Medicaid & Medicare

Out of State Providers

Telehealth makes it possible for providers to deliver services across state lines if they are properly licensed in the state the patient is located in. Some Medicaid programs have placed restrictions on providers located out-of-state, requiring them to have some sort of an in-state presence, while other states have explicitly allowed out-of-state providers as long as they are licensed in the state and enroll with the Medicaid program.

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Disclaimer

PLEASE NOTE: CCHP is providing the following for informational purposes only. We are not providing legal advice or interpretation of the laws and regulations and policies. CCHP encourages you to check with the appropriate state agency for further information and direction. This information should not be construed as legal counsel. Consult with an attorney if you are seeking a legal opinion.

Federal

Last updated 03/18/2024

Doctors of Medicine and Osteopathy – The requirement that a …

Doctors of Medicine and Osteopathy – The requirement that a doctor of medicine be legally authorized to practice medicine and surgery by the State in which he/she performs his/her services means a physician is licensed to practice medicine and surgery. (Similar regulations exist for other types of practitioners, see manual).

SOURCE:  Medicare General Information, Eligibility and Entitlement, Chapter 5 – Definitions, Updated 11/2/2018, Sec. 70, p. 32.  (Accessed Mar. 2024).

During the PHE, CMS has waived the Medicare requirement that a physician or non-physician practitioner must be licensed in the state in which they are practicing if the physician or practitioner 1) is enrolled as such in the Medicare program, 2) has a valid license to practice in the state reflected in their Medicare enrollment, 3) is furnishing services — whether in person or via telehealth — in a state in which the emergency is occurring in order to contribute to relief efforts in his or her professional capacity, and 4) is not affirmatively excluded from practice in the state or any other state that is part of the section 1135 emergency area. A physician or non-physician practitioner could seek an 1135-based licensure waiver from CMS by contacting the provider enrollment hotline for the Medicare Administrative Contractor that serviced their geographic area. This waiver did not have the effect of waiving state or local licensure requirements or any requirement specified by the state or a local government as a condition for waiving its licensure requirements. We originally implemented the waiver out of an abundance of caution; however, it turned out that regulations that existed before the PHE allowed for a deferral to state law.

Reporting Home Address: During the PHE, CMS allowed practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment while continuing to bill from their currently enrolled location. Even though the PHE is anticipated to end on May 11, 2023, the waiver will continue through December 31, 2024.

State Licensure: During the PHE, CMS allowed licensed physicians and other practitioners to bill Medicare for services provided outside of their state of enrollment. CMS has determined that, when the PHE ends, CMS regulations will continue to allow for a total deferral to state law. Thus, there is no CMS-based requirement that a provider must be licensed in its state of enrollment.

SOURCE: Centers for Medicare and Medicaid Services, Physicians and Other Clinicians: CMS Flexibilities to Fight COVID-19, 11/6/23, (Accessed Mar. 2024).

Items and services furnished outside the United States are excluded from coverage (with exceptions for beneficiaries traveling in Canada and emergency situations).

Payment may not be made for a medical service (or a portion of it) that was subcontracted to another provider or supplier located outside the United States. For example, if a radiologist who practices in India analyzes imaging tests that were performed on a beneficiary in the United States, Medicare would not pay the radiologist or the U.S. facility that performed the imaging test for any of the services that were performed by the radiologist in India.

SOURCE:  Medicare Benefit Policy Manual, Chapter 16 – General Exclusions from Coverage, Revised 11/6/14, Sec. 60, p. 24.  (Accessed Mar. 2024).

MFTs and MHCs

How do I enroll to perform telehealth services to patients located in my home state or another state?

Practitioners who perform telehealth services should enroll based on their enrollment scenario. Refer to the scenarios below as a guide for completing the paper application. For faster and easier enrollment, providers are encouraged to submit their applications electronically through PECOS.

Practitioner Only Renders Services in a Private Practice: The practitioner renders telehealth services from his/her home in Florida. The practitioner completes all applicable sections of the paper CMS-855I. In section 4B of the CMS-855I, enter the location where the telehealth service is performed (e.g., office, home). Select the practice location type as “Business Office for Administrative/Telehealth Use Only” or “Home Office for Administrative/Telehealth Use Only.” This option prevents the practitioner’s home address from being published on Care Compare, a tool for Medicare beneficiaries to find and compare different Medicare providers.

The practitioner submits the completed application to First Coast Services Options, the MAC that processes enrollment applications for Florida.

Practitioner reassigns all benefits to a group. Practitioner and group are in the same state: The practitioner reassigns benefits to a group In Maryland but will be rendering telehealth services from his/her home in Maryland. The practitioner completes all applicable sections of the CMS-855I. In section 4F of the CMS-855I, the practitioner lists the group accepting the new reassignment of benefits from the practitioner. If the group is already enrolled, no further action is needed. If the group is not enrolled, they will complete all applicable sections of the CMS-855B and list their office locations in section 4A. The practitioner does not list his/her home address on the CMS-855I or on the group’s CMS-855B application. The calendar year 2024 Physician Fee Schedule final rule allows physicians/practitioners who bill for Medicare telehealth services to report the place of service (POS) code that would have been reported had the service been furnished in person, through December 31, 2024.

The practitioner and group submit the CMS-855I and CMS-855B to Novitas Solutions, the MAC that processes enrollment applications for Maryland.

. Practitioner reassigns all benefits to a group. Practitioner and Group are in different states: The practitioner reassigns benefits to a group in Maryland but will be rendering telehealth services from his/her home in Florida. The practitioner must enroll in the state where the group is located because they are submitting claims on behalf of the practitioner. The practitioner completes all applicable sections of the CMS-855I. In section 4F of the CMS-855I, the practitioner lists the group accepting the new reassignment of benefits from the practitioner. If the group is already enrolled, no further action is needed. If the group is not enrolled, they will complete all applicable sections of the CMS-855B and list their office locations in section 4A. The practitioner does not list his/her home address on the CMS-855I or on the group’s CMS-855B application. The practitioner can continue to bill as if he/she furnished the service in person, through December 31, 2024.

The practitioner and group submit the CMS-855I and CMS-855B to Novitas Solutions, the MAC that processes enrollment applications for Maryland.

SOURCE: Centers for Medicare and Medicaid Services, Marriage and Family Therapists and Mental Health Counselors, Provider Enrollment Frequently Asked Questions, March 2024, (Accessed Mar. 2024).

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Alabama

Last updated 06/18/2024

Telemedicine services may only be provided as a result of …

Telemedicine services may only be provided as a result of a patient’s request, part of an expected follow up, or a referral from the patient’s licensed physician with whom the patient has an established patient-physician relationship.

Services rendered via telecommunication system must be provided by a provider who is licensed, registered, or otherwise authorized to engage in his or her healthcare profession in the state where the patient is located. Per Alabama law, the provision of telemedicine medical services is deemed to occur at the patient’s originating site within this state.

Providers must indicate an in-state or qualifying bordering state site of practice address from which telemedicine services will be provided.

Note: This policy does not expand or grant any authority outside that authority granted to the provider by their respective licensure board or by federal or state law.

SOURCE: AL Medicaid Management Information System Provider Manual, Telemedicine Services, Ch. 112, Jul. 2024, pg. 3-4 (Accessed Jun. 2024).

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Alaska

Last updated 06/19/2024

When can an out-of-state provider not licensed in Alaska provide

When can an out-of-state provider not licensed in Alaska provide services to a member located in Alaska?

Physicians who are licensed in another state may practice telehealth without an Alaska license if:

  • The physician and patient have an established physician-patient relationship and the physician has previously conducted an in-person examination of the patient; or
  • If the patient has a suspected or diagnosed life-threatening condition for which the patient has been referred by an Alaska-licensed physician to a physician licensed in another state and the visit relates to that condition.

SOURCE: Alaska Medicaid Frequently Asked Questions Coverage of Telehealth Modalities, Sept. 19, 2023, (Accessed Jun. 2024).

Subject to the requirements of 7 AAC 110.620 – 7 AAC 110.639, to be eligible for payment under 7 AAC 105 – 7 AAC 160 for providing a service by means of a telehealth modality, a provider must meet the following requirements:

  1. the provider must have an active license under AS 08 or AS 47, an active certification in the state, or an active license under the applicable laws of the jurisdiction in which the provider is located;
  2. the provider must be enrolled under 7 AAC 105.210;
  3. the provider, if licensed under AS 08 and required under 12 AAC 02.600, must be registered under 12 AAC 02.600 (telemedicine business registry);
  4. the service must be delivered within the rendering provider’s, and if applicable, consulting provider’s scope of licensure or certification;
  5. a claim submitted to the department must include applicable telehealth modifiers and place-of-service coding;
  6. if the rendering provider or consulting provider determines, during a telehealth encounter, that a service extends beyond the scope of that provider’s license or certification, the provider must discontinue the encounter and refer the recipient to an appropriate provider; the rendering provider or consulting provider may bill only for the portion of the encounter that was within that provider’s scope of license or certification and only if the rendered portion of the encounter met all criteria of a separately billable service;
  7. except as otherwise provided in 7 AAC 105 – 7 AAC 160, a recipient must be present during and participate in a telehealth encounter;
  8. the provider must comply with all record keeping requirements set out under 7 AAC 105.230 for all telehealth services rendered;
  9. the rendering provider and consulting provider, when delivering a service by means of a synchronous telehealth modality, must annotate the patient’s clinical record with the method of delivery, the recipient’s location during the delivery of the service, and confirmation that the recipient has consented to a telehealth method of delivery.

