Pennsylvania

At A Glance

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MEDICAID REIMBURSEMENT

Live Video: Yes
Store-and-Forward: Yes* (interprofessional consultation codes)
Remote Patient Monitoring: Yes
Audio Only: Yes

PRIVATE PAYER LAW

Law Exists: Yes
Payment Parity: No

PROFESSIONAL REQUIREMENTS

Licensure Compacts: EMS, IMLC, NLC, PSY, PTC
Consent Requirements: Yes (Medicaid)

STATE RESOURCES

Medicaid Program: Pennsylvania Medical Assistance Program (MA)
Administrator: Pennsylvania Department of Public Welfare
Regional Telehealth Resource Center: Mid-Atlantic Telehealth Resource Center

Private Payer

Last updated 04/27/2025

Definitions

“Telemedicine.” The delivery of health care services to a patient by a health care provider who is at a different location, through synchronous interactions, asynchronous interactions or remote patient monitoring that meets the requirements of the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act or other applicable Federal law or law of this Commonwealth regarding the privacy and security of electronic transmission of health information.

SOURCE: PA Consolidated Statutes, Title 40, Chapter 48, Section 4802, (Accessed Apr. 2025).

Last updated 04/27/2025

Parity

SERVICE PARITY

A health insurance policy offered, issued or renewed in this Commonwealth shall provide coverage for medically necessary health care services provided through telemedicine and delivered by a participating network provider who provides a covered health care service through telemedicine consistent with the insurer’s medical policies. A health insurance policy may not exclude a health care service from coverage solely because the health care service is provided through telemedicine.

SOURCE: PA Consolidated Statutes Title 40, Chapter 48, Section 4803(a)(1), (Accessed Apr. 2025).

PAYMENT PARITY

Subject to paragraph (1), an insurer shall pay or reimburse a participating network provider for covered health care services delivered through telemedicine and pursuant to a health insurance policy in accordance with the terms and conditions of the contract as negotiated between the insurer and the participating network provider. A contract that includes payment or reimbursement for covered health care services delivered through telemedicine may not prohibit payment or reimbursement solely because a health care service is provided by telemedicine. Payment or reimbursement may not be conditioned upon the use of an exclusive or proprietary telemedicine technology or vendor.

SOURCE: PA Consolidated Statutes Title 40, Chapter 48, Section 4803(a)(2), (Accessed Apr. 2025).

Last updated 04/27/2025

Requirements

Subsection (a) does not apply if the telemedicine-enabling device, technology or service fails to comply with the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act or other applicable statute, regulation or guidance.

For a health insurance policy for which either rates or forms are required to be filed with the Federal Government or the department, this section shall apply to a policy for which a form or rate is first filed on or after 180 days after the effective date of this paragraph.

For a health insurance policy for which neither rates nor forms are required to be filed with the Federal Government or the department, this section shall apply to a policy issued or renewed on or after 180 days after the effective date of this paragraph.

This section may not be construed to:

Prohibit an insurer from paying or reimbursing other health care providers for covered health care services provided through telemedicine.
Require an insurer to pay or reimburse an out-of-network health care provider for health care services provided through telemedicine.
Require an insurer to pay or reimburse a participating network provider if the provision of the health care service through telemedicine would be inconsistent with the standard of care.

SOURCE: PA Consolidated Statutes, Title 40, Chapter 48, Section 4803, (Accessed Apr. 2025).

Will commercial health insurers be required to reimburse for telemedicine services and to reimburse at the same rate as in-person services after October 1, 2024?

Under Act 42 of 2024, health insurance policies for which forms or rates are filed on or after March 31, 2025, must provide coverage for certain health care services rendered through telemedicine. This means that it will apply to some group plans that are issued or renewed in late 2025, and to other group plans, and all individual policies, beginning in January 2026.

The services provided through telemedicine will be required to be covered if they are rendered by an in-network provider. (A health insurer may also provide coverage for services rendered by an out-of-network provider at the insurer’s option, as reflected in the member’s plan.) In addition, the service must be: (a) medically necessary; (b) consistent with the health insurer’s medical policies and the applicable standard of care; and (c) provided through HIPAA-compliant technology.

Reimbursement for services provided through telemedicine may vary dependent upon the provider’s contract and the member’s plan. However, reimbursement may not be denied solely because a service was provided through telemedicine, nor may it be conditioned on the use of exclusive or proprietary technology.

I provide school-based physical health and behavioral health services and continue to provide care via telemedicine. Will I be allowed to continue to provide services using telemedicine after October 1, 2024?

Coverage for services delivered via telemedicine must be covered by commercial insurance when completed by an in-network provider. Reimbursement of services is also required, but commercial insurer’s reimbursement rates may vary dependent upon applicable provider contracts. Insurers may have policy limitations that prohibit coverage for school-based services. However, state law currently requires all fully insured health plans to cover certain autism services regardless of whether they are provided in a school setting.

In addition, DHS issued a September 2022 Update of the School Based ACCESS Program (SBAP) Handbook allows telehealth for most school-based services. More information on the ACCESS Program can be found here.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Jan. 2025).

Medicaid

Last updated 04/27/2025

Consent Requirements

Providers are to obtain consent prior to rendering a service via telehealth from the beneficiary receiving services or their legal guardian. Providers must also allow beneficiaries to elect to return to in-person services at any time. Services rendered via telehealth may not be recorded without the beneficiary’s consent. Beneficiaries may elect not to receive services via telehealth at any time. Providers cannot use a beneficiary’s refusal to receive services via telehealth as a basis to limit the beneficiary’s access to services.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, 99-23-08 (Aug. 2, 2023), p. 3. (Accessed Apr. 2025).

As OMHSAS works on a bulletin for updated telehealth guidelines, providers will be able to document consent heard by one employee of the service provider. While a previous Frequently Asked Question memo issued on August 16, 2022, required two-person verification of consent, OMHSAS will permit providers to document consent heard by one employee of the service provider.

OMHSAS has stressed the importance of developing appropriate systems to capture electronic signatures since February 2021. Given the options available to providers, OMHSAS expects providers to meet federal and state guidance. OMHSAS understands the challenges providers are experiencing and therefore, it will extend the suspension of bulletins identified in the February 18, 2021 OMHSAS memo to December 31, 2023. The suspension is specific only to consent to treatment, service verifications, and treatment plans that are scheduled to end on March 31, 2023. Effective on January 1, 2024, providers are expected to capture consent to treatment, service verifications, and approval of treatment plans in a manner that creates an auditable file and is in accordance with the timelines expected within regulation.

SOURCE: Mental Health and Substance Abuse Services, Interim Telehealth Guidance, March 30, 2023, (Accessed Apr. 2025).

Services delivered through telehealth may also be provided outside of a clinic, residential treatment setting or facility setting. With the consent of the individual served and when clinically appropriate, licensed practitioners and provider agencies may deliver services through telehealth to individuals in community settings, such as to an individual located in their home. The licensed practitioner or provider agency must have policies in place to address emergency situations, such as a risk of harm to self or others.

