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  • Sep 10, 2025

    💫 IMLCC Licensure Trends, Broadband Dead Zones, and MDPP & FEHP Reimbursement Updates - The September Newsletter is Here!

    CCHP

    In June the Interstate Medical Licensure Compact Commission (IMLCC) released its annual review and report of completed physician applications as part of its ongoing 8-Year Data Study, first launched in 2019. The latest review covers applications completed between April 1, 2024, and March 31, 2025.  Findings from the report emphasize the Compact’s impact on workforce mobility. On average, participating physicians applied for more than four licenses, and the Compact has been found to be twice as effective in addressing physician shortages as any other legislative approach (such as licensure exceptions or state-by-state telemedicine registrations). Member states have seen a 10% average increase in license applications, with the greatest impact reported in Wyoming, North Dakota, and Vermont.  By contrast, Missouri, Pennsylvania, and Michigan saw the lowest new licenses issued through the Compact. 
    These findings build on the broader impact the Compact has had since its launch, reflecting steady growth in physician participation and license issuance across member states.  According to IMLCC’s informational factsheet, since the IMLCC’s launch in 2017, the Compact has facilitated participation by more than 42,000 physicians, resulting in over 95,000 completed applications and 150,000 licenses issued across 41 member states, the District of Columbia, and Guam. The factsheet also includes a chart comparing the data from its study (such as licensure application numbers) from 2019 to April 2025.  To qualify for the expedited process, physicians must meet nine eligibility requirements (such as having graduated from an accredited medical school, no criminal history and fingerprints on record) and hold an active, unrestricted license in a member state where they live, practice, or are employed.

    The IMLCC website also notes recent membership changes and updates in 2025. Pennsylvania joined effective July 7, while North Carolina became the 44th member of the Compact. Michigan, though currently an active Compact member, included statutory language repealing its participation effective March 29, 2025. As a result, the state has initiated the formal withdrawal process, which will take effect on March 28, 2026. Until that date, Michigan will continue to fully participate in the
    Compact, including issuing licenses and serving as a State of Principal License (SPL). In addition, the Commission has transitioned its website from imlcc.org to imlcc.com, where updated reports and information releases are now available.  To review the IMLCC’s latest data, see the full annual data report.

    When Health Care Shortages and Broadband Deserts Collide
    A new webpage hosted by KFF Health News highlights broadband “dead zones” across the United States—counties where inadequate high-speed internet overlaps with severe shortages of primary care providers and behavioral health specialists. Nearly 3 million rural Americans live in more than 200 of these counties, and the health toll is striking: residents in these areas live sicker and die younger on average compared to peers in better-connected regions. While telehealth has the potential to bridge gaps in access—enabling video visits with distant specialists, remote monitoring for chronic conditions, and timely behavioral health care—these services typically require broadband speeds of at least 25 Mbps download and 3 Mbps upload, with higher speeds needed for smooth, uninterrupted video connections. Without reliable access to these minimum standards, many rural patients are left behind, especially those in states with policies excluding audio-only coverage.

    Through powerful multimedia reporting in partnership with InvestigateTV, KFF Health News documents how this disconnect plays out in real lives. One of these articles highlights Greene County, Alabama where decades of underinvestment have left local hospital facilities outdated and internet speeds too slow to support even basic telehealth functions. Patients like Barbara Williams, a diabetic resident, illustrate the consequences: her blood glucose monitor sits unused because weak internet signals prevent her from transmitting data or accessing telehealth portals. Similarly, in rural West Virginia, another article features how their flawed broadband attempts—plagued by inaccurate mapping, weak standards, and poor oversight—have left nearly 3 million Americans in telehealth blackouts, unable to access care despite billions in federal dollars spent.  These stories underscore the urgent need to address both broadband infrastructure and provider shortages together, if telehealth is to fulfill its promise of closing rural health care gaps.  For more stories on the country’s broadband dead zones and its impact on healthcare, see the KFF Health News Dead Zone webpage.

    CMS Proposes Virtual Flexibilities for the Medicare Diabetes Prevention Program
    The Centers for Medicare & Medicaid Services (CMS) recently outlined proposed updates to the Medicare Diabetes Prevention Program (MDPP) in the proposed CY 2026 Physician Fee Schedule, with a focus on expanding virtual participation.  CMS is proposing to extend through December 31, 2029 the flexibilities originally granted during the COVID-19 Public Health Emergency, allowing MDPP suppliers to deliver sessions via distance learning sessions. In addition, CMS proposes to broaden these flexibilities by permitting beneficiaries to self-report weight from home or other reasonable locations, such as fitness centers, medical offices, or temporary residences, with the goal of reducing barriers to participation and increasing access.