SOURCE:  AK Admin. Code, Title 7, 110. 630 (Accessed Jun. 2024).

The Travel Service Authorization Request form has been updated to include a section for providers to declare what telehealth considerations were done prior to requesting travel.

SOURCE: AK MMIS Fiscal Agent Transition Town Hall, Dec. 20, 2023, & Travel Service Authorization Request Form, (Accessed Jun. 2024).

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Arizona

Last updated 05/29/2024

A provider who is not licensed within the State of …

A provider who is not licensed within the State of Arizona may provide Telehealth services to an AHCCCS member located in the state if the provider is an AHCCCS registered provider and complies with all requirements listed within A.R.S. § 36-3606.

SOURCE: AZ Medical Policy for AHCCCS Covered Services. Telehealth and Telemedicine Ch 300, (320-I pg. 2), Approved 8/29/23. (Accessed May 2024).

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Arkansas

Last updated 05/27/2024

A healthcare provider treating patients in Arkansas through telemedicine shall …

A healthcare provider treating patients in Arkansas through telemedicine shall be fully licensed or certified to practice in Arkansas and is subject to the rules of the appropriate state licensing or certification board. This requirement does not apply to the acts of a healthcare provider located in another jurisdiction who provides only episodic consultation services.

SOURCE: AR Medicaid Provider Manual. Section I General Policy.  Rule 105.190. Updated Jan. 1, 2022, (Accessed May 2024).

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California

Last updated 06/29/2024

Provider must be licensed in CA, enrolled as a Medi-Cal …

Provider must be licensed in CA, enrolled as a Medi-Cal rendering provider or non-physician medical practitioner (NMP) and affiliated with an enrolled Medi-Cal provider group. The enrolled Medi-Cal provider group for which the health care provider renders services via telehealth must meet all Medi-Cal program enrollment requirements and must be located in California or a border community.

SOURCE: CA Department of Health Care Services. Medi-Cal Part 2 General Medicine Manual. Telehealth. (Mar. 2024), Pg. 3.; Welfare and Institutions Code 14132.725. (Accessed Jun. 2024).

A person who is licensed as a health care practitioner in another state and is employed by a tribal health program does not need to be licensed in California to perform services for the tribal health program in California or a border community (Business and Professions Code section 719).

SOURCE: CA Department of Health Care Services. Telehealth FAQ. (Accessed Jun. 2024).

Dental providers billing for services delivered via teledentistry must be enrolled as Medi- Cal dental providers. The dental provider rendering MediCal covered benefits or services via a teledentistry modality must be licensed in California, enrolled as a Medi-Cal Dental rendering provider, operate within their allowable scope of practice, and meet applicable standards of care.

SOURCE: CA Department of Health Care Services (DHCS). Medi-Cal Dental Provider Handbook. 2024. Pg. 4-22 – 4-23. (Accessed Jun. 2024).

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Colorado

Last updated 04/30/2024

Any licensed provider enrolled with Colorado Medicaid is eligible to

Any licensed provider enrolled with Colorado Medicaid is eligible to provide telemedicine services within the scope of the provider’s practice. Providers that meet the definition of an eHealth Entity shall enroll as the eHealth specialty.

Electronic Health Entity (eHealth Entity) means a group practice that delivers services exclusively through telemedicine and is enrolled in a provider type that has an eHealth specialty. eHealth entities:

    1. Cannot be Primary Care Medical Providers
      1. Primary Care Medical Provider (PCMP) means an individual physician, advanced practice nurse or physician assistant, who contracts with a Regional Accountable Entity (RAE) in the Accountable Care Collaborative (ACC), with a focus on primary care, general practice, internal medicine, pediatrics, geriatrics, or obstetrics and gynecology
    2. Can be either in-state or out-of-state.

SOURCE: CO Adopted Rule 8.095.1, 8.095.3. (Accessed Apr. 2024).

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Connecticut

Last updated 04/12/2024

DSS’ continued expectation is that enrolled CMAP providers will perform

DSS’ continued expectation is that enrolled CMAP providers will perform clinically appropriate services including, but not limited to, ensuring timely access to in-person services when medically necessary or requested by the HUSKY Health member for optimum quality of care. Therefore, all enrolled billing entities must have the capacity to deliver services in-person and must provide services in-person to the full extent that is clinically appropriate for their patients and to the full extent necessary if the HUSKY Health member does not consent to receiving one or more services via telehealth. Having the capacity means that the provider must have a physical location in CT, (or an approved applicable border state as approved as part of enrollment) where the provider has a room or set of rooms to see members in-person and can maintain the member’s privacy and confidentiality during the visit.

Location of Practitioner – Providers

Independent Practitioners/Group Practitioners/Federally Qualified Health Centers/Outpatient Hospitals

Except as otherwise specifically stated in subsequent provider guidance issued by DSS, stated as part of telehealth policy criteria for a specific service as outlined on the CMAP Telehealth Table, or for coverage of out-of-state services that are not available in-state or from a border provider as required under 42 CFR §431.52, a practitioner who is enrolled with CMAP as an independent provider or as part of an independent provider group, or as a FQHC or outpatient hospital and maintains an approved service location as part of the CMAP enrollment, has the flexibility to perform eligible telehealth services even when the performing/rendering practitioner is not physically in-person at one of the enrolled CT or border service locations at the time of the service, so long as the practitioner complies with all applicable state and federal requirements. Enrolled border providers and out-of-state providers rendering services as approved in 42 CFR 431.52, are encouraged to research applicable licensing and scope of practice requirements that may apply specifically to their location at the time of the telehealth service.

In-state enrolled CMAP providers (facility/billing provider/parent company etc.) who contract with out-of-state practitioners to provide 100% telehealth services to HUSKY members must ensure that the billing provider can provide in-person services when medically necessary or when the member requests it. Consistent with current CMAP requirements, the out-of-state practitioner must hold an active CT license. The billing provider is responsible for providing the Department with supporting documentation for services during any audit review or investigation. If documentation is not provided, or if it is not sufficient to support the services billed, the billing provider will be responsible for any calculated overpayment that needs to be returned to the Department. Except for providers meeting the requirements under 42 CFR §431.52, out-of-state practitioners who are not contracted with an instate CMAP provider are not eligible to enroll and bill for telehealth services.

SOURCE: CT Dept. of Social Services. Provider Bulletin 2023-38 REVISED Guidance for Services Rendered via Telehealth (May 2023). (Accessed Apr. 2024).

Border Providers who are enrolled with the CMAP and have a designation as a border provider may continue to render telehealth services in their border state. Border providers do not need to have an approved location within the state of Connecticut. Enrolled border providers follow the same rules as in-state CMAP enrolled providers, therefore they can perform approved telehealth services.

SOURCE: CT Medicaid Assistance Program Telehealth FAQ (May 2023), p. 6. (Accessed Apr. 2024).

Effective Now Until June 30, 2024

The following providers in another state or territory of the United States or the District of Columbia, that provide telehealth services pursuant to his or her authority under any relevant order issued by the Commissioner of Public Health, and maintains professional liability insurance or other indemnity against liability for professional malpractice in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut health care providers, are considered a telehealth provider:

  • Physician
  • Physician assistant
  • Physical therapist or physical therapist assistant
  • Chiropractor
  • Naturopath
  • Podiatrist
  • Occupational therapist or occupational therapy assistant
  • Optometrist
  • Registered nurse or advanced practice registered nurse
  • Psychologist
  • Marital and family therapist
  • Clinical social worker
  • Master social worker
  • Alcohol and drug counselor
  • Professional counselor
  • Dietitian-nutritionist
  • Speech and language pathologist
  • Respiratory care practitioner
  • Audiologist
  • Pharmacist
  • Paramedic
  • Nurse-midwife
  • Dentist
  • Behavior analyst
  • Genetic counselor
  • Music therapist
  • Art therapist
  • Athletic trainer

Ending on June 30, 2024, any Connecticut entity, institution or health care provider that engages or contracts with a telehealth provider that is licensed, certified or registered in another state or territory of the United States or the District of Columbia to provide health care or other health services shall verify the credentials of such provider in the state in which he or she is licensed, certified or registered, ensure that such a provider is in good standing in such state, and confirm that such provider maintains professional liability insurance or other indemnity against liability for professional malpractice in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut health care providers.

Ending on June 30, 2024, the Commissioner of Public Health may temporarily waive, modify or suspend any regulatory requirements adopted by the Commissioner of Public Health or any boards or commissions as the Commissioner of Public Health deems necessary to reduce the spread of COVID-19 and to protect the public health for the purpose of providing residents of this state with telehealth services from out-of-state practitioners.

