB 213) enacted in Arkansas requires the Medicaid program to reimburse for remote ultrasound procedures when medically necessary and conducted using secure, FDA-approved digital technology. These procedures must collect and transmit health data electronically from a patient at home or another off-site location to a provider for interpretation and follow-up, and must meet the same standard of care as in-person services. This policy applies to both fee-for-service Medicaid and managed care plans. The same legislation also mandates coverage of self-measured blood pressure monitoring (SMBP) services for pregnant and postpartum women. Covered services include validated blood pressure devices and replacement cuffs, patient education and training on device use and calibration, and the collection and transmission of readings for care management. Arkansas also updated its veterinary telemedicine regulations. The regulations specify that only licensed veterinarians may provide telemedicine to animal patients located in the state. In emergencies, veterinarians may initiate care via telemedicine without a pre-established relationship but must formalize a veterinarian-client-patient relationship within 7 days for small animals or 21 days for large animals. Finally, Arkansas has joined several interstate compacts, including the Interstate Medical Licensure Compact (IMLC), Psychology Interjurisdictional Compact (PSYPACT), Emergency Medical Services Compact (REPLICA), and Social Work Licensure Compact.
- COLORADO: A new Colorado rule expands the definition of “Treating Practitioner” under Medicaid to include not only primary care providers but also specialists participating in the Accountable Care Collaborative. Eligible treating practitioners may now include medical doctors (MDs), doctors of osteopathy (DOs), nurse practitioners (NPs), and physician assistants (PAs) with training or qualifications in specialty fields other than primary care, provided they are involved in the member’s care. Additionally, Colorado passed Senate Bill 194, establishing a formal definition for teledentistry. The law defines teledentistry as the use of telehealth technologies—such as electronic communications, remote monitoring, and store-and-forward methods—to deliver oral health services. These services may include assessment, diagnosis, consultation, education, and treatment planning for patients located at an originating site without a dental practitioner, while the licensed dental provider delivers services from a distant site. The technologies must comply with HIPAA requirements.
- HAWAII: Passed HB 951 allowing a healthcare provider to prescribe a three-day supply of opiates via telehealth to a patient who has already been seen in-person by another health care provider in the same medical group. The Hawaiian legislature hopes these changes to prescribing policy will help address barriers to short-term opiate protections while avoiding issues around overprescribing and misuse.
- MONTANA: Montana Healthcare Programs has issued a provider notice related to continuous glucose monitors. Due to a noticeable increase in denied claims, providers are reminded of proper billing procedures for continuous glucose monitor (CGM) supply allowances. Codes A4238 (adjunctive) and A4239 (non-adjunctive) for non-implanted CGMs may only be billed once per month as a single unit of service, inclusive of all necessary supplies and accessories. Providers are encouraged to consult the CMS Policy Article A52464 for detailed guidance. Montana Medicaid also released a provider notice discontinuing the use of audio-only E/M codes 99441–99443, which were implemented during the Public Health Emergency (PHE). These have been replaced by codes 98000–98015, which may be billed with the appropriate revenue code depending on provider type. Alternatively, providers may bill a standard E/M code with the appropriate modifier and revenue code. Montana also passed HB 60, which prohibits insurers from applying higher deductibles, coinsurance, copayments, or other limitations to telehealth services than those applied to in-person care. Finally, Montana has joined several licensure compacts, including those for Dietitians Compact, Physician Assistants (PA), and the Psychology Interjurisdictional Compact (PSYPACT).
- NEW MEXICO: New Mexico has updated its Behavioral Health Policy and Billing Manual to include expanded guidance and coverage details for several behavioral health services. These now include Dialectical Behavior Therapy (DBT), Eye Movement Desensitization and Reprocessing (EMDR), Functional Family Therapy (FFT), Inpatient Psychiatric Care in freestanding psychiatric hospitals and acute care hospital units, Medication for Opioid Use Disorder (MOUD), Multi-Systemic Therapy (MST), Opioid Treatment Programs (OTPs), and Trauma-Focused Cognitive Behavioral Therapy (TF-CBT). In addition, the state enacted Senate Bill 252 encouraging health insurers, HMOs, MCOs, and third-party payors to offer telehealth coverage within their plans, and similarly encourages the state’s Medicaid program to include telehealth services. The legislation clarifies that the New Mexico Telehealth Act does not alter provider scope of practice or permit care delivery methods that are otherwise unauthorized by law. The definition of “health care provider” under the Act was also expanded to include certified peer support workers and any other provider with a Medicaid identification number issued by the state’s health care authority.
- NORTH DAKOTA: North Dakota updated its Telehealth Policies Document which now makes reference to the state’s redesigned procedure code lookup tool. The tool now clearly indicates which codes are allowable for telehealth and audio-only delivery, replacing the state’s previously maintained list of approved telehealth services, which has since been retired. Additionally, the state enacted updates to its veterinary and optometry practice laws, introducing new provisions governing the use of telehealth within each profession.
- OHIO: The Ohio Department of Medicaid (ODM) has released an updated version of the Managed Care Entities (MCE) Telehealth Manual, introducing several clarifications and additions relevant to telehealth billing and delivery. The updated manual now includes a revised telehealth code list and permits audio-only interactions when such services are allowable under Medicare guidelines. It also clarifies billing responsibilities for practitioners operating under contractual arrangements explaining that if the practitioner site does not bill directly, the patient site or contracting practice may instead submit the claim for services delivered via telehealth. In addition, the manual emphasizes that the Place of Service (POS) code on professional claims must reflect the physical location of the practitioner.
- OKLAHOMA: Oklahoma joined the Dietitians Compact and the Social Work Licensure Compact.
Given the nuanced and varied approaches states are taking with their telehealth policies, please reference CCHP’s telehealth Policy Finder to link to additional details and access each states’ policies in their entirety. |
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