Licensed practitioners and provider agencies must obtain consent from the individual receiving services or their legal guardian, as applicable, prior to rendering a service via telehealth. Licensed practitioners and provider agencies must also allow individuals to elect to return to in- person service delivery at any time. Individuals may refuse to receive services through telehealth.

As with services delivered in-person, licensed practitioners and provider agencies must obtain consent from the individual served or their legal guardian, as applicable, to make any recordings of the provision of services through telehealth appointments. Licensed practitioners and provider agencies are not permitted to mandate the use of recording for telehealth service delivery and must still provide the service if an individual or legal guardian, as applicable, does not consent to a recording.

The medical record for the individual must indicate each time services are provided through telehealth in addition to the standard documentation requirements. Consent for services and service modality, such as in-person or telehealth, should be obtained and documented prior to rendering services. Additionally, if the individual served or their legal guardian, as applicable, consents to the recording of a telehealth service, documentation of consent must be included in the medical record.

Signatures for consent to treatment, service verification, and acknowledgement of receipt of treatment or service plan(s) may include hand-written or electronic signatures. Consistent with Act 69 of 1999 Electronic Transactions Act, an electronic signature is an electronic sound, symbol or process attached to or logically associated with a record and executed or adopted by a person with the intent to sign the record.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 4, 6, July 1, 2022, (Accessed Apr. 2025).

Providers are to obtain consent from the beneficiary or the beneficiary’s legal guardian prior to rendering interprofessional consultation services on behalf of the beneficiary receiving services.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

Last updated 04/27/2025

Definitions

SOURCE: PA Consolidated Statutes Title 40, Chapter 48, Sec. 4802, (Accessed Apr. 2025).

Historically, “telemedicine” for purposes of Medicaid payment was the use of two-way, real time interactive telecommunication equipment that included, at a minimum, audio and video equipment, as a mode of delivering healthcare services. However, the term “telehealth” has emerged as the umbrella term that encompasses the full range of services furnished remotely. In response to this shift, the Department will now refer to the remote delivery of services as telehealth.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2. Aug. 2, 2023. (Accessed Apr. 2025).

FQHC/RHC Manual

Telemedicine: An encounter between a practitioner and a beneficiary in which physical health services are provided through the use of approved electronic communication and information technologies to provide medical services at a distance.

Telehealth: An encounter between a licensed practitioner or provider agency and a beneficiary, in which behavioral health services are provided through the use of approved electronic communication and information technologies to provide behavioral health care at a distance.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Updates to The PROMISe™ Provider Handbook 837 Professional/CMS-1500 Claim Form, Appendix E – FQHC/RHC Handbook, Nov. 1, 2024, Number 08-24-16, (Accessed Apr. 2025).

Teledentistry is two-way, real time interactive communication between the patient and dentist. Teledentistry may be provided by any means that allows for two-way, real time interactive audio-video communication, such as through conferencing hosted by a secure mobile application. Audio only technology may be utilized for two procedure codes as described below.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Apr. 2025).

Last updated 04/27/2025

Email, Phone & Fax

The Department will continue to allow providers to utilize audio-only telecommunication when the beneficiary does not have access to video capability or for an urgent medical situation. The use of audio-only telecommunication technology is to be consistent with state and federal requirements, including guidance by CMS with respect to Medicaid payment and to compliance with Health Insurance Portability and Accountability Act (HIPAA).

Services rendered via telehealth, including those delivered using audio-only telecommunication technology, must use technology that is two-way, real-time, and interactive between beneficiary and provider.

If the service was rendered using audio-only technology, providers are to document that the services were rendered using audio-only technology and the reason audio/video technology could not be used.

Audio-only telecommunications technology may be used when the beneficiary does not have video capability or for an urgent medical situation, if consistent with state and federal law.

Providers are to indicate in the beneficiary’s medical record when telehealth services are rendered via audio-only.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 2-4. (Accessed Apr. 2025).

OMHSAS shall issue a bulletin providing additional detail about the use of audio-only services. Audio-only services can only be provided when clinically appropriate and the individual served does not have access to video capability or for an urgent medical situation. The use of audio-only service delivery must be consistent with Pennsylvania regulations and federal requirements

SOURCE: Mental Health and Substance Abuse Services, Interim Telehealth Guidance, March 30, 2023, (Accessed Apr. 2025).

The Department is opening the PT/Spec/POS combination 31/339 (Psychiatry)/02 to the following procedure codes and modifier combination, as the Department determined it is appropriate for this provider to perform these services. These procedure codes include the modifier FQ (audio only).

Certain services can be performed via audio-only (FQ modifier) and POS 10.

SOURCE: PA Department of Human Services, 2023 Evaluation and Management Fee Adjustments and Code Updates , Medical Assistance Bulletin 99-23-06, June 1, 2023 (Accessed Apr. 2025).

Audio-only refers to the delivery of behavioral health services at a distance using real-time, two-way interactive audio only transmission. Audio-only does not include text messaging, electronic mail messaging or facsimile (fax) transmissions. Providers may utilize audio-only when the individual served does not have access to video capability or for an urgent medical situation, provided that the use of audio-only is consistent with Pennsylvania regulations and federal requirements, including guidance by the Centers for Medicare & Medicaid Services with respect to Medicaid payment and the US Department of Health and Human Services Office of Civil Rights enforcement of HIPAA compliance.

Audio-only and text messages may also continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Dept. of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 7, July 1, 2022. (Accessed Apr. 2025).

In response to CMS’s change in policy, the Department is providing coverage and payment for interprofessional consultation services in the MA Program. Allowing direct payments for interprofessional consultations between providers enrolled in the MA Program improves access to specialty care, supports patient-centered care, and maximizes the capacity of the existing workforce by supporting the focus of medical practice towards managing a beneficiary’s chronic conditions. Services must be directly relevant to the beneficiary’s diagnosis and treatment, and the consulting practitioner must have specialized expertise in the particular health concerns of the beneficiary. Interprofessional consultation services are intended to expand access to specialty care and foster interdisciplinary input on beneficiary care. They are not intended to be a replacement for direct specialty care when such care is clinically indicated.

Technology used for interprofessional consultation services must be real-time interactive telecommunication technology. Asynchronous communication and applications, such as store and forward, may be utilized as a part of the synchronous interprofessional consultation, but by themselves do not meet the requirements for interprofessional consultations. Providers must remain informed on federal and state statutes, regulations, and guidance regarding use of technology to render services.

The MA Program will pay for interprofessional consultation services provided on behalf of a beneficiary between licensed and enrolled MA providers when clinically appropriate. Interprofessional consultations occur between an initiating treating provider and a consulting provider to benefit the treatment of the beneficiary but without the beneficiary present. See bulletins for codes eligible for interprofessional consultation services.