SOURCE: HB 5596 (2021 Session) SB 2 (2022 Session). (Accessed Apr. 2024).

Effective July 1, 2022

The Commissioner of Public Health may issue an order authorizing telehealth providers who are not licensed, certified or registered to practice in this state to provide telehealth services to patients in this state. Such order may be of limited duration and limited to one or more types of providers described in subdivision (13) of subsection (a) of section 1 of public act 21-9, as amended by this act, or subdivision (12) of subsection (a) of section 19a906 of the general statutes, as amended by this act. The commissioner may impose conditions including, but not limited to, a requirement that any telehealth provider providing telehealth services to patients in this state pursuant to such order shall submit an application for licensure, certification or registration, as applicable. The commissioner may suspend or revoke any authorization provided pursuant to this section to a telehealth provider who violates any condition imposed by the commissioner or applicable requirements for the provision of telehealth services under the law. Any such order issued pursuant to this section shall not constitute a regulation, as defined in section 4-166 of the general statutes.

SOURCE: SB 2 (2022 Session), Sec. 33 (Accessed Apr. 2024).

Out-of-State Surgery

Physicians rendering inpatient surgical services for a CMAP member must ensure the hospital has submitted and obtained an approved prior authorization for the inpatient surgery. Once the hospital has an approved authorization on file for the CMAP member, the member is eligible to receive their pre- and/or post-surgical consultations via telemedicine. Any telemedicine service related to the surgery must be rendered by the Out-of-State (OOS) provider who will be performing the surgery. All telemedicine services must be clinically appropriate and medically necessary. Pre/Post surgery instructions are not eligible for reimbursement via telemedicine.

SOURCE: CT Medical Assistance Program, Provider Bulletin 2020-09 (March 2020), p. 4. (Accessed Apr. 2024).

Border Hospital Reimbursement

The Department of Social Services (DSS) is notifying border and out-of-state (OOS) hospitals that the rates and parameters for reimbursement of inpatient and outpatient hospital services, provided to Connecticut Medicaid members, have been updated effective for dates of discharges on or after January 1, 2023.

SOURCE: CT Medical Assistance Program, Provider Bulletin 2022-95 (Dec. 2020), p. 1. (Accessed Apr. 2024).

The Commissioner of Public Health, in consultation with the Commissioner of Early Childhood, shall develop and implement a plan to establish licensure by reciprocity or endorsement of a person who (1) is (A) a speech and language pathologist licensed or certified to provide speech and language pathology services, or entitled to provide speech and language pathology services under a different designation, in another state having requirements for practicing in such capacity that are substantially similar to or higher than the requirements in force in this state, or (B) an occupational therapist licensed or certified to provide occupational therapy services, or entitled to provide occupational therapy services under a different designation, in another state having requirements for practicing in such capacity that are substantially similar to or higher than the requirements in force in this state, (2) has no disciplinary action or unresolved complaint pending against such person, and (3) intends to provide early intervention services under the employment of an early intervention service program participating in the birth-to-three program established pursuant to section 17a-248b of the general statutes.

When developing and implementing such plan, the Commissioner of Public Health shall consider eliminating barriers to the expedient licensure of such persons in order to immediately address the needs of children receiving early intervention services under the birthto-three program. The provisions of any interstate licensure compact regarding a speech and language pathologist or occupational therapist adopted by the state shall supersede any program of licensure by reciprocity or endorsement implemented under this section for such speech and language pathologist or occupational therapist.

On or before January 1, 2023, the Commissioner of Public Health shall (1) implement the plan to establish licensure by reciprocity or endorsement, and (2) report, in accordance with the provisions of section 11-4a of the general statutes, to the joint standing committees of the General Assembly having cognizance of matters relating to public health and children regarding such plan and recommendations for any necessary legislative changes related to such plan.

SOURCE: SB 2 (2022 Session), Sec. 26. (Accessed Apr. 2024).

Effective July 1, 2024

A telehealth provider also is to include an appropriately licensed, certified or registered provider as listed below in another state or territory of the United States or the District of Columbia, who (i) provides telehealth services under any relevant order issued pursuant to section 33 of this act, (ii) provides mental or behavioral health care through the use of telehealth within such person’s scope of practice and in accordance with the standard of care applicable to the profession, and (iii) maintains professional liability insurance, or other indemnity against liability for professional malpractice, in an amount that is equal to or greater than that required for similarly licensed, certified or registered Connecticut mental or behavioral health care providers:

  • physician
  • naturopath
  • registered nurse
  • advanced practice registered nurse
  • physician assistant
  • psychologist
  • marital and family therapist
  • clinical social worker
  • master social worker
  • alcohol and drug counselor
  • professional counselor
  • dietitian-nutritionist
  • nurse-midwife
  • behavior analyst
  • music therapist
  • art therapist

SOURCE: SB 2 (2022 Session), Sec. 30. (Accessed Apr. 2024).

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Delaware

Last updated 04/24/2024

A distant site provider is a health care practitioner, legally …

A distant site provider is a health care practitioner, legally allowed to practice in the state of Delaware or the state in which the provider is located if allowed under Delaware State law to provide telehealth services without a Delaware license through the Interstate Medical Licensure Compact or otherwise.

In order to provide telehealth under DMAP, providers at both the originating and distant site must be enrolled with DMAP and must meet all requirements for their discipline as specified in the Delaware Code and the Medicaid State Plan. For services delivered through telehealth technology to be covered, referring providers and distant telehealth practitioners (including out-of-region practitioners) must:

  • Act within their scope of practice;
  • Be licensed to provide telehealth services for which they bill DMAP in Delaware, or the State in which the provider is located if allowed under Delaware State law to provide telehealth services without a Delaware license through the Interstate Medical Licensure Compact or otherwise;
  • Be in good standing in all states in which provider is licensed;
  • Not be the subject of an administrative complaint or under investigation by another state’s licensing authority or board;
  • Be enrolled with DMAP; and • Have provider billing numbers (NPI and Taxonomy).

Distant telehealth practitioners may also need to enroll with the Department of Services for Children, Youth and their Families (DSCYF), Division of Prevention and Behavioral Health Services (DPBHS), and Division of Substance Abuse and Mental Health (DSAMH) as appropriate to provide and be reimbursed for behavioral health services.

The distant telehealth practitioner must be located within the continental United States. As required by §6505 of the Affordable Care Act, DMAP will not make any payments for items or services provided under the State Plan or under a waiver to any financial institution or entity located outside of the United States.

SOURCE: DE Medical Assistance Program. Practitioner Provider Specific Manual, 1/12/24. Ch. 16.2.6 & 16.3 pg. 74-75. (Accessed Apr. 2024).

The Distant site provider must be located within the continental US and enrolled in the DE Medicaid program or in a DE Medicaid Managed Care Organization to be reimbursed for services.

SOURCE: DE Adult Behavioral Health Service Certification and Reimbursement Provider Policy Manual (Dec. 14, 2016), p. 11.  (Accessed Apr. 2024).

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District of Columbia

Last updated 06/05/2024

Providers must be enrolled in the Program and licensed, by

Providers must be enrolled in the Program and licensed, by the applicable Board, to practice in the jurisdiction where services are rendered. For services rendered outside of the District, providers shall meet any licensure requirements of the jurisdiction where the patient is physically located. See Appendix A for illustrative examples.

SOURCE: Department of Health Care Finance. Telehealth Provider Guidance. Jan. 2023. p. 1-2. (Accessed Jun. 2024).

Providers must be enrolled in the Program and licensed, by the applicable Board, to practice in the jurisdiction where services are rendered. For services rendered outside of the District, providers shall meet any licensure requirements of the jurisdiction where he/she is physically located and the jurisdiction where the patient is physically located.

When the provider and patient receiving healthcare services are located in the District of Columbia, all individual practitioners shall be licensed in the state. For healthcare services rendered outside of the District, the provider of the services shall meet any licensure requirements of the jurisdiction in which the patient is physically located.

SOURCE: DC Municipal Regulation. Title 29, Ch. 9, Sec. 910.9. (Accessed Jun. 2024).

Providers whose practice address is located outside of the geographic boundaries of the District of Columbia are eligible to request consideration for participation in the DC Medicaid program if licensed in the state of the practice address.

SOURCE: Physicians Billing Manual.  DC Medicaid.  (Jan. 2024) Sec. 5.3.2 P. 17, Clinic Billing Manual, DC Medicaid (Sept. 2023), Sec. 5.3.2, P. 17. FQHC Billing Manual, DC Medicaid 5.3.2 P. 17. (Oct. 2023),  Outpatient Hospital Billing Guide, 5.3.2, p. 17 (Apr. 2024), Inpatient Hospital Billing Guide, 5.3.2, p. 18 (Apr. 2024), Long-Term Care Billing Manual, 5.3.2, p. 20 (Sept. 2023). (Accessed Jun. 2024).