    For the first time, CMS is also proposing to test an asynchronous, online delivery option for MDPP, available through 2029. Under this model, participants could complete program sessions virtually on their own schedule, without the need for real-time group meetings. A new HCPCS G-code ($18) would reimburse online delivery, while performance-based payments for achieving 5% and 9% weight loss would remain the same across in-person, distance learning, or online modalities. Notably, CMS clarified that MDPP suppliers will not be required to maintain in-person delivery capability during this period, opening the door for virtual-only organizations to enroll as MDPP suppliers. These proposals are designed to increase uptake, modernize program delivery, and align MDPP with CDC Diabetes Prevention Recognition Program standards while continuing to test the effectiveness of online models in achieving meaningful health outcomes.  CCHP previously highlighted the value of these flexibilities in our earlier MDPP write-up and also referenced these changes in our PFS write-up and fact sheet.  For more details, see the full MDPP proposed rule summary and the proposed CY 2026 Physician Fee Schedule. CMS will review public comments (due September 12) and is expected to issue the final rule in November.  Comments can be submitted via the federal register.

    Anthem to End Telehealth Coverage for 173 Services Under Federal Employee Plans
    Anthem Blue Cross Blue Shield recently announced that it has eliminated coverage for many telehealth services under its Federal Employee Health Benefits (FEHB) Program and Postal Service Health Benefits (PSHB) plans. This change took effect April 5, 2025 and applies to members enrolled in the Standard Option, Basic Option, and FEP Blue Focus plans.

    According to Anthem’s notice, telemedicine claims will be considered non-covered for inpatient and outpatient professional services if the CMS-1500 form contains specific codes and telehealth indicators in the place of service/modifier fields.  The notice applies to all diagnosis codes.  The policy affects 173 procedure codes, including ESRD (end stage renal disease) services, psychotherapy services, and telehealth consultations for inpatient or emergency department settings—services that are otherwise covered under Medicare Part B’s Physician Fee Schedule list. Anthem is also ending coverage for codes not included on CMS’s list, such as the AMA’s telemedicine-specific codes (98000–98014). As part of the change, Anthem will no longer accept telehealth-specific place of service codes (02 and 10) or modifiers (93, 95, GT, G0) for the 173 procedure codes it identified.

    While most states have telehealth parity laws requiring private health plans to cover telehealth on the same basis as in-person care, these state requirements do not apply to federal programs like FEHB. Similarly, the requirement that Medicare Advantage plans cover the same telehealth services as Medicare Part B does not extend to FEHB, as it is a separate program. Instead, the FEHB program is regulated under federal rules which do not explicitly mention requirements around telehealth coverage.  Notices of these telehealth benefit eliminations have been published across multiple states, including Colorado, Connecticut, Georgia, Indiana, Kentucky, Maine, Missouri, Nevada, New Hampshire, New York, Ohio, Virginia, and Wisconsin.

    It is important to note that Anthem is not the only plan available through FEHB. Other insurers—such as Compass Rose Health Plan, APWU Health Plan, and Government Employees Health Association (GEHA)—also offer coverage under the FEHB program. At this time, no similar telehealth benefit changes have been reported for those plans, although it is unclear what their telehealth coverage policies are. Federal employees can review and compare their available plan options through OPM’s FEHB plan comparison tool though telehealth isn’t included as part of the comparison information.  Providers may need to reach out to the plans directly for information about telehealth.  For more information, including the full list of 173 procedure codes no longer covered for telehealth, see Anthem’s notice.
    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 California, District of Columbia, Iowa, Massachusetts, Mississippi, Missouri, Nebraska, New York, Puerto Rico, Texas, Virgin Islands, Virginia, Washington, and Wisconsin.