The treating provider enrolled in the MA Program who participates in an interprofessional consultation performed at the same time as an office visit is to bill using office visit procedure codes. The treating provider is to bill using procedure code 99452 when participating in a medical consultative discussion outside of an evaluation and management service, which can only be billed once every 14 days.

Consulting providers enrolled in the MA Program are to bill using procedure codes 99446, 99447, 99448, 99449, and 99451 when participating in a medical consultative discussion as the consulting provider. Consulting providers are not to bill for interprofessional consultation services if they have seen the beneficiary in the previous 14 days or if they plan to see the beneficiary in the next 14 days.

Providers who participate in an interprofessional consultation should bill with the POS codes identified in the attachment. Providers should not bill with POS 02 (telehealth provided other than in patient’s home) or POS 10 (telehealth provided in patient’s home) because these POS codes can only be utilized when the MA beneficiary is present.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

See list of eligible interprofessional telephone/electronic consultation codes in the fee schedule.

SOURCE: PA Department of Human Services, Medical Assistance Program Fee Schedule Revisions, issued Apr. 16, 2025, Effective May 1, 2025, (Accessed Apr. 2025).

Outpatient Drug and Alcohol Clinic Services

Payment will not be made for the following types of services regardless of where or to whom they are provided:

Clinic visits, psychotherapy, diagnostic psychological evaluations, psychiatric evaluations and comprehensive medical evaluations conducted over the telephone, that is, any clinic service conducted over the telephone.

SOURCE: PA 55 Code 1223.14 (Accessed Apr. 2025).

Payment will not be made for the following types of services regardless of where or to whom they are provided:

A covered psychiatric outpatient clinic, MMHT or partial hospitalization outpatient service conducted over the telephone.

SOURCE: PA 55 Code 1153.14. (Accessed Apr. 2025).

School-Based ACCESS Program Provider Handbook Mid-Year Update

The provider services log must indicate whether the service type is Direct: Telehealth (indicating also whether the student was at home or somewhere other than home) or Direct: In Person when documenting the service and how it was provided. The “Description of Service” section of the provider service paper log should be used to record details about the service which was provided, including whether any service disruptions or connectivity issues occurred during the service delivery and whether the service was delivered using telephone-only.

SOURCE: PA Department of Human Services, School-Based ACCESS Program Provider Handbook, 35-24-01, Sept. 16, 2024, (Accessed Apr. 2025).

Last updated 04/27/2025

Live Video

POLICY

MA or CHIP managed care plan payments shall be made on behalf of enrollees for medically necessary health care services provided through telemedicine, if all of the following apply:

The health care service would be covered through an in-person encounter.
The provision of the health care service through telemedicine is consistent with Federal law and regulations, the laws of this Commonwealth, applicable regulations and guidance.
Federal approval, if necessary for the provision of the health care service through telemedicine, has been received by the Department of Human Services.

The MA or CHIP managed care plan shall pay a participating network provider for covered health care services delivered through telemedicine in accordance with the terms and conditions of both:

the contract negotiated between the MA or CHIP managed care plan and the participating network provider; and
the agreement with the Department of Human Services.

This section shall apply to MA and CHIP managed care plans beginning on or after January 1, 2026.

This section may not be construed to:

Prohibit a MA or CHIP managed care plan from making payments on behalf of enrollees to other health care providers for covered health care services provided through telemedicine.
Require a MA or CHIP managed care plan to pay for a health care service if the delivery of the health care service through telemedicine would be inconsistent with the standard of care.

SOURCE: PA Statute Sec. 4804-4805, (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3. (Accessed Apr. 2025).

Behavioral Health

Services delivered in the MA FFS delivery system through telehealth will be paid the same rate as if the services were delivered in-person.

MA providers in the MA FFS delivery system that provide services via telehealth should bill for services with a Place of Service (POS) 02 for telehealth provided in a location other than the home of the individual being served and (POS) 10 for telehealth provided in the home of the individual being served, unless instructed otherwise for specific services. Please consult the MA Fee Schedule for procedure codes that have the POS 02 or 10. For services delivered through audio-only, informational modifier code FQ should be used. Providers in the MA HC program must follow the billing instructions of the BH-MCO.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 8, July 1, 2022, (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

ELIGIBLE SERVICES/SPECIALTIES

MA services in the FFS delivery system rendered via telehealth will be paid the same rate as if the services were rendered in person. MA managed care organizations (MCO) may, but are not required to, allow for the use of telehealth. MA MCOs may negotiate payment for services rendered via telehealth. The MA Program will continue to pay for MA covered services rendered to beneficiaries via telehealth when clinically appropriate. Services rendered via telehealth must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3. (Accessed Apr. 2025).

See list of eligible interprofessional telephone/electronic consultation codes in the fee schedule.

SOURCE: PA Department of Human Services, Medical Assistance Program Fee Schedule Revisions, issued Apr. 16, 2025, Effective May 1, 2025, (Accessed Apr. 2025).

The Department is adding POS 10 (Telehealth Provided in a Patient’s Home) for the following procedure codes and procedure code and modifier combinations for all PT/Spec combinations as the Department determined telehealth is appropriate for the performance of these services. These procedure codes may include modifiers FP, GN (speech pathology), HD (pregnant/parenting women’s program), HQ (group therapy), TC, TJ (Childhood Nutrition Weight Management Services), TM (School-Based ACCESS Program), UA (audiology), UB (pricing), U3 (pricing), U4 (pricing), U5 (pricing), U6 (pricing), U7, U8 (pricing), U9 (pricing), 24 (unrelated E&M service by the same physician or other qualified health care professional during a postoperative period), 25 (significant, separate identifiable E&M service by the same physician or other qualified health care professional on the same day of the procedure or other service), 26, 27(multiple outpatient hospital E&M encounters on the same date), 57 (decision for surgery).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-09, 2023 Healthcare Common Procedure Coding System (HCPCS) Updates, Fee Adjustments, and Other Procedure Code Changes (Aug. 31, 2023), (Accessed Apr. 2025).

The Department added POS 10 (Telehealth Provided in a Patient’s Home) to procedure 96160 with the FP modifier for the following PT/Spec combinations as the Department determined telehealth is appropriate for the performance of these services

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Updates to the Family Planning Services Program Fee Schedule (Sept. 1, 2023), (Accessed Apr. 2025).

The Department added Place of Service (POS) 10 (Telehealth Provided in a Patient’s Home) to the following procedure codes (see bulletin) as the Department determined telehealth was appropriate for the performance of services.

SOURCE: PA Department of Human Services, 2023 Medical Assistance Program Dental Fee Schedule Update and Dental Provider Handbook Update (Sept. 5, 2023), (Accessed Apr. 2025).

Behavioral Health Services: The Department is adding POS 10 (Telehealth Provided in Patient’s Home) with the UB (pricing) modifier and UB, FQ (audio-only communication technology) modifier combination to procedure code 90853 for PT/Spec combination 08/110 (Psychiatric Outpatient) based upon clinical review.