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Florida

Last updated 06/11/2024

No Reference Found

No Reference Found

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Georgia

Last updated 05/23/2024

The Georgia Composite Medical Board is authorized to administer the …

The Georgia Composite Medical Board is authorized to administer the compact in this state. Under the compact, physicians must meet certain requirements, including: possess a full and unrestricted license to practice medicine in a Compact state; possess specialty certification or be in possession of a time unlimited specialty certificate; have no discipline on any state medical license; have no discipline related to controlled substance; not be under investigation by any licensing or law enforcement agency; have passed the USMLE or COMLEX within three attempts; and have successfully completed a graduate medical education (GME) program. License to practice medicine obtained through this compact will be issued by the State’s Medical Composite Board. Providers should see the Georgia Composite Medical Board for additional information.

SOURCE: GA Dept. of Community Health GA Medicaid Telehealth Guidance Handbook, p.71 (Apr. 1, 2024). (Accessed May 2024).

All enrolled providers, rendering services through the use of Telemedicine or Telehealth must possess the required credentials and be legally allowed to practice within the state of Georgia.  All enrolled providers must be credentialed by DCH’s Centralized Credentialing Verification Organization (CVO) or through a delegated credentialing arrangement with a Care Management Organization (CMO).

All individual practitioners must possess the appropriate Georgia license (this includes a Telemedicine License, Temporary License or Emergency Practice Permit), permit, certificate, approval, registration, or other form of permission issued by an entity other than the Department of Community Health (DCH), which form of permission is required by law.  All enrolled individual practitioners must act within the scope of his or her practice as defined by federal and state laws, rules, and regulations.

Telemedicine/Telehealth services shall be subject to utilization review and auditing requirements.

Providers must maintain documentation of all services provided through the use of Telemedicine/Telehealth in accordance with DCH policy.

SOURCE: GA Department of Community Health, Provider Messages (All Providers) Sept. 16, 2022. (Accessed May 2024).

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Hawaii

Last updated 06/03/2024

All providers prescribing controlled substances must be located in the …

All providers prescribing controlled substances must be located in the State of Hawai’i

SOURCE: Med-QUEST Memo QI-2338/FFS 23-22/CCS-2311.  (Accessed Jun. 2024).

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Idaho

Last updated 06/18/2024

No reference found.

No reference found.

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Illinois

Last updated 02/27/2024

For medical services, the provider rendering the service at the …

For medical services, the provider rendering the service at the distant site can be a physician, physician assistant, podiatrist or advanced practice nurse, who is licensed by the State of Illinois or by the state where the patient is located.

For psychiatric services, the provider rendering the service at the distant site must be a physician licensed by the State of Illinois, or by the state where the patient is located, who has completed an approved general psychiatry residency program or a child and adolescent psychiatry residency program.

SOURCE: IL Handbook for Practitioners Rendering Medical Services, Chapter 200, 220.5.7 p. 26, (June 2021); Handbook for Podiatric Services, Chapter F-200 Policy & Procedures, p. 28 (Oct. 2016), & Handbook for Encounter Clinic Services 210.2.2 pg. 17-18 (Aug. 2016). (Accessed Feb. 2024).

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Indiana

Last updated 03/19/2024

Out-of-state providers can perform telehealth services without fulfilling the out-of-state …

Out-of-state providers can perform telehealth services without fulfilling the out-of-state prior authorization requirement if they have the subtype “Telemedicine” attached to their enrollment.  See Module for requirements.

SOURCE:  Indiana Health Care Coverage Program, Provider Reference Module, Telehealth and Virtual Services (Nov. 1, 2023), p. 11.  (Accessed Mar 2024).

A provider that is licensed, certified, registered, or authorized with the appropriate state agency or board and exclusively offers telehealth services (as defined in IC 12-15-5-11(a)) to maintain a physical address or site in Indiana to be eligible for enrollment as a Medicaid provider.

A telehealth provider group with providers that are licensed, certified, registered, or authorized with the appropriate state agency or board to have an in-state service address to be eligible to enroll as a Medicaid vendor or Medicaid provider group.

SOURCE: IN Code 12-15-11-10 & ICHP Bulletin “IHCP to begin enrollment for telehealth-only providers” BT202417, (Feb. 15, 2024). (Accessed Mar. 2024).

Prior Authorization for Out-of-State Services

All out-of-state services rendered to IHCP members require prior authorization (PA), with the following exceptions: …

  • Telemedicine services if providers have the subtype “telemedicine” attached to their enrollment – See the Telemedicine and Telehealth Services module for more information (IHCP has marked the Telemedicine and Telehealth Services module “obsolete.”)

SOURCE: IN Medicaid Out-of-State Providers Module (Sept. 27, 2022) p. 1, (Accessed Mar. 2024).

Subject to federal law, the office may not impose any location requirements concerning the originating site or distant site in which a telehealth service is provided to a Medicaid recipient.

SOURCE: IN Code 12-15-5-11(d) (Accessed Mar. 2024)

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Iowa

Last updated 04/22/2024

No Reference Found

No Reference Found

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Kansas

Last updated 03/04/2024

No reference found. See Cross-State Licensing Section under Professional Requirements.…

No reference found. See Cross-State Licensing Section under Professional Requirements.

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Kentucky

Last updated 03/18/2024

Notwithstanding any provision of law to the contrary, neither the …

Notwithstanding any provision of law to the contrary, neither the Department for Medicaid Services nor a Medicaid managed care organization with whom the department has contracted for the delivery of Medicaid services shall require that a health professional, as defined in KRS 205.510, or medical group maintain a physical location or address in this state to be eligible for enrollment as a Medicaid provider if the provider or group exclusively offers services via telehealth as defined in KRS 211.332.

KY Medicaid program shall require a telehealth provider to be licensed in Kentucky, or as allowed under the standards and provisions of a recognized interstate compact, in order to receive reimbursement for telehealth services.

SOURCE: KY Statute Sec. 205.5591. (Accessed Mar. 2024).

A telehealth service shall not be reimbursed by the department if: … The telehealth care provider of the telehealth service: … not physically located within the United States or a United States territory at the time of service.

Telehealth Provided by an Out-of-State Telehealth Care Provider.

  • The department shall evaluate and monitor the healthcare quality and outcomes for recipients who are receiving healthcare services from out-of-state telehealth care providers.
  • The department shall implement any in-state or out-of-state participation restrictions established by a state licensing board for the impacted provider.

SOURCE: 907 KAR 003:170. (Accessed Mar. 2024).

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Louisiana

Last updated 06/04/2024

No reference found.

No reference found.

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Maine

Last updated 05/20/2024

Health Care Provider: Individual or entity licensed or certified to …

Health Care Provider: Individual or entity licensed or certified to provide medical, behavioral health, and related services to MaineCare Members. Health Care Providers must be enrolled as MaineCare Providers to receive reimbursement for services.

SOURCE: MaineCare Benefits Manual, Telehealth, 10-144 Ch. 101, Ch. 1, Sec. 4. (Nov. 6, 2023)Adopted 10-144 C.M.R. Chapter 101, Chapter I, Section 4, Telehealth Services. (Nov. 6, 2023).  (Accessed May 2024).

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Maryland

Last updated 05/24/2024

Licensure requirements, including for telehealth practice, are determined by the

Licensure requirements, including for telehealth practice, are determined by the state’s health care professional licensing boards. Maryland Medicaid does not further restrict telehealth practice or reimbursement beyond rules determined by the Health Occupations Code, and professional licensing board regulations.

For all scope of practice questions, including whether telehealth visits are permitted when a patient is outside the state where the practitioner is physically located, practitioners should contact their licensing board or credentialing authority to determine if rendering services via telehealth is a permitted modality of care and what limitations on telehealth may exist. Note that it may be necessary to consult the relevant licensing board of the foreign state.

Providers who are licensed, certified, or otherwise authorized and who are enrolled in Maryland Medicaid may provide services via telehealth as long as telehealth is a permitted delivery model within the rendering provider’s scope of practice. Providers should consult their licensing board prior to rendering services via telehealth.

A distant site may be any location where a licensed, certified, or otherwise authorized provider is located when rendering a service using technology-assisted communication.

SOURCE: MD Medicaid Synchronous Telehealth Policy Guide, p. 5-7. Updated Aug. 2023. (Accessed May 2024).

To receive reimbursement for services delivered via telehealth, a provider shall:

  • Be actively enrolled with Maryland Medical Assistance on the date the service is rendered; and
  • Comply with payment procedures as set forth in COMAR 10.09.36.

Distant Site Reimbursement.

  • The distant site provider shall be reimbursed as set forth in the COMAR chapter defining the covered service being rendered.
  • Services delivered via telehealth shall be billed with the telehealth GT modifier.
  • Services delivered via telehealth shall be within the provider’s scope of practice as determined by its governing licensure or credentialing board.

SOURCE: Code of Maryland Admin. Regs. Sec. 10.09.49.08. (Accessed May 2024).

“Health care provider” means a person who is licensed, certified, or otherwise authorized under the Health Occupations Article to provide health care in the ordinary course of business or practice of a profession or in an approved education or training program.

SOURCE: MD Health General Code Sec. 15-141.2(a)(4)(i). (Accessed May 2024).