    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 requirements.  Highlighted changes from this group of states include:
    • CALIFORNIA: Medicaid (Medi-Cal) added CPT code 98016 in recent coding updates included in its Telehealth Manual – CPT code 98016: Brief communication technology-based service, for example, virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient. Code 98016 can be billed when the virtual communication is via a telephone call. A Medi-Cal Provider News article noted a new requirement for providers to input information for each of their service locations that are enrolled with Medi-Cal, including whether providers are offering covered services via telehealth.
    • DISTRICT OF COLUMBIA: The Department of Health Care Finance issued an Emergency and Proposed Rulemaking proposing, on both an emergency and permanent basis, programmatic and reimbursement changes to the My Health GPS program, which was established by DHCF as a Health Home program to address the unmet needs of Medicaid beneficiaries with multiple chronic conditions. Amendments include clarifying that the in-person requirement for assessments is limited to only the initial assessment. All subsequent biopsychosocial assessments may be completed in the setting selected by the beneficiary, through in-person, video conference or other electronic modality, or telephone, in accordance with HIPAA. Additionally, B 26-0025 amended the Health Services Planning Program to exempt certain entities from certificate of need requirements related to health facility services and expenditures. The legislation exempts from the definition of health care facility entities including virtual provider networks or virtual telehealth platforms. Additionally, the legislation exempts activities from the certificate of need review, including any proposal by a virtual telehealth platform or virtual provider network to provide access to, offer, or develop health care services exclusively via a virtual telehealth platform to District residents. Lastly, the legislation creates registration processes for certain health care entities, including virtual provider networks or virtual telehealth platforms operating in the district.
    • IOWA: Joined two additional interstate licensure compacts, expanding provider mobility and cross-state practice opportunities. The state is now a member of both the Dietitian Licensure Compact and the Physician Assistant (PA) Licensure Compact, supporting more seamless practice for licensed professionals across participating states.
    • MISSOURI: Enacted Senate Bill 79 which updated the state’s statutory definition of telehealth and telemedicine to explicitly include both audiovisual and audio-only technologies, reinforcing the legitimacy of multiple modalities for delivering care. In addition, Senate Bill 79 also revised Missouri’s Medicaid telehealth statute to protect provider flexibility in platform selection. The updated law states that health care providers shall not be limited in their choice of electronic platforms used to deliver telehealth or telemedicine services under Medicaid.
    • NEW YORK: Medicaid announced an expansion of remote patient monitoring reimbursement in an outpatient setting. Another Medicaid Update mentioned Project TEACH, which is the NY child/adolescent and perinatal psychiatry access program. Project TEACH provides referral support and telephone consultations with a child/adolescent or perinatal psychiatrist are also offered to primary care, ob/gyn, pediatric and psychiatric clinicians. Consultations are billable using Current Procedural Terminology code "99452". Additionally, a Department of Health final rule was issued impacting the use of telehealth to prescribe controlled substances.
    • TEXAS: Enacted several significant telehealth-related laws during the 2025 legislative session. House Bill 1620 updates Medicaid policy on remote patient monitoring (RPM) by directing the Health and Human Services Commission (HHSC) to evaluate the cost-effectiveness and clinical effectiveness of home telemonitoring before establishing reimbursement provisions. The bill outlines specific diagnoses for HHSC to consider for coverage, including end-stage renal disease and conditions requiring renal dialysis, which were added to the existing list. It also requires the agency to assess whether high-risk pregnancy should qualify for RPM reimbursement. The law applies to providers such as home and community support services agencies, federally qualified health centers (FQHCs), rural health clinics (RHCs), and hospitals, and mandates that any clinical data collected via telemonitoring be shared with the patient’s physician to ensure continuity of care. Texas also passed House Bill 1052 requiring that beginning January 1, 2026, health benefit plans cover telemedicine, teledentistry, and telehealth services delivered from or to out-of-state sites on the same basis as in-state services, provided the patient primarily resides in Texas and the provider is licensed and maintains a physical office in Texas. In addition, House Bill 1700 requires all health professional licensing agencies to adopt standardized consent documentation rules for telehealth, including requirements for treatment, data collection, and sharing, and allowing audio-only consent where clinically appropriate.
    • WASHINGTON: Medicaid (Apple Health) Alerts from May and June announced the addition of new audio-only codes billable for certain services and providers. A Provider Bulletin also announced updates to the community health worker billing guide for dates of service on and after July 1, 2025, removing the requirement for the first visit of the month to be in-person. The first service each month may now be delivered in-person or via telemedicine. An emergency rule implemented reimbursement for birth doula services, effective January 1, 2025, while the permanent rule-making process is completed. Telehealth services are covered in certain situations. SB 5167 passed and provides funding for a variety of telehealth-related activities. SB 5814 updates the state’s tax code, including current tax exemptions addressing digital automated services. Examining Board of Psychology final rules added telehealth definitions and practice requirements, and Veterinary Board of Governors final rules added telehealth definitions and practice requirements related to establishing a Veterinary-client-patient relationship.
    • WISCONSIN: Adopted new optometry regulations clarifying that the same standards of practice and professional conduct apply to optometrists regardless of whether care is delivered in person or via telehealth. Under the new rules, optometrists providing telehealth services to patients located in Wisconsin must either hold a Wisconsin license, apply for a temporary credential under state statute, or be licensed with endorsement through the appropriate board pathways.  The Wisconsin Marriage and Family Therapy, Counseling, and Social Worker Examining Board also issued a new rule for telehealth practice. Practitioners must be licensed in Wisconsin to treat patients located in the state via telehealth and must comply with out-of-state regulations when treating clients physically located elsewhere. The rule requires licensees to meet the same standards for confidentiality, recordkeeping, and quality of care as for in-person services. Nonresident providers may treat nonresident clients in Wisconsin via telehealth for up to 5 days per month, not to exceed 15 days total, if a prior therapeutic relationship exists. Providers are also responsible for ensuring that telehealth technology supports safe and competent care delivery.
    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.

    Remote CBT Programs Show Benefits for Chronic Pain Management
    A new randomized clinical trial published in JAMA evaluated the effectiveness of remote cognitive behavioral therapy (CBT)–based treatments for individuals with high-impact chronic musculoskeletal pain. The study included more than 2,300 participants from four diverse health systems who were assigned to either a coach-led telehealth program, a self-guided online program (painTRAINER), or usual care with a resource guide. At three months, 32% of participants in the health coach group and 27% in the online program achieved at least a 30% reduction in pain severity, compared to 21% in the usual care group. The coach-led intervention outperformed the online program, and both interventions showed statistically significant benefits over usual care for pain and functioning outcomes at six and twelve months.

    These findings highlight that remote, scalable CBT-based approaches can provide modest but meaningful improvements in pain and quality of life for patients with chronic pain. Importantly, both telehealth and online options offer lower-resource, evidence-based alternatives to expand access to nonpharmacologic pain management, particularly in underserved or rural areas where specialized care may be limited. For more details on the study, read the full JAMA article.
     

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