SOURCE: PA Department of Human Services, Medical Assistance Program Fee Schedule Revisions, issued Apr. 16, 2025, Effective May 1, 2025, (Accessed Apr. 2025).

Additionally, the MA Program now utilizes two Place of Service (POS) codes to identify when services are rendered via telehealth – POS 02 (Telehealth Provided Other than in a Patient’s Home) and POS 10 (Telehealth Provided in a Patient’s Home). As a result of revisions announced in the 2023 HCPCS Update bulletin, the Department added POS 10 to all CNWMS-related procedure codes on the MA Program Fee Schedule. In conjunction with these updates, the GT Modifier was removed from procedure code T1015. Therefore, the chart attached to this bulletin has been updated to reflect the POS code changes for CNWMS rendered via telehealth.

SOURCE: PA Department of Human Services, 2023 Updates to Childhood Nutrition and Weight Management Services (Sept. 5, 2023), (Accessed Apr. 2025).

Screening, Diagnostic, and Targeted Case Management Services for Eligible Juveniles Enrolled in Medical Assistance Prior to Release from a Carceral Setting

These procedure codes can be used by the following provider type (PT)/specialty (Spec) combinations with place of service (POS) 02 (Telehealth Provided Other than in a Patient’s Home), 09 (Correctional Facility), 10 (Telehealth Provided in a Patient’s Home), or 11 (Office) as indicated below.

For EPSDT screenings and diagnostic services performed via telemedicine, providers should refer the beneficiary to a provider in the community for laboratory testing, dental services, or any other medically necessary services that must be performed in-person, including “catchup” services as needed, to ensure that the beneficiary receives the required screens and diagnostic services for the applicable periodicity period.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Screening, Diagnostic, and Targeted Case Management Services for Eligible Juveniles Enrolled in Medical Assistance Prior to Release from a Carceral Setting, (Feb. 18, 2025). (Accessed Apr. 2025).

For FQHCs & RHCs

Telemedicine encounters must be provided according to the same standard of care as if delivered in-person. FQHCs/RHCs providing physical health services are to refer to MA Bulletin 99-23-08, titled “Updates to Guidelines for the Delivery of Physical Health Services via Telehealth,” or the current MA Bulletin or Department guidance, for more information. (https://www.dhs.pa.gov/docs/Publications/Documents/FORMS%20AND%20PUBS%20OMAP/MAB2023080201.pdf).

Telehealth encounters must be provided according to the same standard of care as if delivered in-person. FQHCs/RHCs providing behavioral health services licensed by OMHSAS are to refer to OMHSAS Bulletin OMHSAS-22-02, titled “Revised Guidelines for the Delivery of Behavioral Health Services Through Telehealth,” or the current OMHSAS Bulletin or Department guidance, for more information (https://www.dhs.pa.gov/docs/Documents/OMHSAS/Bulletin%20OMHSAS-22-02%20%20Revised%20Guidelines%20for%20Delivery%20of%20BH%20Services%20Through%20Telehealth%207.1.22.pdf)

Some dental services can be provided using teledentistry. FQHCs/RHCs are to refer to MA Bulletin 08-22-13, titled “Teledentistry Guidelines and Dental Fee Schedule Updates,” or the current MA Bulletin, for more information (https://www.dhs.pa.gov/docs/Publications/Documents/FORMS%20AND%20PUBS%20OMAP/MAB2022061301.pdf).

Limited English Proficiency

All recipients of federal funding, including the MA Program, must offer and make available interpretation services to beneficiaries with limited English proficiency, visual limitations, and/or auditory limitations. Providers who elect to render services through telehealth (telemedicine) must have policies in place to make language assistance services, such as oral interpretation, including sign language interpretation, and written translation, available to beneficiaries being served via telemedicine.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 3-4 & [slight variation] PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 6, July 1, 2022, (Accessed Apr. 2025).

Some behavioral health services may be appropriate to be provided primarily through telehealth, while other services will require ongoing in-person delivery for a significant portion of or all of the services. Providers and practitioners should carefully consider the clinical appropriateness of telehealth delivery for such services, including, but not limited to: Partial Hospitalization, Intensive Behavioral Health Services (IBHS), Family Based Mental Health, Assertive Community Treatment (ACT), or for beneficiaries in a residential facility or inpatient setting.

Providers in the MA HC program must follow the billing instructions of the BH-MCO.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 5, & 8, July 1, 2022, (Accessed Apr. 2025).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

FQHCs and RHCs are to continue billing procedure code T1015 with the U9 modifier to indicate dental visits/encounters rendered via teledentistry to patients. FQHCs and RHCs should no longer use the GT modifier, as previously directed in Provider Quick Tip # 237, “Teledentistry Guidelines Related to COVID-19 for Dentists, Federally Qualified Health Centers and Rural Health Clinics” (https://www.dhs.pa.gov/providers/Quick Tips/Documents/PROMISeQuickTip237.pdf), and must begin using POS 02 as of May 2, 2022.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022), p. 2-3. (Accessed Apr. 2025).

Additionally, vaccine counseling only visits may be provided via telemedicine with the use of Place of Service (POS) 02 (Telehealth Provided Other than in Patient’s Home) or POS 10 (Telehealth Provided in Patient’s Home).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Vaccine Counseling Only Visits for Beneficiaries Under 21 (May 30, 2023). (Accessed Apr. 2025).

I am a licensed, Medical Assistance (MA) enrolled provider – will I continue to be reimbursed for physical health and behavioral services delivered via telemedicine after October 31, 2022, when the suspended regulations expire?

The MA program will continue to reimburse both physical health and behavioral services delivered via telemedicine after October 31, 2022

Act 98 of 2022 permanently abrogated the two DHS regulations that prohibited payment specifically for audio-only telehealth service delivery—outpatient psychiatric clinics (which includes Mobile Mental Health Treatment and Partial Hospitalization Outpatient Services) under 55 Pa. Code § 1153.14(1), and Outpatient Drug & Alcohol Clinic Services under 55 Pa. Code § 1223.14(2).

Will there be a change in MA reimbursements for physical health or behavioral health services provided via telemedicine after May 11, 2023, or will I continue to be reimbursed at the same level for services provided regardless of how they are delivered?

DHS will continue to reimburse services delivered via telemedicine at the same rates as in-person delivered services for the MA Fee-for-Service (FFS) Program.

MA MCOs may negotiate payment for services rendered via telemedicine in the MA HealthChoices managed care program. To date, all MCOs are reimbursing for services delivered via telemedicine. DHS cannot require the MCOs to have payment parity for services delivered via telemedicine without a CMS approved directed payment, as MCOs are allowed to negotiate rates.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Apr. 2025).

School-Based ACCESS Program Provider Handbook

Delivery Method: While DHS has historically expressed its intent for MA services to be rendered to MA beneficiaries in person, some services may be delivered using telehealth.