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Massachusetts

Last updated 04/15/2024

No Reference Found

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Michigan

Last updated 04/29/2024

In compliance with the Michigan Insurance Code of 1956 (Act …

In compliance with the Michigan Insurance Code of 1956 (Act 218 of 1956), telemedicine services must be provided by a provider who is licensed, registered, or otherwise authorized to engage in his or her health care profession in the state where the beneficiary is located. The provider at the distant site who is licensed under State law to furnish a covered telemedicine service (as described in the Allowable Services subsection) may bill, and receive payment for, the service when it is delivered via a telecommunications system.

SOURCE: Dept. of Health and Human Services, Medicaid Provider Manual, p. 2118,  Apr. 1, 2024 (Accessed Apr. 2024).

Michigan Medicaid telemedicine policy permits providers who are licensed in another state to render/be reimbursed for telemedicine services for Michigan Medicaid-enrolled beneficiaries if the beneficiary is in the state where the provider is licensed.

Unless otherwise specified in policy, telemedicine providers associated to a billing provider located outside of Michigan must obtain prior authorization (PA) for services. Providers should refer to the Out-of-State/Beyond Borderland Providers subsection in the General Information for Providers chapter of the MDHHS Medicaid Provider Manual for situations where PA could be approved.

See below (Psychology Interjurisdictional Compact [PSYPACT]) for specific situations where an out-of-state licensed provider is otherwise authorized to render/be reimbursed for telemedicine services.

Telemedicine providers who do not have a physical location for treatment, but are Michigan licensed and meet all other Medicaid enrollment requirements, are considered “virtual-only”, and are permitted to render services for Michigan Medicaid-enrolled beneficiaries.

Virtual-only providers not associated to a Michigan billing provider within the Community Health Automated Medicaid Processing System (CHAMPS) will be subject to out-of-state provider PA requirements. Providers should refer to the Out-of-State/Beyond Borderland Providers subsection in the General Information for Providers chapter of the MDHHS Medicaid Provider Manual for situations where PA could be approved.

Virtual-only providers must report Place of Service (POS) 02 or 10 along with the appropriate modifier when submitting claims/encounters for telemedicine.

Telemedicine providers who have an Authority to Practice Interjurisdictional Telepsychology (APIT) certificate from the PSYPACT Commission are eligible to render/be reimbursed for telemedicine services for Medicaid beneficiaries as authorized under PSYPACT and allowed by Medicaid telemedicine policy.

PSYPACT providers must abide by the same telemedicine requirements as all other telemedicine providers. Services performed by PSYPACT providers are subject to PA requirements that would apply if the provider were located in-state. Providers should refer to the CHAMPS Code Rate and Reference tool for service-specific in-state authorization requirements.

PSYPACT providers must report POS 02 or 10 along with the appropriate modifier when submitting claims/encounters via telemedicine.

SOURCE: MI Medicaid Policy Bulletin MMP 24-06, Apr. 1, 2024, (Accessed Apr. 2024).

Asynchronous Interprofessional Consultations

In consultations that cross state lines, consulting providers must be an enrolled Medicaid provider in the state in which the beneficiary resides, though they need only be licensed/credentialed in the state in which they are practicing. Interprofessional consultations that occur across state lines require prior authorization. Refer to the MDHHS Medicaid Provider Manual for further information regarding out-of-state/beyond borderland providers and the prior authorization process.

SOURCE:  MI Dept. of Health and Human Services., Bulletin 23-60, Asynchronous Telemedicine: Interprofessional Telephone / Internet / Electronic Health Record Consultations (eConsults), Updated Requirements, Nov. 1, 2023, & MI Dept. of Health and Human Services, Medicaid Provider Manual, p. 2123-2124, Apr. 1, 2024 (Accessed Apr. 2024).

Behavioral Health

Behavioral health services may be delivered via telemedicine in accordance with current Medicaid policy. In compliance with the Michigan Insurance Code of 1956 (Act 218 of 1956), telemedicine services must be provided by a health care professional who is licensed, registered, or otherwise authorized to engage in his or her health care profession in the state where the patient is located.

SOURCE: Dept. of Health and Human Services, Medicaid Provider Manual, p. 548, Apr. 1, 2024 (Accessed Apr. 2024).

Assertive Community Treatment Programs (ACT)

Typically, although not exclusively, physician activities may include team meetings, beneficiary appointments during regular office hours, psychiatric evaluations, psychiatric meetings/consultations, medication reviews, home visits, telephone consultations and telemedicine.

The physician (MD or DO) must possess a valid license to practice medicine in Michigan, a Michigan Controlled Substance License, and a Drug Enforcement Administration (DEA) registration.

SOURCE: Dept. of Health and Human Services, Medicaid Provider Manual, p. 368, Apr. 1, 2024 (Accessed Apr. 2024).

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Minnesota

Last updated 06/24/2024

Out-of-state coverage policy applies to services provided via telehealth.

See …

Out-of-state coverage policy applies to services provided via telehealth.

See out-of-state providers section of manual.

SOURCE: MN Dept. of Human Services, Provider Manual, Physician and Professional Services (Telehealth), As revised Apr. 4, 2024, MN Dept of Human Services, Provider Manual, Provider Basics: Out-of-State Providers.  Revised 5/19/21  &MN Dept. of Human Svcs, Provider Manual Rehabilitation Services Jan. 25, 2022.  (Accessed Jun. 2024).

1115 Substance Use Disorder System Reform Demonstration

A provider seeking to enroll in the 1115 SUD Reform Demonstration must be enrolled as an MHCP provider for Substance Use Disorder (SUD) Services. To enroll, providers must submit the forms listed under the 1115 SUD System Reform Demonstration heading on the Substance Use Disorder (SUD) Services Enrollment Criteria and Forms provider enrollment webpage. Providers must meet the requirements listed on these forms and submit the forms to DHS to be eligible to provide, bill and be paid by MHCP for SUD services within the 1115 SUD System Reform Demonstration.

Eligible providers may include the following:

  • Licensed residential SUD treatment programs
  • Licensed nonresidential (outpatient) SUD treatment programs
  • Tribes
  • Licensed withdrawal management programs
  • Approved out-of-state SUD providers

SOURCE: MN Dept of Health Svcs Provider Manual Substance Use Disorder (SUD) Services Jun. 17, 2024.  (Accessed Jun. 2024).

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Mississippi

Last updated 04/05/2024

Providers of telehealth services must be an enrolled Mississippi Medicaid

Providers of telehealth services must be an enrolled Mississippi Medicaid provider acting within their scope-of-practice and license or medical certification or Mississippi Department of Health (MDSH) certification and in accordance with state and federal guidelines, including but not limited to, authorization of prescription medications at both the originating and distant site.

For teleradiology, a consulting and referring provider is a licensed physician (or PA or NP for referring providers) who must be licensed in the state within the United States in which he/she practices.

SOURCE: MS Admin. Code 23, Part 225, Rule 3.1. (Accessed Apr. 2024).

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Missouri

Last updated 05/01/2024

The provision prohibits MHD from making any payments for items …

The provision prohibits MHD from making any payments for items or services provided under the State Plan or under a waiver to any financial institutions, telemedicine providers, pharmacies, or other entities located outside of the United States, Puerto Rico, the Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa. If it is discovered that payments have been made to financial institutions or entities outside of the previously stated approved regions, MHD must recover these payments.

SOURCE: MO HealthNet, Provider Manual, General Sections Manual, p. 35 (9/1/23), (Accessed May 2024).

In order to treat participants in this state through the use of telemedicine, health care providers shall be fully licensed to practice in this state and shall be subject to regulation by their respective professional boards. In addition, psychologists licensed in a Psychology Interjurisdictional Compact (PSYPACT) state may render telemedicine services under the Authority to Practice Interjurisdictional Telepsychology, according to the requirements in the PSYPACT.

A health care provider utilizing telemedicine at either a distant site or an originating site shall be enrolled as a MO HealthNet provider pursuant to 13 CSR 65-2.020 and be fully licensed for practice in the state of Missouri. A health care provider utilizing telemedicine must do so in a manner that is consistent with the provisions of all laws governing the practice of the provider’s profession and shall be held to the same standard of care as a provider employing in-person behavioral health or medical health care.

SOURCE: MO Code of State Regulations, Title 13 Sec. 70-3.330(2)(B) & (C), (Accessed May 2024).

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Montana

Last updated 06/03/2024

Any out of state distance providers must be licensed in …

Any out of state distance providers must be licensed in the State of Montana and enrolled in Montana Healthcare Programs in order to provide telemedicine services to Montana Healthcare Programs members. Providers must contact the Montana Department of Labor and Industry to find out details on licensing requirements for their applicable professional licensure.

SOURCE: MT Dept. of Public Health and Human Svcs., Medicaid and Medical Assistance Programs Manual, General Information for Providers, Telemedicine (Feb. 2020). (Accessed Jun. 2024).

