While much of our recent newsletter coverage has centered on federal telehealth developments, there continues to be substantial activity at the state level shaping how telehealth services are delivered and reimbursed. The Center for Connected Health Policy (CCHP) closely monitors these changes through our Telehealth Policy Finder, which is updated year-round, as CCHP ensures that each state undergoes three rounds of comprehensive policy review annually.
Each fall, CCHP compiles a full snapshot of the telehealth policy landscape in our 50-State Summary Report, covering all 50 states, Washington, DC, Puerto Rico, and the U.S. Virgin Islands. This report includes Medicaid reimbursement status for live video, store-and-forward, RPM, and audio-only services, as well as state-level requirements related to patient consent, cross-state licensing, and private payer laws. To view the most recent version, visit: Fall 2024 State Telehealth Laws and Reimbursement Policies Report.
While the 50-State Report offers a comprehensive annual snapshot, CCHP also provides more frequent updates through our online tools to reflect the latest policy shifts as close to real time as possible. 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 District of Columbia, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Massachusetts, Michigan, Mississippi, Missouri, Nebraska, New York, Pennsylvania, South Dakota, Tennessee, Texas, Virginia, Washington and Wisconsin.
This month, we are highlighting several key trends emerging from our most recent state updates—reflecting how legislatures, Medicaid programs, and regulatory boards are actively shaping telehealth policy in 2025. 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.
Recent state-level policy activity reflects a continued effort to expand and refine telehealth, including remote patient monitoring (RPM) and electronic consultations (e-consults), particularly with a focus on permanency, clinical specificity, and patient-centered care. Several states, including Mississippi and Massachusetts, took steps to solidify or expand telehealth coverage, with Mississippi removing the sunset clause on its private payer mandate and Massachusetts affirming coverage of doula services via telehealth in Medicaid. States including District of Columbia, New York, and Washington also implemented policies to expand Medicaid coverage of various community-based services that may delivered through telehealth. New York, Nebraska, South Dakota, and Texas updated their Medicaid manuals or administrative codes to include more detailed telehealth reimbursement requirements—especially regarding audio-only, RPM, behavioral health, teledentistry, and provider-patient communication preferences. In particular, Texas introduced strict prescribing protocols for chronic pain management via telemedicine, underscoring the balance states are trying to strike between flexibility and patient safety. States are also looking to strike a balance around how telehealth is used to meet network adequacy requirements, such as New York, to ensure that patients remain able to receive timely access to all necessary care.
Meanwhile, states such as Virginia are using legislation to direct Medicaid agencies to not only expand RPM access—specifically for high-risk maternal health—but also to develop cost analyses and implementation plans for broader chronic care applications. The inclusion of maternal health (such as in Virginia), substance use disorder services (such as in South Dakota), and detailed audiovisual requirements (such as in Texas) suggests that states are prioritizing targeted populations and service types where telehealth can fill gaps in access. A notable trend is the increased specification of modality-based requirements (e.g., when audio-only is permitted, such as in Nebraska and Washington) as well as expanding coverage specific to certain modalities, including e-consults. New York issued Medicaid updates to both expand e-consult coverage in outpatient settings and enhance reimbursement rates for a period of five years for e-consults between eligible physical health and behavioral health practitioners. Washington also issued an alert regarding availability of a Perinatal Psychiatry Consultation Line that offers free provider-to-provider consultations to health care providers in Washington State. There is also growing alignment with national coding policies (for example, Michigan deleting audio-only codes 99441-99443, just as Medicare has recently done). Nevertheless, while the District of Columbia noted coding updates related to the new AMA telemedicine codes for 2025, DC Medicaid decided not to cover these codes, affirming that previously issued guidance will remain in effect for telemedicine services. Going forward, stakeholders should watch if and how additional states operationalize these changes, particularly in their provider manuals and fee schedules.
For those focused on federally qualified health centers (FQHCs), CCHP is pleased to announce that we will soon be reviving the dedicated section of our Policy Finder focused on telehealth in Medicaid as used by FQHCs, with funding support from the National Association of Community Health Centers (NACHC). CCHP previously maintained this section, however due to limited funding was forced to remove it in early 2024. Now with renewed resources, we are updating this valuable section, which will be relaunched later this summer—stay tuned!
As always, 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. Stay tuned to CCHP’s Fall 50 State Telehealth Polices Report for an analysis of trends for all 50 states, DC, Puerto Rico and Virgin Islands. |
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