Refer to Medical Assistance Bulletin 99-23-08 titled “Updates to Guidelines for the Delivery of Physical Health Services via Telehealth,” and any subsequent guidance issued by DHS on the use of telehealth. Note that originating site facility fees discussed in Bulletin 99-23-08 are not applicable within SBAP. All providers using telehealth are advised to remain informed on all federal and state statutes, regulations and guidance regarding telehealth.

Telehealth place of service (POS) indications are distinguished by where the student was at the time of service, regardless of where the direct service provider was at the time of service. Whenever a service is delivered via telehealth to a student who is in their own home, POS 10 is to be used. Whenever a service is delivered via telehealth to a student who is somewhere other than their own home, POS 02 is to be used. This may include situations where the student is physically in the school setting and the direct service provider uses telehealth to remotely provide the service.

See manual for list of services that can be delivered via telehealth.

SOURCE: PA Department of Human Services, School-Based ACCESS Program Provider Handbook, 35-24-01, Sept. 16, 2024, (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

Effective for dates of services on or after March 1, 2024, the Department added POS 02 (Telehealth Provided Other than in a Patient’s Home) and POS 10 (Telehealth Provided in a Patient’s Home) for PT/Spec 10 (Mid-Level Practitioner)/247 (Pharmacist) for certain procedure codes based upon clinical review. See fee schedule.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-07 (Sept. 9, 2024), p. 3. (Accessed Apr. 2025).

The Department added procedure code G0136 with the FP (family planning) modifier for the following Provider Type (PT)/Specialty (Spec) combinations, based on clinical review, in Place of Service (POS) 02 (Telehealth Provided Other than in a Patient’s Home), 10 (Telehealth Provided in a Patient’s Home), 11 (Office), 12 (Home), 22 (Outpatient Hospital), 27 (Outreach Site/Street), and/or 49 (Independent Clinic) certain procedure codes based upon clinical review. See fee schedule.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 01-24-06, 08-24-07, 09-24-06, 10-24-06, 24-24-04, 25-24-02, 28-24-01, 31-24-07, 33-24-06 (May 28, 2024), p. 2. (Accessed Apr. 2025).

Certified Nurse Midwife Services: The Department is adding POS 99 (Special Treatment Room) for PT/Spec 33 (Certified Nurse Midwife)/370 (Tobacco Cessation) to procedure code 99407. Additionally, the Department is adding the FP (Family Planning) modifier to procedure code 99407 for PT/Spec combination 33/370 for POS 02 (Telehealth Provided Other than in a Patient’s Home), 10 (Telehealth Provided in a Patient’s Home), 11 (Office), 27 (Outreach Site/Street), and 99.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-02 (April 29, 2024), p. 2. (Accessed Apr. 2025).

ELIGIBLE PROVIDERS

Does the Department of Human Services allow Medical Assistance (MA) enrolled providers to bill for services delivered using telemedicine?

Yes. The Department of Human Services (DHS) has allowed services to be provided via telemedicine since 2007 and has allowed MA-enrolled providers to bill MA for these services. MA-enrolled providers should consult the Office of Medical Assistance Programs (OMAP) and Office of Mental Health and Substance Abuse Services (OMHSAS) telemedicine bulletins for more information on service delivery and billing (see question 7 below). DHS will continue allowing physical health and behavioral health services to be provided via telemedicine delivery and will continue to reimburse at the same rate as services delivered in person in the Fee-for-Service (FFS) delivery system. Managed Care Organizations (MCOs) may, but at present are not required to, allow for the use of telemedicine. Beginning January 1, 2026, Medicaid and CHIP managed care plans will be required to make payment on behalf of enrollees for medically necessary health care services provided through telemedicine if certain conditions outlined in Act 42 of 2024 are met. MA MCOs may negotiate payment for services rendered via telemedicine.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Apr. 2025).

Licensed Practitioners

MA coverage and payment for services provided via telehealth is separate and apart from authorization to engage in telehealth from a professional licensing standpoint. Providers using telehealth must remain informed on federal and state statutes, regulations, and guidance regarding telehealth. Practitioners should exercise sound clinical judgement and should not provide services through telehealth when it is not clinically appropriate to do so. Services delivered using telehealth must comply with all service specific and payment requirements for the service.

Provider Agencies

Provider agencies using behavioral health staff who are unlicensed, including, but not limited to, unlicensed master’s level therapists, mental health targeted case managers, mental health certified peer support specialists, certified recovery specialists, and drug and alcohol counselors (as defined in 28 Pa. Code §704.7(b)), and licensed practitioners may provide services using telehealth. Provider agencies should establish and enforce policies for assessing when it is clinically appropriate to deliver services through telehealth. Services delivered using telehealth must comply with all service specific and payment requirements for the service.

See out of state providers section for more info for out of state providers.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 3, July 1, 2022, (Accessed Apr. 2025).

The Department is opening Provider Type (PT)/Specialty (Spec) combination 08 (Clinic)/110 (Psychiatric Outpatient Clinic) in Place of Service (POS) 02 (Telemedicine), 10 (Telehealth provided in the home of the individual being served) and 49 (Independent Clinic) and PT/Spec combination 08/184 (Outpatient Drug and Alcohol Clinic) in POS 02, 10, 12 (Home) and 57 (Non-Residential Substance Abuse Treatment Facility) for the following outpatient and other office evaluation and management procedure codes as a result of clinical review.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Addition of Behavioral Health Providers to Certain Procedure Codes and other Procedure Code Changes (Aug. 2, 2022). (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-07 (Sept. 9, 2024), p. 3. (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-02 (April 29, 2024), p. 2. (Accessed Apr. 2025).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Apr. 2025).

School-Based ACCESS Program Provider Handbook

Delivery Method: While DHS has historically expressed its intent for MA services to be rendered to MA beneficiaries in person, some services may be delivered using telehealth.

SOURCE: PA Department of Human Services, School-Based ACCESS Program Provider Handbook, 35-24-01, Sept. 16, 2024, (Accessed Apr. 2025).

FQHC/RHC

Telemedicine encounters must be provided according to the same standard of care as if delivered in-person. FQHCs/RHCs providing physical health services are to refer to MA Bulletin 99-23-08, titled “Updates to Guidelines for the Delivery of Physical Health Services via Telehealth,” or the current MA Bulletin or Department guidance, for more information (https://www.dhs.pa.gov/docs/Publications/Documents/FORMS%20AND%20PUBS%20OMAP/MAB2023080201.pdf).

ELIGIBLE SITES

The originating site is where the beneficiary is located at the time the MA covered service is rendered to them via telehealth. The originating site can be, but is not limited to, the beneficiary’s home, a provider’s office, clinic, nursing facility, or other medical facility site. When the originating site is a provider’s office, clinic, nursing facility or other medical facility, staff at the originating site should be trained to assist beneficiaries with the use of the telehealth equipment and available to provide in-person clinical intervention, if needed. Providers should obtain the location of the beneficiary at the time each service is rendered via telehealth should there be a need for emergency medical services.