Licensing Requirements for Out-of-State Mental Health Practitioners Practicing Via Telehealth in Montana

A recent Medicaid provider notice reminds enrolling and revalidating out-of-state mental health practitioners of the Montana Department of Labor and Industry Board of Behavioral Health’s licensing requirements for providing mental health services via telehealth to clients located in Montana. The Medicaid notice cites the Montana Board of Behavioral Health:

  • Telehealth/telepractice is a method of delivery of services and not a specific type of license or practice. To practice under the scope of the professions licensed under this board you must be licensed in the state of Montana (e.g., where the services are occurring). Note that laws concerning telepractice/telehealth vary from jurisdiction to jurisdiction so you should also check with the regulatory entity in the jurisdiction where you are licensed with regard to its laws. For more information on mental health practitioner licensing, please visit the Montana Department of Labor and Industry Board of Behavioral Health’s website, Board of Behavioral Health (mt.gov).

SOURCE: MT Dept. of Public Health and Human Svcs., Medicaid Provider Notice (Mar. 6 2024). (Accessed Jun. 2024).

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Nebraska

Last updated 04/10/2024

The location of the telehealth service is the physical location …

The location of the telehealth service is the physical location of the member. Out-of-state telehealth services are covered if the telehealth services otherwise meet not only the telehealth requirements but also the requirements for payment for services provided outside Nebraska.

SOURCE: NE Medicaid Program, Bulletin 23-38:  Guidance on Telehealth, Dec. 29, 2023, (Accessed Apr. 2024).

Payment in fee-for-service and Managed Care may be approved for services provided outside Nebraska in the following situations:

  • When an emergency arises from accident or sudden illness while a client is visiting in another state and the client’s health would be endangered if medical care is postponed until the client returns to Nebraska;
  • When a client customarily obtains a medically necessary service in another state because the service is more accessible; and
  • When the client requires a medically necessary service that is not available in Nebraska.

Prior authorization is required for out-of-state services.  See regulation for procedures.

Out-of-State telehealth services are covered if the telehealth services otherwise meet the regulatory requirements for payment for services provided outside Nebraska and:

  • When the distant site is located in another state and the originating site is located in Nebraska; or
  • When the Nebraska client is located at an originating site in another state, whether or not the provider’s distant site is located in or out of Nebraska.

SOURCE: NE Admin. Code Title 471, Ch. 1,  Sec. 1-002.02(E) & 1-004.11, (Accessed Apr. 2024).

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Nevada

Last updated 03/26/2024

No Reference Found

No Reference Found

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New Hampshire

Last updated 03/29/2024

No Reference Found

No Reference Found

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New Jersey

Last updated 05/09/2024

The patient and/or the provider may be at any location …

The patient and/or the provider may be at any location as long as the provider is licensed to practice in New Jersey.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter. Vol. 28, No. 17, Sept. 2018. (Accessed May 2024).

A psychiatrist or psychiatric APN may be off-site, but must be licensed in the State of New Jersey.

SOURCE: NJ Division of Medical Assistance and Health Services. Newsletter. Vol. 23, No. 21, December 2013. (Accessed May 2024).

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New Mexico

Last updated 06/17/2024

For telemedicine services, when the originating-site is in New Mexico …

For telemedicine services, when the originating-site is in New Mexico and the distant-site is outside New Mexico, the provider at the distant-site must be licensed for telemedicine to the extent required by New Mexico state law and regulations or meet federal requirements for providing services to IHS facilities or tribal contract facilities. Provision of telemedicine services does not require that a certified medicaid healthcare provider be physically present with the MAP eligible recipient at the originating site unless the telemedicine consultant at the distant site deems it necessary.

SOURCE: NM Administrative Code 8.310.2.12 (M). (Accessed Jun. 2024).

For telemedicine services, when the originating-site is in New Mexico and the distant-site is outside New Mexico, the provider at the distant-site must be licensed for telemedicine to the extent required by New Mexico state law and NMAC rules or meet federal requirements for providing services to IHS facilities or tribal contract facilities.

SOURCE: NM Administrative Code 8.310.3.9 (F). (Accessed Jun. 2024).

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New York

Last updated 06/03/2024

“Distant site” means a site at which a telehealth provider …

“Distant site” means a site at which a telehealth provider is located while delivering health care services by means of telehealth. Any site within the United States or United States’ territories is eligible to be a distant site for delivery and payment purposes.

SOURCE: NY Public Health Law Article 29 – G Section 2999-cc, (Accessed Jun. 2024).

Any secure site within the fifty United States (U.S.) or U.S. territories is eligible to be a distant site for delivery and payment purposes. Providers located outside of New York State may provide telehealth services to New York Medicaid members if:

  1. the services are allowable,
  2. the provider is enrolled in New York State Medicaid, and
  3. the provider possesses New York State licensure.

Out of state licensing is under the authority of The New York State Education Department, Office of the Professions.

Out of state providers should also consult the proper authorities in the state from which they are providing services for its requirements.

Telemental Health

Part 596 of Title 14 NYCRR permits the provision of Telehealth Services by the New York State (NYS) Office of Mental Health (OMH) programs licensed or designated pursuant to Article 31 of the NYS Mental Hygiene Law, if approved to do so by OMH. Approval shall be based upon review of policies and procedures that satisfactorily address a series of standards and procedures. For example, the policies and procedures must confirm that:

  • Telehealth Practitioners meet standards established in Part 596.6(a)(1)(i), including that they possess a current, valid license, permit, or limited permit to practice in New York State, or are designated or approved by the Office to provide services.

SOURCE: New York State Office of Mental Health, Telehealth Services Guidance for OMH Providers (Apr. 2023) p. 45. (Accessed Jun. 2024).

The recipient can be physically located at a provider site licensed by the office, or the recipient’s place of residence, other identified location, or other temporary location out-of-state.

Telehealth practitioners may deliver services from a site located within the United States or its territories, which may include the practitioner’s place of residence, office, or other identified space approved by the Office and in accordance with Office guidelines.

SOURCE: NY Code of Rules and Regs.  Title 14, Sec. 596.4(b)(e), Sec. 596.5(a), & Sec. 596.6(a) as proposed to be amended by Final Rule and Notice Of Adoption. (Accessed Jun. 2024).

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North Carolina

Last updated 03/17/2024

No Reference Found

No Reference Found

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North Dakota

Last updated 06/10/2024

Telehealth services provided to members while they are located in …

Telehealth services provided to members while they are located in the State of North Dakota by ND Medicaid-enrolled out of state telehealth providers are not considered out of state care. The requirement to request authorization for out of state services does not apply in these situations. If the service itself requires service authorization the provider is still required to obtain authorization prior to rendering the service.

SOURCE: ND Medicaid, Out of State Services, Jan. 2024, (Accessed Jun. 2024).

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Ohio

Last updated 06/05/2024

Mental Health Services Provided by Agencies

Provider must have a …

Mental Health Services Provided by Agencies

Provider must have a physical location in Ohio or have access to a physical location in Ohio where individuals may opt to receive in person services rather than telehealth services.

SOURCE: OAC 5122-29-31. (Accessed Jun. 2024).

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Oklahoma

Last updated 03/06/2024

Out-of-state providers must comply with all laws and regulations of …

Out-of-state providers must comply with all laws and regulations of the provider’s location, including health care and telehealth requirements.

SOURCE: Health Care Authority, Providers, Telehealth, Modified Jul. 2, 2023. (Accessed Mar. 2024).

The provider must be contracted with SoonerCare and appropriately licensed or certified, in good standing.  Services that are provided must be within the scope of the practitioner’s license or certification. If the provider is outside of Oklahoma, the provider must comply with all laws and regulations of the provider’s location, including health care and telehealth requirements.

Providers and/or members may provide or receive telehealth services outside of Oklahoma when medically necessary; however, prior authorization may be required.

SOURCE: OK Admin. Code Sec. 317:30-3-27. (Accessed Mar. 2024).

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Oregon

Last updated 03/30/2024

A provider located in a state other than Oregon whose …

A provider located in a state other than Oregon whose services are rendered in that state shall be licensed and otherwise certified by the proper agencies in the state of residence as qualified to render the services. Certain cities within 75 miles of the Oregon border may be closer for Oregon residents than major cities in Oregon, and therefore, these areas are considered contiguous areas, and providers are treated as providing in-state services.  See rule for additional requirements.

Reimbursement and services outside the territorial limits of the United states:

  • For purposes of this provision, the United States includes the District of Columbia, Puerto Rico, the Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa;
  • The division may not provide any payments for items or services to any financial institution or entity located outside of the United States pursuant to 1902(a)(80) of the Social Security Act.

This provision also prohibits payments to telemedicine providers and pharmacies located outside of the United States.

SOURCE: OAR 410-120-1180, (Accessed Mar. 2024).

The Authority may expand network capacity through remote care and telemedicine, or telehealth services provided across state lines.

SOURCE: OR OAR 410-120-1990 (Accessed Mar. 2024).

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Pennsylvania

Last updated 05/07/2024

Out-of-state licensed practitioners who provide treatment through telehealth to individuals

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 May 2024).

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 May 2024.

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 May 2024).

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

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Puerto Rico

Last updated 03/22/2024

Certification to practice in Puerto Rico required.

SOURCE: Law No.

Certification to practice in Puerto Rico required.

SOURCE: Law No. 68 of 2020 For the Use of Telemedicine in Puerto Rico.   Regulation 9107 of August 20, 2019 Telemedicine Use in Puerto Rico (original law). (Accessed Mar. 2024).

 

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Rhode Island

Last updated 05/15/2024

No Reference Found

No Reference Found

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South Carolina

Last updated 05/07/2024

The health professional providing the medical care must be currently …

The health professional providing the medical care must be currently and appropriately licensed in South Carolina.

SOURCE: SC Health and Human Svcs. Dept. Physicians Provider Manual, p. 32-33 (Apr. 2024). (Accessed May 2024).

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South Dakota

Last updated 04/02/2024

The out-of-state prior authorization requirement does not apply to telemedicine …

The out-of-state prior authorization requirement does not apply to telemedicine services if the recipient is located in South Dakota at the time of the service and the provider is located outside of the State. If the service otherwise requires a prior authorization, the provider is still required to obtain prior authorization prior to providing the service.

Distant sites located outside of the United States are not covered.

An originating site is located in South Dakota, but the distant site is an enrolled provider located out-of-state, does the distant site provider need an out of state prior authorization?  No, the distant site provide does not need an out-of-state prior authorization for services delivered via telemedicine. If the service otherwise requires a prior authorization, the provider is still required to obtain prior authorization prior to providing the service.

SOURCE: SD Medicaid Billing and Policy Manual: Telemedicine, (Feb. 2024) & Out-of-State Providers [first paragraph], Jan. 2024, p. 5, (Accessed Apr. 2024).

Indian Health Service (IHS) Servicing Providers Licensure and Referrals

Per 42 CFR 431.110, servicing providers who practice at an Indian Health Service (IHS) facility may do so with a South Dakota license or an equivalent license from another state as long as the individual otherwise meets South Dakota Medicaid’s provider eligibility requirements.

Referrals made to non-IHS providers by IHS physicians and other licensed practitioners who are solely licensed out-of-state are considered valid referrals under federal regulation. Non-IHS providers should accept referrals by IHS providers on the same basis as they accept referrals from non-IHS providers.

Certain exceptions apply for Indian Health Service providers. See Medicaid Out of State section for details.

SOURCE: SD Department of Social Services, Indian Health Service (IHS) Servicing Providers Licensure and Referrals, May 25, 2022, (Accessed Apr. 2024).

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Tennessee

Last updated 05/03/2024

“Healthcare provider” means a person who is licensed, certified, or …

“Healthcare provider” means a person who is licensed, certified, or authorized or permitted by the laws of this state to administer health care in the ordinary course of business or practice of a profession; and

“Telehealth provider group” means two (2) or more healthcare providers that share a common employer and provide healthcare services exclusively via telehealth.

This chapter does not require:

  • A vendor or healthcare provider who provides healthcare services exclusively via telehealth to maintain a physical address or site in this state in order to be eligible to enroll as a vendor or provider for the medical assistance program; or
  • A telehealth provider group to have a service address in this state in order to be eligible to enroll as a vendor or provider group for the medical assistance program, as long as the healthcare providers that comprise the telehealth provider group are licensed with the appropriate healthcare licensing authority in this state or are otherwise authorized by law to provide healthcare services in this state.

SOURCE: TN Code Annotated, Sec. 71-5-167, (Accessed May 2024).

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Texas

Last updated 04/25/2024

Distant site providers must be licensed in Texas.

An out-of-state …

Distant site providers must be licensed in Texas.

An out-of-state physician who is a distant site provider may provide episodic telemedicine without a Texas medical license as outlined in Texas Occupations Code §151.056 and Title 22 Texas Administrative Code (TAC) §172.2(g)(4) and 172.12(f).

Distant site providers that provide mental health services must be appropriately licensed or certified in Texas, or be a qualified mental health professional-community services (QMHP-CS), as defined in 26 TAC §301.303(48).

Distant site providers that provide mental health services must be appropriately licensed or certified in Texas or be a QMHP-CS as defined in 26 Texas Administrative Code §301.303(48).

A distant-site provider that is located outside of state lines while rendering services is considered an out-of-state provider.

SOURCE: TX Medicaid Telecommunication Services Handbook, pg. 8, 12 (Apr. 2024). (Accessed Apr. 2024).

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Utah

Last updated 06/25/2024

A non-resident provider may report telehealth services given to an …

A non-resident provider may report telehealth services given to an in-state Medicaid member when the following conditions are met:

  • The provider meets the licensing requirements of the Department of Professional Licensing (DOPL) as outlined in Utah Annotated Code 58-1-302.1
  • The provider is enrolled as a Utah Medicaid provider as explained in Chapter 3 Provider Participation and Requirements
  • Follow the policies outlined in Chapter 8-4.2 Telehealth.

SOURCE: Utah Medicaid Provider Manual: Section I: General Information (May 2024). (Accessed Jun. 2024).

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Vermont

Last updated 07/02/2024

If you hold an active out-of-state license which is in …

If you hold an active out-of-state license which is in good standing in a healthcare profession, you may practice in Vermont under certain circumstances. Visit the Office of Professional Regulation (OPR) for Updates to Telehealth Registrations and Licensing.

SOURCE: Department of Vermont Health Access. Agency of Human Services. Telehealth: Methods for healthcare service delivery using telecommunications technologies. (Accessed Jul. 2024).

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Virgin Islands

Last updated 03/25/2024

No reference found.

No reference found.

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Virginia

Last updated 04/22/2024

The purpose of this bulletin is to notify all providers …

The purpose of this bulletin is to notify all providers that, pursuant to Virginia Acts of Assembly 2023, Chapter 112 (HB 1602, SB 1418), 1) licensed health care providers who provide health care services exclusively through telemedicine are not required to maintain a physical presence in the Commonwealth to be considered an eligible provider for enrollment as a Medicaid provider and 2) telemedicine services provider groups with licensed health care providers are not required to have an in-state service address to be eligible to enroll as a Medicaid vendor or Medicaid provider group. Providers wishing to enroll can access DMAS’s online provider enrollment process through the Provider Enrollment link located on the DMAS Medicaid Enterprise System (MES) Provider Resources site at https://vamedicaid.dmas.virginia.gov/provider.

In-state telemedicine providers will continue to need to meet the Virginia Department of Health Profession’s (DHP’s) licensing requirement and out-of-state telemedicine providers need to continue to meet DHP’s licensing requirements in addition to their state licensing requirements to provide telemedicine services to Virginia Medicaid members.

SOURCE:  Medicaid Bulletin:  No requirement for exclusive telemedicine providers to maintain a physical presence in Virginia/in-state address. April 20, 2023, (Accessed Apr. 2024).

For the purposes of this subdivision, a health care provider duly licensed by the Commonwealth who provides health care services exclusively through telemedicine services shall not be required to maintain a physical presence in the Commonwealth to be considered an eligible provider for enrollment as a Medicaid provider.

For the purposes of this subdivision, a telemedicine services provider group with health care providers duly licensed by the Commonwealth shall not be required to have an in-state service address to be eligible to enroll as a Medicaid vendor or Medicaid provider group.

SOURCE: Code of Virginia Sec. 32.1-325 (Accessed Apr. 2024).

Providers must maintain a practice at a physical location in the Commonwealth or be able to make appropriate referral of patients to a Provider located in the Commonwealth in order to ensure an in-person examination of the patient when required by the standard of care.

Providers must meet state licensure, registration or certification requirements per their regulatory board with the Virginia Department of Health Professions to provide services to Virginia residents via telemedicine. Providers shall contact DMAS Provider Enrollment (888-829-5373) or the Medicaid MCOs for more information.

SOURCE:  VA Dept. of Medical Assistant Svcs., Medicaid Provider Manual Supplement-Telehealth Services, (1/10/24) (Accessed Apr. 2024).

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Washington

Last updated 06/19/2024

You must be licensed according to Washington State law to …

You must be licensed according to Washington State law to bill for telemedicine or telehealth services. Service(s) must be rendered consistent with the scope of professional licensure or certification. See the Washington State Department of Health website for further information and details related to each option. This rule does not pertain to providers in a Direct IHS Clinic, Tribal Clinic, or Tribal FQHC as those providers may be licensed in any state per federal law. If the Washington Apple Health (Medicaid) client is receiving services outside of Washington State by a Washington State provider, the provider must follow the applicable laws of the state in which the client is located.

SOURCE: WA State Health Care Authority Behavioral Health Policy and Billing FAQ (Oct. 2023). (Accessed Jun. 2024).

A distant site must be located within the continental United States, Hawaii, District of Columbia, or any United States territory (e.g., Puerto Rico). A distant site is where a physician or other licensed provider, delivering a professional service, is physically located at the time the service is provided through telemedicine.

SOURCE: WA State Health Care Authority Telemedicine Policy and Billing Manual (Jun. 2024), p. 17-18. (Accessed Jun. 2024).

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West Virginia

Last updated 05/17/2024

All interstate telehealth practitioners must be registered with the appropriate …

All interstate telehealth practitioners must be registered with the appropriate board in West Virginia.