Providers are to use POS 02 when billing for services provided via telehealth technology to beneficiaries located in a location other than their home. Providers are to use POS 10 to identify when services via telehealth technology are provided in the home of the individual being served.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 4. (Accessed Apr. 2025).

The originating site is the setting at which an individual receives behavioral health services using telehealth delivery. When telehealth is being used to deliver services to an individual who is at a clinic, residential treatment setting, or facility setting, the originating site must have staff trained in telehealth equipment and protocols to provide operating support. In addition, the clinic or facility must have staff trained and available to provide clinical intervention in-person, if a need arises.

Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or bandwidth reducing devices. When services are being provided to a child, youth or young adult, consideration should also be given to how much caregiver involvement will be needed during the appointment.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 4, & 7, July 1, 2022, (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-07 (Sept. 9, 2024), p. 3. (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-24-02 (April 29, 2024), p. 2. (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Vaccine Counseling Only Visits for Beneficiaries Under 21 (May 30, 2023). (Accessed Apr. 2025).

Teledentistry may be used by dentists, FQHCs, and RHCs to provide dental services to MA beneficiaries. The provider must be licensed in Pennsylvania and enrolled in the MA Program.

Teledentistry visits must be provided according to the same standard of care as if delivered in-person.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin, Teledentistry Guidelines and Dental Fee Schedule Updates (May 2, 2022). (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Program Fee Schedule Revisions, issued Apr. 16, 2025, Effective May 1, 2025, (Accessed Apr. 2025).

Screening, Diagnostic, and Targeted Case Management Services for Eligible Juveniles Enrolled in Medical Assistance Prior to Release from a Carceral Setting

School-Based ACCESS Program Provider Handbook

Delivery Method: While DHS has historically expressed its intent for MA services to be rendered to MA beneficiaries in person, some services may be delivered using telehealth.

Nursing Services/Personal Care Services: Services delivered through telehealth are NOT compensable.

SOURCE: PA Department of Human Services, School-Based ACCESS Program Provider Handbook, 35-24-01, Sept. 16, 2024, (Accessed Apr. 2025).

GEOGRAPHIC LIMITS

Services may be provided using telehealth to Pennsylvania residents who are temporarily out of the state as long as the individual continues to meet eligibility for the Pennsylvania MA Program, and the provider or licensed practitioner has received authorization to practice in the state or territory where the individual will be temporarily located.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 5. (Accessed Apr. 2025).

Access to Services Delivered In-Person

In the managed care delivery system, the HealthChoices Primary Contractor must ensure that provider agencies and licensed practitioners who deliver services through telehealth within their service area can arrange for services to be delivered in-person as clinically appropriate or requested by the individual served. HealthChoices Primary Contractors must ensure that each contracted provider agency and licensed practitioner meets one of the two following criteria:

The provider agency or licensed practitioner maintains a physical location in Pennsylvania within 60 minutes or 45 miles (whichever is greater) of the area served with appropriate licensure for all services provided through telehealth; or
The provider agency or licensed practitioner maintains a physical location in a state bordering Pennsylvania, located within 60 minutes or 45 miles (whichever is greater) of the area served in Pennsylvania, maintains licensure in the state where they are physically located for all services provided through telehealth and is enrolled with the Pennsylvania MA program.

The HealthChoices Primary Contractor may apply for an exception to allow licensed practitioners and/or provider agencies beyond the 60 minute/45 mile restriction to deliver services through telehealth in their service area when supporting additional access to services or in circumstances when the licensed practitioner and/or provider agency is needed to meet the cultural, racial/ethnic, sexual/affectional or linguistic needs of individual(s) served or in instances when the licensed practitioner serves less than 5 individuals. An exception request can be submitted to the OMHSAS Telehealth Resource Account using the form in Attachment B.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, July 1, 2022, (Accessed Apr. 2025).

FACILITY/TRANSMISSION FEE

When the beneficiary accesses services at an enrolled originating site, the provider serving as the originating site may bill for the technology service using the telehealth originating site procedure code Q3014 only. The MA fee for Q3014 is $15.72. MA Providers may not bill procedure code Q3014 if another MA covered service is provided at the originating site. Providers may access the online version of the MA Program Fee Schedule at the Department’s website at: https://www.dhs.pa.gov/providers/Providers/Pages/Health%20Care%20for%20Providers/MAFee-Schedule.aspx.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08 (Aug. 2, 2023), p. 5. (Accessed Apr. 2025).

School-Based ACCESS Program Provider Handbook

Note that originating site facility fees discussed in Bulletin 99-23-08 are not applicable within SBAP. All providers using telehealth are advised to remain informed on all federal and state statutes, regulations and guidance regarding telehealth.

SOURCE: PA Department of Human Services, School-Based ACCESS Program Provider Handbook, 35-24-01, Sept. 16, 2024, (Accessed Apr. 2025).

Last updated 04/27/2025

Miscellaneous

Technology Requirements:

Technology used for telehealth, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. Telehealth equipment should clearly display the practitioners’ and participants’ faces to facilitate clinical interactions. The telehealth equipment must meet all state and federal requirements for the transmission or security of health information and comply with the Health Insurance Portability and Accountability Act (HIPAA).

Delivery of Services:

The medical record for the individual served must indicate each time a service is provided using telehealth including the receipt of informed consent prior to the start of the session, start time of service and end time of service. Additionally, if the individual served or their legal guardian, as applicable, consents to the recording of a telehealth service, documentation of consent must be included in the medical record.

Provider Policies:

Providers using telehealth must maintain written policies for the operation and use of telehealth equipment. Policies must include the provision of periodic staff training to ensure telehealth is provided in accordance with the guidance in this bulletin as well as the provider’s established patient care standards.
Providers must maintain a written policy detailing a contingency plan for transmission failure or other technical difficulties that render the behavioral health service undeliverable. Contingency plans should describe how the plan will be communicated to individuals receiving services.
Prior to delivering services through telehealth, providers or practitioners should provide information to the individual receiving services that supports the delivery of quality services. At a minimum, information should address the importance of the individual being in a private location, preventing interruptions and distractions such as from children or other family members, visitors in the household and from other communication or bandwidth reducing devices. When services are being provided to a child, youth or young adult, consideration should also be given to how much caregiver involvement will be needed during the appointment.

Determining Appropriateness for Telehealth Delivery of Services

Licensed practitioners and provider agencies delivering services through telehealth must have policies that ensure that services are delivered using telehealth only when it is clinically appropriate to do so and that licensed practitioners are complying with standards of practice set by their licensing board for telehealth where applicable.

Factors to consider include, but are not limited to:

The preference of the individual served and/or the preference of parents/guardians
Whether there is an established relationship with the service provider and the length of time the individual has been in treatment
Level of acuity needed for care
Risk of harm to self or others
Age of a minor child
Ability of the individual served to communicate, either independently or with accommodation such as an interpreter or electronic communication device
Any barriers to in-person service delivery for the individual
Access to technology of the individual served
Whether privacy for the individual served could be maintained if services are delivered using telehealth
Whether the service relies on social cueing and fluency

The preference of the individual served and their legal guardian(s), as applicable, should be given high priority when making determinations of the appropriateness of the telehealth delivery. However, no service should be provided through telehealth when, in the best clinical judgement of the licensed practitioner, it is not clinically appropriate. When the use of telehealth is not clinically appropriate, the licensed practitioner or provider agency must offer the services in-person. If the individual disagrees with the clinical determination, the licensed practitioner or provider agency may refer the individual to other in-network providers or the managed care organization.

Guidance specific to delivering children’s services through telehealth is included in Attachment A.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, pgs. 4-5 & 7-8, July 1, 2022, (Accessed Apr. 2025).

Pennsylvania Residents Temporarily Out-of-State

Behavioral Health Services may be provided using telehealth to meet the behavioral healthcare needs of Pennsylvania residents who are temporarily out of the state as long as the delivery of services out-of-state is consistent with the authorization for services and treatment plan, the individual continues to meet eligibility for the Pennsylvania MA Program, and the Pennsylvania provider agency or licensed practitioner has received authorization to practice in the state or territory where the individual will be temporarily located.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, July 1, 2022, (Accessed Apr. 2025).

Technology Requirements

Providers should fully document the services rendered and the telecommunication technology used to render the service in the MA beneficiary’s medical record. If the service was rendered using audio-only technology, providers are to document that the services were rendered using audio-only technology and the reason audio/video technology could not be used.

Technology used for telehealth, whether fixed or mobile, should be capable of presenting sound and image in real-time and without delay. The telehealth equipment should clearly display the rendering practitioner’s and participant’s face to facilitate clinical interactions and must meet all state and federal requirements for the transmission and security of health information, including HIPAA.

Audio-only telecommunications technology may be used when the beneficiary does not have video capability or for an urgent medical situation, if consistent with state and federal law. Providers must assure the privacy of the beneficiary receiving services and comply with HIPAA and all other federal and state laws governing confidentiality, privacy, and consent. Public facing video communication applications should not be used to render services via telehealth.

Telehealth does not include asynchronous or “store and forward” technology such as facsimile machines, electronic mail systems, or remote patient monitoring devices. While asynchronous applications are not considered telemedicine in the MA Program, they may be utilized as part of a MA covered service, such as a laboratory service, x-ray service or physician service. Telehealth also does not include text messages, although text messages and telephone may continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, Aug. 2, 2023, p. 3-4, (Accessed Apr. 2025).

Guidelines for Telehealth Service Delivery for Children and Youth

The following guidelines are recommended best practices. When delivering services through telehealth, licensed practitioners and provider agencies should ensure that, regardless of age, each child or youth has sufficient caregiver support to engage effectively in services.

When services are being delivered through telehealth to children 3 to 5 years old, each child should have a caregiver participate during the provision of services.
When services are being delivered through telehealth to children 6 to 9 years old, a caregiver should observe each child during provision of services.
When services are being delivered through telehealth to children ages 10 to 13 years old, any child that may need a caregiver during the provision of services should have a caregiver available.
When services are being delivered through telehealth to youth 14 years old to 18 years old, any youth that may need a caregiver during the provision of services should have a caregiver available.
All children or youth that participate in services through telehealth delivery should have the ability to communicate, either independently or with accommodation such as an interpreter or electronic communication device.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Bulletin, OMHSAS 22-02, Attachment A Guidelines for Telehealth Service Delivery for Children and Youth. (Accessed Apr. 2025).

FQHC/RHC Manual

Physical and behavioral health records shall be legible and shall include, but not be limited to:

An indication if the visit was conducted using telehealth or telemedicine.

Last updated 04/27/2025

Out of State Providers

Out-of-state licensed practitioners who provide treatment through telehealth to individuals in Pennsylvania through the MA program must meet the licensing requirements established by the Pennsylvania Department of State. In order to receive payment for services to beneficiaries in the FFS delivery system, practitioners must be enrolled in the MA Program. Practitioners seeking to provide services to beneficiaries in the managed care delivery system should contact the appropriate Managed Care Organization for its enrollment processes. Practitioners are also advised to consult with their professional liability insurance carrier regarding provision of services in other jurisdictions.

SOURCE: PA Department of Human Services, Office of Mental Health and Substance Abuse Services Bulletin OMHSAS-22-02, p. 3, July 1, 2022, (Accessed Apr. 2025).

Out-of-state licensed practitioners who render services via telehealth to individuals in Pennsylvania through the MA Program must meet the licensing requirements established by the Pennsylvania Department of State. In order to receive payment for services to beneficiaries in the FFS delivery system, practitioners must be enrolled in the MA Program.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 5, (Aug. 2, 2023) (Accessed Apr. 2025).

Out-of-state licensed practitioners who participate in an interprofessional consultation service for a beneficiary must meet the licensing requirements established by the Pennsylvania Department of State. Providers must be enrolled in the MA Program to receive payment for services to beneficiaries in the FFS delivery system.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

See Miscellaneous section for residence temporarily out-of-state.

Last updated 04/27/2025

Overview

Under bulletins from the Office of Mental Health and Substance Abuse Services and PA Medical Assistance, they now offer live video reimbursement to a wide range of licensed providers, and patient locations, and audio-only in situations when the beneficiary does not have video capability or an urgent medical situation. PA Medicaid does not consider store-and-forward or remote patient monitoring to fall under the definition of telemedicine. Reimbursement for interprofessional consultation services were also recently added though store-and-forward may only be utilized as part of the synchronous consultation.

Last updated 04/27/2025

Remote Patient Monitoring

POLICY

Telehealth, for purposes of MA Program payment, does not include asynchronous or store and forward technology or facsimile machines, electronic mail systems or remote patient monitoring devices. However, these technologies may be utilized as a part of the provision of a MA covered service.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 2-3, Aug. 2, 2023 (Accessed Apr. 2025).

CONDITIONS

PA Medicaid pays for some continuous glucose monitoring products with prior authorization.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Prior Authorization of Continuous Glucose Monitoring Products – Pharmacy Services, Jan. 8, 2024, (Accessed Apr. 2025).

PROVIDER LIMITATIONS

No Reference Found

OTHER RESTRICTIONS

No Reference Found

Last updated 04/27/2025

Store and Forward

POLICY

“Asynchronous interaction.” An exchange of information between a patient and a health care provider that does not occur in real time, including the secure collection and transmission of a patient’s medical information, clinical data, clinical images, laboratory results and self-reported medical history.