Interstate: The provision of telehealth services to a patient located in West Virginia by a healthcare practitioner located in any other state or commonwealth of the United States. The practitioner must be licensed and in good standing in the state they reside and not currently under investigation or subject to an administrative complaint. The provider must register as an interstate telehealth practitioner with the appropriate board in West Virginia and will be subject to the laws and requirements set forth by the registering board. The practitioner must also enroll with the current Medicaid fiscal agent(s) as an Interstate Provider. A practitioner currently licensed to practice in West Virginia is not subject to registration.

SOURCE: WV Dept. of Health and Human Svcs. Medicaid Provider Manual, Chapter–519.17.2 Practitioner Services: Telehealth Services. p. 3, 5 (Effective Jan. 1, 2022). (Accessed May 2024).

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Wisconsin

Last updated 01/09/2024

The department may not require a health care provider that …

The department may not require a health care provider that is licensed, certified, registered, or otherwise authorized to provide health care services in this state and that exclusively offers health care services in this state through telehealth to maintain a physical address or site in this state to be eligible for enrollment as a certified provider under the Medical Assistance program.

The department may not require a provider group with health care providers that are licensed, certified, registered, or otherwise authorized to provide health care services in this state and that exclusively offer health care services in this state through telehealth to maintain a physical address or site in this state to be eligible for enrollment as a provider group under the Medical Assistance program.

SOURCE: WI Statute, Sec. 49.45 (61m), & SB 476 (2023 Session), (Accessed Apr. 2024).

ForwardHealth policy for services provided via telehealth by out-of-state providers is the same as ForwardHealth policy for services provided face to face by out-of-state providers.

Out-of-state providers who meet the definition of a border-status provider as described in Wis. Admin. Code § DHS 101.03(19) and who provide services to Wisconsin Medicaid members only via telehealth, may apply for enrollment as Wisconsin telehealth-only border-status providers if they are licensed in Wisconsin under applicable Wisconsin statute and administrative code.

Out-of-state providers who do not have border status enrollment with Wisconsin Medicaid are required to obtain PA before providing services via telehealth to BadgerCare Plus or Medicaid members.

Note: Wisconsin Medicaid is prohibited from paying providers located outside of the United States and its territories, including the District of Columbia, Puerto Rico, the Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa.

SOURCE: WI ForwardHealth Online Handbook. Topic #510 Telehealth. (Accessed Apr. 2024).

Beginning June 1, 2023, a new telehealth-only border-status option will allow out-of-state providers located in a state that does not physically border Wisconsin to enroll in Medicaid as a telehealth-only border-status provider.

These out-of-state providers will enroll through the border-status process but will select the newly added “telehealth” option as their county. This option will distinguish these providers from regular border-status providers that may potentially also deliver in-person services to members in addition to telehealth delivery. This option is only available for providers located in the United States that:

  • Provide services solely through telehealth.
  • Are located in states that do not physically border Wisconsin.

In-state providers located in Wisconsin that provide services solely through telehealth should enroll in Medicaid as an in-state provider, and border-status providers located in a state that physically borders Wisconsin should enroll in Medicaid as a border-status provider.

Refer to the Attachment to this ForwardHealth Update for additional guidance on which enrollment process is most appropriate to provide telehealth-only services based on the provider’s location and status.

Note: Wisconsin Medicaid is prohibited from paying providers located outside of the United States and its territories (Puerto Rico, the Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa).

Definition of Telehealth-Only Border-Status Provider

Out-of-state providers who meet the definition of a border-status provider as described in Wis. Admin. Code § DHS 101.03(19) and who provide services to Wisconsin Medicaid members via telehealth, regardless of provider location, may apply for enrollment as a telehealth-only border-status provider if they are licensed in Wisconsin under applicable statute and administrative code and are professionally licensed/certified to provide services as defined by the Wisconsin Department of Safety and Professional Services.

Enrolled border-status providers are subject to the same program requirements as in-state providers, including coverage of services, prior authorization (PA), and claim submission procedures. Out-of-state providers that do not enroll as telehealth-only border-status providers are required to obtain PA from ForwardHealth before providing a non-emergency service.

See bulletin for more on providers eligible to enroll and providers not eligible to enroll, as well as the process to become a telehealth-only border-status provider.

During the enrollment process, telehealth-only border-status providers must attest to understanding the limitations on the services they are delivering to members in Wisconsin and following all applicable policies, state and federal rules, regulations, and licensure requirements applicable to claims submitted to Wisconsin Medicaid. Providers must also acknowledge that, as a telehealth-only border-status provider, they may only submit claims for reimbursable services delivered through telehealth; any in-person services are subject to out-of-state provider requirements including PA for services.

Program limitations and requirements for telehealth-only border-status providers include the following:

  • Border-status providers who are located in states that do not border Wisconsin may only deliver services via telehealth unless they have PA. Regular border-status providers (those that physically border Wisconsin – Illinois, Iowa, Michigan, and Minnesota) may deliver services via telehealth and in-person.
  • Telehealth-only border-status providers must open a Portal account upon enrollment to conduct business via the Portal including submission of PA requests as necessary.
  • Telehealth-only border-status providers are required to follow all applicable federal and state laws, policies, and regulations, including any related requirements from the state from which they are practicing when delivering services.

SOURCE: Wisconsin ForwardHealth Bulletin No. 2023-20, June 2023, (Accessed Apr. 2024).

When a provider in a state that borders on Wisconsin documents to the department’s satisfaction that it is common practice for recipients in a particular area of Wisconsin to go for medical services to the provider’s locality in the neighboring state, the provider may be certified as a Wisconsin border status provider, subject to the certification requirements in this chapter and the same rules and contractual agreements that apply to Wisconsin providers, except that nursing homes are not eligible for border status.

Out-of-state independent laboratories, regardless of location, may apply for certification as Wisconsin border status providers.

Out-of-state providers who meet the definition of a border-status provider as described in s. DHS 101.03 (19) and who provide services to Wisconsin members via telehealth, regardless of provider location, may apply for certification as Wisconsin border-status providers if they are licensed in Wisconsin under applicable Wisconsin statute and administrative code.

Other out-of-state providers who do not meet the requirements of sub. (1) may be reimbursed for non-emergency services provided to a Wisconsin MA recipient upon approval by the department under s. DHS 107.04.

The department may review border status certification of a provider annually. Border status certification may be canceled by the department if it is found to be no longer warranted by medical necessity, volume or other considerations.

A provider certified in another state for services not covered in Wisconsin shall be denied border status certification for these services in the Wisconsin program.

A provider denied certification in another state shall be denied certification in Wisconsin, except that a provider denied certification in another state because the provider’s services are not MA-covered in that state may be eligible for Wisconsin border status certification if the provider’s services are covered in Wisconsin.

SOURCE: Department of Health Services Administrative Rules Sec. 105.48, (Accessed Apr. 2024).

Can I receive services from an out-of-state provider through telehealth?

Yes, you can receive services from an out-of-state provider if they are enrolled in Wisconsin Medicaid and follow Medicaid policy for prior authorizations (getting permission before the service occurs). Check with your provider to see if they qualify. If you are enrolled in a managed care program, you should check with them to determine who you can see.

If I am out of state, can I still receive telehealth services?

Maybe. Providers may be required to have a license to practice in the state where you are located. Check with your provider to see if they are able to provide telehealth services in the state where you are located.

SOURCE: Wisconsin Department of Health Services, Medicaid Telehealth Expansion: Frequently Asked Questions, May 11, 2023, (Accessed Apr. 2024).

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Wyoming

Last updated 05/13/2024

The billing Provider must comply with all licensing and regulatory …

The billing Provider must comply with all licensing and regulatory laws applicable to the Providers’ practice or business in Wyoming and must not currently be excluded from participating in Medicaid by state or federal sanctions.

SOURCE: WY Dept. of Public Health Insurance, Medicaid, CMS 1500 Provider Manual, p. 136-137 (Apr. 1, 2024), WY Division of Healthcare Financing Tribal Provider Manual, pg. 134 & 212, (Apr. 1, 2024); School Based Services Manual, pg. 16, (Apr. 1, 2024); & Institutional Provider Manual pg. 135.  (Apr. 1, 2024). (Accessed May 2024).

If the provider is an out-of-state, non-enrolled provider and renders services to a Medicaid client, the provider may choose to enroll in the Medicaid Program and submit the claim according to Medicaid billing instructions, or bill the client.  Out-of-state providers furnishing services within the state on a routine or extended basis must meet all of the certification requirements of the State of Wyoming. The provider must enroll in Medicaid prior to furnishing services.

Each site will be able to bill for their own services as long as they are an enrolled Medicaid provider (this includes out-of-state Medicaid providers).

SOURCE: WY Dept. of Public Health Insurance, Medicaid, CMS 1500 Provider Manual, pgs. 43 & 135 (Apr. 1, 2024), WY Division of Healthcare Financing Tribal Provider Manual, pg. 43, 133 & 211, (Apr. 1, 2024) & Institutional Provider Manual pgs. 45 & 134.  (Apr. 1, 2024). (Accessed May 2024).

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Medicaid & Medicare

Out of State Providers

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