SOURCE: PA Consolidated Statutes, Title 40, Chapter 48, Section 4802, (Accessed Apr. 2025).,

Telehealth does not include asynchronous or store and forward technology such as facsimile machines, electronic mail systems, or remote patient monitoring devices. While asynchronous applications are not considered telehealth in the MA Program, they may be utilized as part of a MA covered service, such as a laboratory service, x-ray service or physician service. Telehealth also does not include text messages, although text messages and telephone may continue to be utilized for non-service activities, such as scheduling appointments.

SOURCE: PA Department of Human Services, Medical Assistance Bulletin 99-23-08, p. 4, Aug. 2, 2023 (Accessed Apr. 2025).

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

ELIGIBLE SERVICES/SPECIALTIES

SOURCE: PA Department of Human Services, Medical Assistance Bulletin Interprofessional Consultation Services, (Dec. 27, 2023) (Accessed Apr. 2025).

See list of eligible interprofessional telephone/electronic consultation codes in the fee schedule.

SOURCE: PA Department of Human Services, Medical Assistance Program Fee Schedule Revisions, issued Apr. 16, 2025, Effective May 1, 2025, (Accessed Apr. 2025).

GEOGRAPHIC LIMITS

No Reference Found

TRANSMISSION FEE

No Reference Found

Professional Requirements

Last updated 04/27/2025

Cross State Licensing

Pennsylvania issues extraterritorial licenses that allow practice in Pennsylvania to physicians residing or practicing with unrestricted licenses in an adjoining state, near the Pennsylvania boundary, and whose practice extends into Pennsylvania.

Pennsylvania bases the granting of this license on the availability of medical care in the area involved, and whether the adjoining state extends similar privileges to Pennsylvania physicians.

SOURCE: PA Statutes Annotated, Title 63 Sec. 422.34(a) and (c)(2). (Accessed Apr. 2025).

How will the use of telemedicine by out-of-state practitioners be impact?

As was the case prior to the pandemic, practitioners wishing to provide services to individuals in Pennsylvania need to be licensed in Pennsylvania in order to practice in Pennsylvania. This holds true whether the provision of services occurs in person or via an electronic interaction such as a telehealth consultation. Practitioners who are not licensed in Pennsylvania and wish to provide services to individuals in Pennsylvania via telemedicine or otherwise may apply for licensure here: https://www.pals.pa.gov

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQ. (Accessed Apr. 2025).

Last updated 04/27/2025

Definitions

Telemedicine is a way to provide real-time, interactive health services virtually, such as through video conferencing or over the phone. In Pennsylvania, Medical Assistance (MA) enrolled providers have been permitted to provide certain physical health and behavioral health services via telemedicine since 2007 and 2011, respectively, to provide access to specialist care. The option was not widely used until many providers, and not just specialty care providers, shifted to deliver services via telemedicine during the COVID-19 pandemic and expanded for services beyond specialist care.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Apr. 2025).

Telehealth: The delivery and facilitation of health care services by telecommunications and digital communication technologies, including Health Insurance Portability and Accountability Act (HIPPA)-compliant video and audio-only communication platforms.

SOURCE: Title 49, Part I, Subpart A, Ch. 16, Subch. F, Sec. 16,92, (Accessed Apr. 2025).

Last updated 04/27/2025

Licensure Compacts

Member of the Interstate Medical Licensure Compact.

SOURCE: The IMLC. Interstate Medical Licensure Compact. (Accessed Apr. 2025).

Member of Interjurisdictional Psychology Compact.

SOURCE: PSYPACT, Map, (Accessed Apr. 2025).

Member of Nurses Licensure Compact.

SOURCE: Nurse Licensure Compact, (Accessed Apr. 2025).

Member of Physical Therapy Compact.

SOURCE: PT Compact, Compact Map, (Accessed Apr. 2025).

Member of the Emergency Medical Services Compact.

SOURCE: EMS Compact. (Accessed Apr. 2025).

* See Compact websites for implementation and license issuing status and other related requirements.

Last updated 04/27/2025

Miscellaneous

No Reference Found

Last updated 04/27/2025

Online Prescribing

Medical Marijuana

Except as provided in subsection (b), a dispensary shall ensure that a physician or a pharmacist is available, either in person or by synchronous interaction, to verify patient certifications and to consult with patients and caregivers at all times during the hours the facility is open to dispense or to offer to dispense medical marijuana products to patients and caregivers.

If a dispensary is authorized to operate more than one facility under its permit, a physician assistant or a certified registered nurse practitioner may be available, either in person or by synchronous interaction, to verify patient certifications and to consult with patients and caregivers at each of the other locations instead of a physician or pharmacist. The physician, pharmacist, physician assistant or certified registered nurse practitioner may rotate coverage of the facilities, provided that a physician or pharmacist is always available, either in person or by synchronous interaction, at one of the facilities. Furthermore, no less than one dedicated medical professional must be present either, physically or by synchronous interaction, for each distinct dispensary facility location and shall not cover more than one dispensary facility location regardless of whether in-person coverage or synchronous interaction is used.

SOURCE: Rules and Regulations, Title 28, 1161a.25, (Accessed Apr. 2025).

Opioid Treatment Programs. For OTPs, the initial physical examination required under subsection (a)(1) may be conducted by means of telehealth for those patients being admitted for treatment of opioid use disorder in an OTP with either buprenorphine or methadone provided that the provider determines that an adequate evaluation of the patient can be accomplished by telehealth and a full in-person physical examination is completed within 14 days after admission to the OTP. The initial telehealth examination must comply with the requirements of 42 CFR 8.12 (relating to Federal opioid use disorder treatment standards).

SOURCE: Title 49, Part I, Subpart A, Ch. 16, Subch. F, Sec. 16,92, (Accessed Apr. 2025).

See FAQ Number 13 on federal requirements for substance abuse disorder treatment and Medication Assisted Treatment.

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Apr. 2025).

Last updated 04/27/2025

Professional Board Standards

Does the Department of State allow licensed professionals to practice telemedicine in Pennsylvania?

Licensees under the Department’s Bureau of Professional and Occupational Affairs (BPOA) health-licensing boards can provide services within their existing scopes of practice via telemedicine when appropriate, provided it is done according to accepted standards of care.

While providing telemedicine is permissible from a professional licensing standpoint, it is important to note that there may be additional issues to consider − such as the type of insurance coverage, insurance reimbursement policies, medical appropriateness, and the intersection of telemedicine services with existing facility licensing requirements that must be met by hospitals or other licensed health care facilities.

These additional considerations are not within the purview of the Department of State. Rather, such issues fall within the jurisdiction of other federal and state agencies, such as the United States Department of Health and Human Services (HHS), the Centers for Medicare and Medicaid Services (CMS), the Pennsylvania Department of Human Services (DHS), the Pennsylvania Insurance Department, the Pennsylvania Department of Drug and Alcohol Programs (DDAP), and the Pennsylvania Department of Health (DOH).

SOURCE: PA Dept. of State, Professional Licensing, Telemedicine FAQs. (Accessed Apr. 2025).